The Berne Financial Services Agreement
His Majesty鈥檚 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.
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Details
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.听
This Agreement is built on the UK and Switzerland鈥檚 shared belief in open and resilient financial markets and it will cement the open access between the two nations for decades to come.听
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. 听 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.听
UK signs first of its kind financial services agreement with Switzerland听
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. An Explanatory Memorandum setting out background, framework, and principles of the Agreement, including a summary of the commitments in the Annexes.听 can be found here.听
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. The link to the report, and the government response, can be found .听听
On 15 July 2025, it was announced that the government is laying two statutory instruments in July to implement the UK鈥檚 commitments under the Berne Financial Services Agreement. 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.听
If you have any questions about the Berne Financial Services Agreement, you can get in touch at: uk.ch.mra@hmtreasury.gov.uk
Separate to the Berne Financial Services Agreement, the UK is also currently negotiating an听enhanced Free Trade Agreement听with Switzerland that will boost ties and cover the full range of trade between the two countries.
Updates to this page
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Added paragraphs to update on the progress of the Berne Financial Services Agreement through the Constitutional Reform and Governance Act process, including the Explanatory Memorandum, Lords International Agreements Committee report, and Government Response. Added an update on current timelines for the Agreement and an email to contact with any questions. Also made further amendments to update the language used to describe the Agreement.
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Sentence added at the bottom of the page to reflect that the UK is also currently negotiating an enhanced Free Trade Agreement with Switzerland that will boost ties and cover the full range of trade between the two countries.
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First published.