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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...
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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.
