How to Successfully Distribute ETFs in Switzerland

Global and European ETF issuance remained robust in 2025, with record product launches driven by:

• Active ETFs (transparent and semi-transparent)
• Fixed income ETFs
• Thematic and ESG ETFs, supported by AMAS and EU ESMA/SFDR developments.

Globally at the end of September 2025, the number of ETFs reported by ETFGI was 3,413 with total assets of more than $3,000bn, meaning a net new asset of $290bn YTD.

Source: ETFGI data reported in SIX Swiss Exchange ETF Market Report

In Europe, liquidity is anchored by the primary European venues, with Switzerland – through the SIX and Bern Stock Exchanges – among the top three ETF trading and listing centres in Europe.

Market Scale and Momentum

The Swiss ETF market continued its upward trajectory in 2025, reflected in notable growth across trading activity, turnover and the expanding universe of listed products:

• ETF turnover and transactions on SIX Swiss Exchange accelerated through H1 2025
• Average quarterly turnover exceeded CHF 30bn
• The number of listed ETFs surpassed 2,000 by June 2025
• H1 2025 ETF turnover and trades materially exceeded prior-year levels
• The average trade size was CHF 38,569 with the upward trend in trades over CHF 1,000,000 continuing to increase significantly.

Provided in the graph below is the quarterly ETF turnover and trades in Switzerland reported by the SIX Swiss Exchange.

Source: SIX Swiss Exchange ETF Market Report

Product Mix

Switzerland’s ETF listings showed two key trends in 2025:

1. New listings have been dominated by equity and bond ETFs
2. Commodities ETF listings had fewer launches in 2025 despite renewed investor interest.

Provided in the graph below is the quarterly ETF turnover and number of trades in Switzerland since 2019 on the SIX Swiss Exchange.

Source: SIX Swiss Exchange ETF Market Report

Market Quality and Infrastructure

The SIX Swiss Exchange provides:

• Multiple liquidity mechanisms
• Daily market quality metrics (MQM) for ETFs
• An efficient listing, clearing and settlement infrastructure
• Recognised market makers (MMs) ensuring continuous two-sided markets.

ETF assets and flows in Switzerland have expanded meaningfully since 2020. Market snapshots indicate ETF assets surpassed CHF 300bn in 2025 across the Swiss platform datasets, with cumulative positive flows YTD. Institutional fund assets also grew steadily post-2020, with 2024–2025 recovery from the 2022 drawdown.

Switzerland operates a three-pillared regulatory framework for funds and ETFs:

1. Product Law in the Collective Investment Schemes Act/Ordinance (CISA/CISO):
   CISA/CISO regulates collective investment schemes including foreign ETFs offered to retail investors.
2. Offering and Conduct Rules under the Financial Services Act/Ordinance (FinSA/FinSO):
   FinSA/FinSO covers prospectus requirements, client segmentation, point-of-sale obligations and documentation rules.
3. Licensing and Institutional Requirements under the Financial Institutions Act/Ordinance (FinIA/FinIO):
   FinIA/FinIO covers asset managers, fund management companies, and distributors operating in Switzerland.

Additional regulatory essentials to note:

• Prospectus review: A FINMA-licensed reviewing body must review and approve prospectuses for public offers or exchange admissions.
• Foreign funds: FINMA approval remains required for foreign collective investment scheme ETFs offered to retail clients.
• Qualified investor offers: These are largely notification/representation-based.

Offering ETFs to Non-Qualified (Retail) Investors

• FINMA approval of the foreign ETF collective investment scheme required before offering in Switzerland
• Appointment of a Swiss Representative and a Swiss Paying Agent
• Retail distribution ETF share classes must be listed on a Swiss exchange, typically SIX Swiss Exchange or Bern Stock Exchange, and meet the listing timetable/documentation requirements
• Prospectus must be reviewed by a licensed reviewing body and published pre-public offer/admission.

Offering Exclusively to Qualified Investors (including opted-out HNWIs as “professional investors” under FinSA)

• No FINMA product approval required
• Appointment of a Swiss representative and a Swiss paying agent remains required if offered to opted-out HNWI retail clients
• FinSA’s conduct duties apply at the point of sale:
  • Client segmentation
  • Information and
  • Documentation duties.

1. Appoint a recognised issuer representative

Engage a recognised issuer representative such as Waystone to prepare and file the listing package with SIX Exchange Regulation (SER).

2. Prepare and file listing documentation

Typical filing timelines are:

• At least 20 exchange days before first trading day
• 10 days for new sub-funds or new classes of an already listed umbrella.

3. Ensure prospectus compliance

A prospectus must be approved/recognised by a FINMA-licensed reviewing body and comply with FinSA/FinSO schemes for ETFs (passive vs active ETF frameworks).

4. Assign identifiers and coordinate market making

This includes:

• ISIN
• Swiss valoren number
• Ticker
• Market maker designation and two-way quotes.

5. Align listing with ongoing obligations under SER Listing Rules (May 2025 revision) and relevant directives

This includes:

• Official notice
• Disclosures
• Material event updates
• Ongoing governance obligations.

6. Coordinate FINMA processes (where relevant)

This stage requires:

• Coordination in parallel of FINMA approval (if retail share class) and publication requirements with the Swiss representative
• Synchronisation of first trading date with approval milestones.

Waystone delivers end-to-end solutions and guidance across the ETF lifecycle for managers seeking to launch ETFs across Europe, including:

• Evaluating and selecting the optimal domicile (Ireland, Luxembourg, or other UCITS jurisdictions)
• Advising on fund architecture (umbrella vs. standalone)
• Ensuring compliance with UCITS and MiFID frameworks
• Coordinating service providers for portfolio management, custody, and market-making
• Integrating ESG and sustainability standards aligned with AMAS and EU SFDR
• Passporting strategies for cross-EU distribution to maximize reach
• Determining listing venues and distribution perimeter
• Designing cross-border market access strategies.

To support ETF structuring in Europe, Waystone delivers core ETF solutions in Ireland and Luxembourg:

• White Label Multi-Manager ETF Platform Solutions: Waystone’s white-label platform enables clients to build and launch world-class ETFs efficiently and cost effectively, providing the best time-to-market option and all service providers contracted.
• Client Dedicated ETF Platform Solutions: This solution enables clients to launch and operate ETFs via a bespoke, standalone structure that preserves full brand identity, governance and strategic flexibility, while leveraging Waystone’s institutional infrastructure, operational expertise and ETF experience.
• UCITS Management Company (ManCo) ETF Solutions: Our leading ManCo platform in Ireland and Luxembourg provides clients with access to Waystone’s ETF expertise across governance, capital markets and operations—while retaining full control to select service providers and manage the fund.
• ETF Capital Markets Solutions: Our experienced ETF Capital Markets team supports and advises on all matters related to the appointment of Market Makers and Authorised Participants.

Waystone was one of the first Swiss Representatives to specialise in ETFs. Our Swiss ETFs experts help clients to:

• Navigate regulatory complexity with ease including CISA, FinSA, and FinIA
• Provide the Swiss Representative service and coordinating the appointment of the Paying Agent
• Prepare FINMA filings for retail distribution
• Ensure the prospectus is review by licensed bodies
• Handle the SIX Swiss Exchange listing process, from drafting the listing application and coordinating with recognised issuer representatives to securing market maker arrangements
• Advise on ongoing obligations under SIX Listing Rules and AMAS sustainability self-regulation.