Key Takeaways
- Definition: an actively managed certificate (AMC) is a structured product whose underlying assets are managed on a discretionary basis, throughout the product's life, according to a defined investment strategy. The investor holds a single security – with an ISIN, bookable in any bank custody account – that tracks the value of that strategy.
- It is not a fund: legally, an AMC is a claim against its issuer, not a share of a segregated pool of assets. It is not a collective investment scheme under the Swiss CISA: the specific protection funds enjoy – assets separated from the bankruptcy estate – does not apply.
- The central risk is issuer risk: if the issuer defaults, a total loss is possible, whatever the performance of the underlying strategy. That risk shrinks when the certificate is issued by a dedicated securitization vehicle whose assets are held as collateral – a point the documentation should settle.
- A heavyweight of the Swiss market: structured products recorded about CHF 235 billion in turnover in Switzerland in 2025, up 18% year on year – and AMCs are among the segments driving that growth.
- Why the success: an AMC launches in weeks rather than months, at lower setup costs than a fund, with wide freedom in the investment universe – from equities to digital assets.
- A framework exists: the recommendations of the Swiss Structured Products Association (SSPA) have imposed minimum standards since 2020 – a documented strategy, continuous pricing, fees itemized line by line, and a ban on the advisor double-dipping on components of the underlying.
- Key reflex: an AMC is neither a good nor a bad wrapper in itself. The questions that matter – who the issuer is, whether the certificate is collateralized, what the full fees are, where the composition can be consulted – find their answers in the product documentation.
Introduction
Switzerland is the world's leading market for structured products: about CHF 235 billion in turnover in 2025, up 18% year on year. Within that family, one wrapper is enjoying a particular boom: the actively managed certificate, or AMC – the instrument that turns an actively managed investment strategy into a single, tradable, bankable security.
Independent wealth managers, banks, and specialized asset managers use it to offer access to equity, bond, alternative, or digital-asset strategies without creating a fund. Investors, for their part, encounter it more and more often in their portfolios – sometimes without its legal nature, very different from a fund's, having been fully explained.
This article describes what an AMC is, what it is not, where its Swiss success comes from, and the points its documentation should clarify – neither recommending nor advising against the wrapper: as so often, what matters most is understanding what you hold.
What Is an Actively Managed Certificate?
The reference definition comes from the SSPA recommendations: AMCs are structured products whose underlying assets are, during their lifetime, managed on a discretionary basis according to a specific investment strategy. In practice, three parties share the roles:
- The issuer – a bank, a securities firm, or a securitization vehicle – issues the certificate and replicates its value synthetically: the security tracks the strategy whether or not the issuer holds the corresponding assets.
- The strategy advisor (the "AMC Advisor" in SSPA terminology) – often a wealth manager – composes and restructures the underlying assets at its discretion, within the framework of the documented strategy.
- The investor – buys a single security, with an ISIN, whose value moves with the strategy, net of fees.
The value of an AMC therefore depends directly on the advisor's ability to execute the strategy – that is what "actively managed" means. Unlike an index tracker, the composition is not fixed by mechanical rules: it evolves with management decisions, within the limits the documentation imposes (permitted asset categories, any leverage, diversification rules, restructuring frequency).
What an AMC Is Not: A Fund
The essential difference fits in one sentence of the SSPA recommendations: the investor in an AMC has no recourse against the underlying assets, only against the issuer of the certificate.
In a Swiss investment fund governed by the CISA, investors' assets form a separate estate: if the fund management company or the custodian bank fails, the fund's assets are segregated from the bankruptcy estate for the benefit of unit holders. An AMC does not fall under the CISA: it belongs to the category of structured products, governed by the Financial Services Act (FinSA) – which requires documentation (a key information document, a prospectus where applicable) but neither asset segregation nor fund-style authorization.
Capital invested in an AMC sits on the issuer's balance sheet, like any other debt. That difference is not a technicality: it shifts the product's main risk from the strategy to the balance sheet of whoever issues it.
Issuer Risk – and How It Can Be Reduced
The direct consequence is counterparty risk: if the issuer defaults, a total loss is possible, regardless of the quality of the underlying strategy. An AMC's documentation must inform investors about the credit risks relating to the issuer – an explicit requirement of the SSPA recommendations.
The market has, however, developed structures that mitigate this risk:
- Classic bank issuance: the certificate is a debt of the issuing bank. The investor carries that institution's credit risk, as with any uncollateralized structured product.
- Issuance through a securitization vehicle (SPV): specialized platforms issue the certificate through a dedicated entity, off any bank's balance sheet, in which the assets corresponding to the strategy are actually held and pledged for the benefit of holders. Counterparty risk is reduced – it shifts toward the quality of the custody and of the legal structure.
- Collateralized products: some listed certificates rely on standardized collateralization mechanisms, where security is deposited to cover the product's value.
None of these structures turns an AMC into a fund; but the risk gap between an uncollateralized certificate and a collateralized one is substantial. It is the first question the documentation should settle.
Why Switzerland Loves AMCs
Three reasons explain the wrapper's rise:
- Speed: an AMC typically launches in a few weeks, where creating a fund – authorization, governing bodies, documentation – takes months. To test a strategy or catch a market window, the difference is decisive.
- Cost: setting up and administering a certificate is markedly lighter than a fund. The digitization of issuance – "securitization as a service" platforms – has lowered the entry ticket further, opening the instrument to more managers and broader investor circles.
- Flexibility: an AMC's investment universe can cover assets that are hard to fit into a traditional fund – niche strategies, alternatives, digital currencies – while remaining an ordinary bankable security from the custody point of view.
The regulator is watching this growth closely: as early as 2021, FINMA flagged business models built on AMCs stuffed with the issuer's own instruments as carrying elevated risks, requiring separate risk management and reinforced internal controls. And the SSPA has codified best practice: a strategy advisor with an adequate organization (at least two qualified people), a strategy recorded in writing and communicated understandably, prices established continuously under normal market conditions – not once a day – and full fee transparency.
AMC, Fund, ETP: The Comparison Table
| Criterion | AMC | Fund (CISA) | Backed ETP (crypto) |
| Legal nature | Claim against the issuer (structured product) | Share of a segregated collective estate | Claim against the issuer, generally collateralized |
| Protection in bankruptcy | ⚠️ No segregation (unless SPV/collateral structure) | ✅ Assets carved out of the bankruptcy estate | 🔶 Pledged collateral, depending on the structure |
| Product authorization | No fund-style authorization; FinSA documentation | FINMA authorization and supervision | Listing and documentation; not a fund |
| Launch | ✅ Weeks, lower costs | ⚠️ Months, high costs | In between |
| Investment universe | ✅ Very broad (including digital assets) | Framed by fund regulation | Generally one defined asset or basket |
| Management | Active, discretionary | Active or index-based | Mostly passive |
| Fees | Per documentation – to be read line by line | Published TER, regulatory framework | Published management fees |
The table does not crown a "best" wrapper: it shows that the same phrase – "investment product" – covers different legal realities, and that asset protection, speed to market, and freedom of management are traded against one another.
Fees: What the Documentation Must Show
The SSPA recommendations are precise: all applicable fees must be clearly stated in the product documentation, and for each item, the amount or its calculation method, how it is charged, who receives it, and the service provided in return. Added to this is an important rule: the ban on double dipping – the strategy advisor may not collect compensation on components of the underlying assets (retrocessions, commissions) without crediting it back to the underlying.
In practice, an AMC's cost structure generally combines a management fee, issuance and administration costs, and bid-ask spreads on entry and exit. Depending on the strategy and the platform, the total can be lower or higher than a comparable fund's – the difference being that a fund publishes a standardized TER, while an AMC requires a careful reading of its documentation. Supervisory authorities have, in fact, made AMC cost transparency an explicit point of attention.
The Digital Angle: Why So Many Crypto Strategies Use AMCs
Digital currencies and assets figure explicitly among an AMC's possible underlyings – and the wrapper has become one of the preferred access routes to crypto strategies in Switzerland, alongside backed ETPs.
The reasons are those already described, taken to their maximum: housing digital assets in a traditional CISA fund remains a narrow exercise, whereas an AMC can replicate an actively managed crypto strategy and make it bankable – an ISIN in an ordinary custody account, with no digital wallet or direct token custody for the investor.
The reading grid is rigorously the same as for any AMC, with added weight in places:
- Issuer and collateral first: for a volatile underlying held by specialized custodians, the question "who holds what, and what happens on default?" matters even more. Crypto ETPs generally answer with collateral held in custody; for an AMC, the answer depends on the issuance structure.
- Liquidity next: an unlisted certificate is sold back to the issuer, on the terms set by the documentation; the continuous pricing recommended by the SSPA takes on its full importance here.
- Fees last: management fees, specialized custody, and spreads add up on markets that are already volatile.
Limits and Points of Attention
Four points complete the picture. First, conflicts of interest: when the strategy advisor is also the wealth manager or the distributor to the end investor, the SSPA requires organizational measures and disclosure of those conflicts to the client and to the issuer – something the documentation should reflect.
Second, liquidity: not all AMCs are listed. For an unlisted certificate, the exit depends on the redemption terms set by the issuer; the depth of the secondary market bears no comparison with an open-ended fund's redemption mechanism.
Third, taxes: the tax treatment of an AMC for a private investor in Switzerland depends closely on the product's structuring and tax reporting – the split between taxable income and capital gain is not uniform from one certificate to the next. Each product's status can be checked in its documentation and in the Federal Tax Administration's price list.
Finally, a perimeter remark: the rise of AMCs also has implications on the manager side – beyond certain asset thresholds, managing an AMC can requalify its advisor as a collective asset manager subject to authorization. A sign, if one were needed, that the border between the structured wrapper and the fund world is closely watched.
Conclusion
The actively managed certificate is one of the most characteristic instruments of the Swiss financial center: a wrapper that turns a management strategy into a single security, in a few weeks, with unmatched freedom in the investment universe – at the price of a legal nature that has to be understood: a claim against an issuer, without a fund's asset segregation.
The SSPA recommendations have given the market a best-practice framework – documented strategy, continuous pricing, itemized fees, disclosed conflicts of interest – that equips investors to ask the right questions: who issues, with what collateral, at what cost, and under what consultable strategy. Answers that appear – or should appear – in each certificate's documentation.
For another illustration of how technology is transforming access to assets, we refer the reader to our article on real estate tokenization.
Sources
- ASPS / SVSP – « Recommandations concernant les certificats activement gérés ou "actively managed certificates" (AMC) » (adopted December 13, 2019, in force March 31, 2020)
- BDO – « Actively Managed Certificates (AMC) », Wealth Management News
- Everon – « AMCs (certificats gérés activement) : conseils et informations »
- KM3 Asset Management – "The Rise of Actively Managed Certificates (AMCs): 2026 Market Update" (SSPA market data)
- Federal Act on Financial Services (FinSA), SR 950.1
- Federal Act on Collective Investment Schemes (CISA), SR 951.31
