The Berne Financial Services Agreement

Explaining the UK-Switzerland Agreement on Mutual Recognition in Financial Services

Just over two years after its signing in December 2023, the Berne Financial Services Agreement (BFSA) came into effect on 1 January 2026. This marks a major milestone in the relationship between two of the world’s foremost financial and professional services hubs, now connected more closely than ever before. The BFSA represents a significant diplomatic achievement and breaks new ground in financial services trade arrangements. 

The agreement facilitates wholesale cross‑border services trade to the benefit of both UK and Swiss firms. It enables UK insurance companies and intermediaries to supply Swiss corporate clients on a cross‑border basis. Swiss investment services firms, including private banks, wealth managers and advisers, can likewise provide services to UK corporates and sophisticated clients without additional authorisation, relying instead on a simple registration process. 

The BFSA is a mutual recognition agreement: each country recognises the other’s regulatory regimes and supervision, committing to enabling free cross‑border market access in the covered sectors. A landmark framework for the financial services sector, it reflects the close partnership between the UK and Switzerland. Building on the early momentum of the agreement, the UK and Swiss governments are now negotiating a services‑focused Free Trade Agreement.