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The Berne Financial Services Agreement (BFSA) entered into force on 1 January 2026. The BFSA facilitates cross-border financial services between the UK and Switzerland by recognising the equivalence of each country's regulatory frameworks. It applies only to specified sectors, client types and financial instruments. To implement the BFSA, the UK has introduced legislative amendments alongside updates to the FCA Handbook and PRA Rulebook.
For Swiss firms, the BFSA operates alongside the existing UK regulatory framework; it cannot be used simultaneously with either the Part 4A FSMA permission regime or the Overseas Persons Exclusion for the same activity.
The FCA announced in late January 2026 that the first notifications under the BFSA have been successfully received from both UK and Swiss firms. These notifications are being validated by the respective regulators before firms can be added to host authority registers.
This blog post summarises the key elements of the BFSA, with a particular focus on how Swiss firms may rely on it to provide services into the UK.
To read the full post, please click on the link below.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
