UK regulators the FCA and the Prudential Regulation Authority (PRA) have introduced the Berne Financial Services Agreement (BFSA) to make it easier for UK and Swiss firms to conduct business in each other's country.
The BFSA, which took effect on 1 January 2026, is based on the understanding the UK and Switzerland’s supervisory and regulatory regimes are of a similarly high standard and achieve equivalent outcomes in specified financial services relating to market integrity, financial stability and the protection of consumers and investors.
The agreement creates a new model for regulatory and supervisory cooperation by enabling firms to take part in cross-border trade in financial services to wholesale and sophisticated clients.
FCA looks to boost cross-border services between UK and Switzerland
This is done by deferring to the relevant regulatory and supervisory rules in the other country, which the FCA says removes the need for businesses to navigate unfamiliar rules.
Eligible firms must be authorised to supply the relevant services in their domestic market and placed on the relevant BFSA register.
The PRA and the FCA have jointly published guidelines to assist firms that are considering providing services under the BFSA.
