Research and legal mapping
The starting point was a review of the primary legal sources, FinIA, FinIO, and FinIO-FINMA, to identify licensing thresholds and requirements applicable to portfolio managers and trustees. The commerciality threshold (CHF 50,000 annual gross income) determines whether the licensing obligation is triggered at all.
Actor identification
All actors involved in the licensing process were then identified and structured as swim lanes: the financial institution, the supervisory organisation (SO), external auditors, the ombudsman, FINMA, and the EHP platform. The EHP (Electronic Survey and Application Platform) is the sole digital channel for submitting documentation throughout the process, which explains the recurring "To EHP" annotations in the diagram rather than direct bilateral interactions with FINMA.
Diagram drafting and iteration
The visual was assembled as a diagram, arranging swim lanes, decision diamonds, and document symbols into a BPMN-like layout. Several iterations were required to correctly reflect the conditional logic.

