Opportunities offered by the Berne Financial Services Agreement

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. 

Berne Financial Services Agreement – Now Live

Hear testimonies about the agreement from regulators, government officials, and business representatives.

Key facts and figures

• Switzerland is the UK’s 10th biggest trading partner – with bilateral trade worth more than £45bn in 2024. 
• Services exports account for more than £18bn of the UK-Swiss trading relationship, making Switzerland the UK’s 6th largest services export partner. 
• Services sit at the heart of the two countries’ economic relationship, with bilateral services trade worth around £28bn annually.  
• The UK-Swiss trading relationship supported 130,000 services jobs across the UK in 2020. 

Further links and resources

We urge companies to explore the BFSA’s possibilities for expanded access and trade – in both Switzerland and the UK. To find out more about the agreement and guidelines on utilising it:

• Berne Financial Services Agreement for UK and Swiss firms | FCA 
• Berne Financial Services Agreement (BFSA) Operational Direction and Guidelines for UK Insurers’ Section IV Notifications | Bank of England 
• FINMA publishes guidelines on the Berne Financial Services Agreement | FINMA 

This paper, published the City of London Corporation and Clifford Chance in March 2024, offers a practical explanation of the BFSA and its benefits for firms.