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UK–Swiss Hub

Insights

This hub tracks the Berne Financial Services Agreement and UK–Swiss market access, and what mutual recognition means in practice.

In force since 1 January 2026, the Berne Financial Services Agreement opens direct routes between the UK and Swiss markets for defined financial services: chiefly cross-border investment services by eligible Swiss firms to professional and high-net-worth clients in the UK, and cross-border non-life insurance by eligible UK insurers to large Swiss corporates, with narrower relief for UK client advisers and provisions that preserve existing access. The benefits differ by direction, sector, firm and client category. This hub collects the official sources on eligibility, notification and ongoing obligations.

Featured insights

18 June 2026|Client Update

What the Berne Financial Services Agreement changes for UK–Swiss financial services

See update 23 June 2026|Client Update

A Swiss firm's practical guide to serving UK clients under the BFSA

See update

Client Updates

BFSA analysis, together with UK regulatory developments that Swiss firms with UK business will meet: AI regulation, corporate criminal liability, cryptoasset authorisation.

22 September 2026|Client Update

Identity verification at UK Companies House and the company-by-company deadlines to 17 November 2026

8 September 2026|Client Update

The limits of the UK overseas persons exclusion and of the appointed representative route for Swiss firms

2 September 2026|Client Update

What the Berne Agreement gives UK firms in Switzerland

1 September 2026|Client Update

Four positions for a Swiss firm's UK business outside the Berne Agreement

27 August 2026|Client Update

How the United Kingdom regulates AI without an AI Act

19 August 2026|Client Update

The four BFSA notification routes, step by step

4 August 2026|Client Update

The BFSA client test: which UK clients a Swiss firm may take on

2 August 2026|Client Update

The UK failure-to-prevent-fraud offence and non-UK groups

16 July 2026|Client Update

The UK cryptoasset regime: the FSMA gateway, 30 September 2026 to 28 February 2027

Resources by topic

The Agreement

Agreement between the United Kingdom and Switzerland on Mutual Recognition in Financial Services (Berne Financial Services Agreement), signed 21 December 2023, in force since 1 January 2026

Official text and related documents (GOV.UK) Swiss overview: State Secretariat for International Finance (SIF) Swiss systematic compilation, SR 0.950.136.7 (Fedlex)
United Kingdom: implementation

FCA: the BFSA for UK and Swiss firms: eligibility, notifications and registers

FCA BFSA page FCA BFSA Guidelines for firms (PDF)

The Financial Services and Markets Act 2023 (Mutual Recognition Agreement) (Switzerland) Regulations 2025 (SI 2025/1145)

Full text (legislation.gov.uk)

The OTC Derivatives Risk Mitigation and Central Counterparties (Equivalence) (Switzerland) Regulations 2025 (SI 2025/898): the financial-market-infrastructure commitments (OTC derivative risk mitigation, Swiss CCP recognition), in force 1 January 2026

Full text (legislation.gov.uk)
Switzerland: implementation

FINMA on the Berne Financial Services Agreement: legal basis and supervisory practice

FINMA BFSA page FINMA BFSA guidelines for investment services and insurance suppliers (version of 8 January 2026, PDF)

State Secretariat for International Finance (SIF): Switzerland–UK financial services relations

SIF: United Kingdom
See how we support firms using the Agreement on our United Kingdom page and in Financial Regulation.

Last reviewed: 26 September 2026. The materials on this page are provided for general information only, do not constitute legal advice and do not create a lawyer–client relationship. Links to official sources are provided for convenience; always rely on the current official text.