The United Kingdom for Swiss and European firms: access under the Berne Financial Services Agreement, authorisation under FSMA where the Agreement does not reach, and the UK rules that follow the route and the client.
Four routes lead into the UK market, and they suit different business models. Under the Berne Financial Services Agreement, in force since 1 January 2026, eligible Swiss firms may serve UK per se professional and high-net-worth clients and eligible counterparties without UK authorisation, on a notification through FINMA and entry on the FCA's BFSA register, which must precede the first service. Firms outside the Agreement, or serving clients it does not cover, may be able to rely on an applicable exclusion after an activity-specific analysis: the overseas persons exclusion covers dealing, arranging and advising from outside the UK, and only agreeing to manage or safeguard investments, and it turns on whether the activity is carried on in the UK at all and on a legitimate approach, which needs to be documented from the start. Where the model needs a UK presence, Part 4A authorisation of a UK branch or subsidiary is the answer, sequenced against the FCA's requirements and, for banks and designated investment firms headquartered outside the UK, the expectations the PRA sets out in Supervisory Statement SS5/21 (April 2026 version). Digital-asset firms have a separate timetable: the FSMA cryptoasset gateway, the application path to Part 4A authorisation or a variation of permission for the new cryptoasset activities, is open from 30 September 2026 to 28 February 2027 under the FCA's direction of 20 February 2026, for a regime that goes live on 25 October 2027; the overseas persons exclusion is not available for those activities, so a non-UK firm's question is territorial scope.
Which UK rules apply depends on the route. A Swiss firm registered under the Agreement is subject to Swiss conduct rules for its Annex 5 services, with the Agreement's own client tests and disclosure duties, and the FCA Handbook disapplied for those services (GEN 2.4); a firm authorised in the UK, or serving UK clients outside the Agreement's deference, carries UK conduct rules into the engagement, including client categorisation and, where retail clients are served, the Consumer Duty. The failure-to-prevent-fraud offence has been in force since 1 September 2025 and reaches qualifying large organisations, including non-UK organisations where the fraud has the statutory UK nexus. Since 28 January 2026 the UK Sanctions List has been the single source of UK designations. UK GDPR applies to groups whose processing falls within its territorial scope: processing in the context of a UK establishment, or an overseas group's offering of goods or services to people in the UK or monitoring of their behaviour there (Article 3); UK users alone do not bring a group within it. The UK regulates AI through its existing regulators and their sectoral rules; there is no UK AI Act.
The Agreement also runs the other way. UK firms entering Switzerland work under its Swiss annexes: for investment services the deference is limited to relief from client-adviser registration, while eligible UK insurers may write specified non-life business for large Swiss corporates on their UK authorisation; where the model needs more, conventional Swiss licensing applies. English-law documentation and UK regulatory analysis are provided under the England & Wales admission, and the Swiss side is advised from Zurich, with a registered Swiss lawyer for any step that Swiss law reserves to one.
Access routes and the UK rules that follow each route. Jurisdictions: United Kingdom and Switzerland.