Switzerland’s alternative investment market is evolving quickly. The Limited Qualified Investor Fund (L-QIF) has made it faster than ever to launch a Swiss fund, and tokenisation is opening new ways to structure private investments. At the same time, the regulatory perimeter is being redrawn: a possible tightening of the “Lex Koller” real estate rules and a wider Anti-Money Laundering Act (AMLA) regime from October 2026 both demand close attention. Dr Alexander Schiemenz and Dr Tatiana Zakharova set out five questions every fund sponsor, investor and adviser should be asking.

1. What is the L-QIF, and why does it matter?

The L-QIF is a new category of Swiss fund that can be launched without FINMA product approval, provided it is limited to qualified investors and managed by a FINMA-supervised institution. It is not an “unregulated” fund: the manager remains supervised and reporting duties apply, but it allows far more flexibility in investment strategy, structure and timeline than a traditional FINMA-approved fund. Since its amendments to the Collective Investment Schemes Act entered into force on 1 March 2024, it has quickly become the most significant development in the Swiss fund market in years.

2. If Switzerland has the L-QIF now, why do many managers still set up funds abroad?

Regulation is rarely the main reason. Switzerland sits outside the EU and EEA, so a Swiss fund has no automatic marketing passport under the AIFMD. Marketing to professional investors in Europe can mean separate filings in every country. Luxembourg, Ireland and Malta, by contrast, let an authorised manager market an EU or EEA fund across the EEA through a single notification. Tax treatment, investor familiarity and established service-provider ecosystems add to the calculus. In many cases, the manager stays in Switzerland while the fund itself is set up abroad.

3. What would the proposed Lex Koller reform change for real estate investors?

Nothing is final yet: the proposal went through consultation in 2026 and remains subject to parliamentary process. But as drafted, it would be a meaningful tightening: listed real estate funds, SICAVs and real estate L-QIFs would lose their current exemption from the “persons abroad” restrictions, commercial property bought purely as an investment (rather than for the buyer’s own business use) would generally require authorisation, and the national quota for holiday homes would be cut from 1,500 to 750 units a year. Investors and fund managers with exposure to Swiss real estate should be watching this closely.

4. Who is newly caught by the 2026 AMLA reform?

From 1 October 2026, certain lawyers, notaries, family offices, fiduciaries and advisers become subject to anti-money-laundering duties when they take part in specified transactions: real estate deals, setting up or administering asset-holding entities, company sales, and longer-term domiciliation services, among others. Crucially, this is transaction-specific, not status-based: a law firm can be covered for one mandate and not for another, and traditional legal advice (opinions, litigation strategy, representation) remains protected by professional secrecy. Firms affected should be reviewing mandates and updating engagement procedures now.

5. Can you really put a building “on the blockchain”?

Not quite. Tokenisation changes how rights in an asset are recorded and transferred. It does not change what those rights are. A token representing, say, a stake in a property-holding company is still subject to the same company law, tax treatment and, where relevant, Lex Koller restrictions as the underlying right. Switzerland’s DLT legislation (in force since February and August 2021) gives tokenisation a solid legal basis, and FINMA licensed the country’s first DLT trading facility in March 2025. But custody, tax and compliance questions do not disappear just because an asset is digital. If anything, they require more careful structuring, not less.

This is a short overview of a fast-moving area. For the full legal analysis, including the detailed treatment of L-QIF taxation, the AMLA sanctions-compliance obligations, and the practical structuring questions around tokenised investments, read the complete Trends & Developments article by Dr Alexander Schiemenz and Dr Tatiana Zakharova for Chambers Global Practice Guides: practiceguides.chambers.com – Switzerland, Alternative Funds 2026, Trends & Developments

Have questions about how these developments affect your fund, investment structure or compliance set-up? Get in touch with LINDEMANNLAW team.