Berne Financial Services Agreement
The Berne Financial Services Agreement is an agreement between Switzerland and the United Kingdom. It enables or simplifies cross-border market access between to the countries for financial service suppliers in the sectors of investment services and insurance in Switzerland and the United Kingdom.
The Berne Financial Services Agreement (BFSA) allows Swiss financial servicessuppliers especially to provide cross-border investment services for professional and high-net-worth clients in the United Kingdom (UK) in selected areas. Under the agreement, British insurance companies can provide cross-border services in Switzerland in selected areas of non-life insurance. In the area of financial market infrastructures, the BFSA facilitates the recognition of central counterparties, strengthens cooperation between parties with regard to trading venues, and simplifies certain requirements for over-the-counter derivatives. In the area of asset management, the agreement sets out the regimes already in force in Switzerland and the UK.
The BFSA is scheduled to enter into force on 1 January 2026. The new cross-border market access provided for in the agreement as well as the corresponding notification form on the EHP will be available from that date.
Memorandum of understanding formalises cooperation
The BFSA seeks closer cooperation between the supervisory authorities of the two countries in the sectors of investment services and insurance, where deference is provided for. It thus strengthens the stability and integrity of the financial system and the protection of clients and investors. To this end, SFMA, the Financial Conduct Authority (FCA) and the Bank of England in its capacity as the Prudential Regulation Authority (PRA) have signed a memorandum of understanding. This formalises the cooperation and sets out the arrangements for implementing supervisory cooperation under the BFSA in the sectors of investment services and insurance.
Guidelines for financial service suppliers
SFMA, like the FCA and the PRA, has provided guidelines for investment services and insurance services suppliers. Institutions wishing to utilise the possibilities of the BFSA will find more detailed explanations and instructions in these:
- SFMA guidelines
- FCA/PRA guidance
Further information on the BFSA can be found at the following links:
- Original text of the agreement
- Dispatch on the approval of the agreement
- FCA page on the BFSA
Investment services– process and responsibilities
The related information for this topic is set out in the following section.
Notification process in the area of investment services
The related information for this topic is set out in the following section.
Reporting process in the area of investment services
To the EHP login
Questions relating to the BFSA can be sent by email to info@swissfma.com.
Charts and visual information

