The Berne Financial Services Agreement
Source: gov.uk (2025-08-14)

His Majesty’s Treasury of the United Kingdom of Great Britain and Northern Ireland and the Federal Department of Finance of the Swiss Confederation have signed a ground-breaking agreement to enhance the cross-border market access of financial services between the UK and Switzerland.

The Berne Financial Services Agreement between the UK and Switzerland uses outcomes-based mutual recognition of domestic laws and regulations to enable cross-border trade in financial services to wholesale and sophisticated clients. The Agreement was signed in December 2023 and implementation is currently underway.

This Agreement is built on the UK and Switzerland’s shared belief in open and resilient financial markets and it will cement the open access between the two nations for decades to come.

At its heart is a new and innovative model of mutual regulatory recognition. This provides stability for UK businesses supplying financial services to clients in Switzerland and supports unprecedented new market access. The Agreement provides for UK firms to provide some wholesale insurance services into Switzerland without supervisory authorisation from Swiss supervisory authorities. For investment services, Swiss firms will have access to the UK to provide some wholesale investment services without authorisation. The Agreement provides for UK firms to provide some wholesale insurance services into Switzerland without supervisory authorisation from Swiss supervisory authorities. For investment services, Swiss firms will have access to the UK to provide some wholesale investment services without authorisation.

UK signs first of its kind financial services agreement with Switzerland (https://www.gov.uk/government/news/uk-signs-first-of-its-kind-financial-services-agreement-with-switzerland)

For the UK, the first step in implementing the Berne Financial Services Agreement was for Parliament to scrutinise it in accordance with Section 20 of the Constitutional Reform and Governance Act 2010, which all international treaties entered into by the UK are subject to. Please see the Explanatory Memorandum (https://www.gov.uk/government/publications/ukswitzerland-agreement-on-mutual-recognition-in-financial-services-cs-switzerland-no12024) setting out background, framework, and principles of the Agreement, including a summary of the commitments in the Annexes.

The Lords International Agreements Committee conducted an inquiry as part of their scrutiny of the Agreement. The Committee approved the Agreement for ratification in April 2024. Please see the report and the government response. (https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fcommittees.parliament.uk%2Fwork%2F8202%2Fukswiss-financial-services-agreement%2Fpublications%2F&data=05%7C02%7CDigitalCommunications%40hmtreasury.gov.uk%7Cdfccfb54a0dc4623925908dddb1a0e3d%7Ced1644c505e049e6bc39fcf7ac51c18c%7C0%7C0%7C638907627204103044%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=m1lXuwm6KXOzcsIsdlnn3t%2FPGG5FrTOtpxEa9G%2Brg%2Bg%3D&reserved=0)

The UK and Switzerland have committed to ensuring the Agreement is fully implemented by the end of this year so firms can start registering to use the Agreement on 1 January 2026. On 21 July 2025, the government laid two statutory instruments to implement the UK’s commitments under the Berne Financial Services Agreement. Please see information on the statutory instruments and their progress (https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fstatutoryinstruments.parliament.uk%2Finstrument%2FHyz72MH8%2Ftimeline%2Fci9egFsk&data=05%7C02%7CDigitalCommunications%40hmtreasury.gov.uk%7Cdfccfb54a0dc4623925908dddb1a0e3d%7Ced1644c505e049e6bc39fcf7ac51c18c%7C0%7C0%7C638907627204152302%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=cF4L%2BQaf5R57puKf%2BiUyiGj4CgbP2gF8NcXqSI1eVtQ%3D&reserved=0) and also at this link (https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fstatutoryinstruments.parliament.uk%2Finstrument%2FNxUIow8q%2Ftimeline%2FHB8UfGgb&data=05%7C02%7CDigitalCommunications%40hmtreasury.gov.uk%7Cdfccfb54a0dc4623925908dddb1a0e3d%7Ced1644c505e049e6bc39fcf7ac51c18c%7C0%7C0%7C638907627204195276%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=Xxze%2Fg9zTa%2Ff0csdG7coZ1jo2%2FgcH930isnoAm9Isa0%3D&reserved=0).

If you have any questions about the Berne Financial Services Agreement, you can get in touch at: xxx@xxx.xx (mailto:xxx@xxx.xx)

The Financial Conduct Authority (FCA) have launched a webpage on the Berne Financial Services Agreement for UK and Swiss firms, including an expressions of interest form for financial services firms interested in receiving future updates and information on the Agreement. Firms can express interest by visiting the FCA’s website. (https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.fca.org.uk%2Ffirms%2Fberne-financial-services-agreement&data=05%7C02%7CDigitalCommunications%40hmtreasury.gov.uk%7Cdfccfb54a0dc4623925908dddb1a0e3d%7Ced1644c505e049e6bc39fcf7ac51c18c%7C0%7C0%7C638907627204235916%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=FfxEMkmkK0KJKmg5tU3e5r2kG4usMU1j5YYE1Zd4R%2Bo%3D&reserved=0)

Submitting an expressions of interest form does not mean that you will be automatically registered to use the Agreement on 1 January 2026.

Separate to the Berne Financial Services Agreement, the UK is also currently negotiating an enhanced Free Trade Agreement (https://www.gov.uk/government/collections/uk-switzerland-enhanced-free-trade-agreementnegotiations) with Switzerland that will boost ties and cover the full range of trade between the two countries.