Berne Financial Services Agreement prompts uptick in UK brokers serving Swiss clients
In January 2026, a new agreement between the UK and Switzerland changed the landscape for UK financial services firms wishing to market their products and services to Swiss clients. The Berne Financial Services Agreement (BFSA) came into force on 1 January 2026 and makes things considerably easier for UK financial services firms to conduct business in Switzerland. In response, there has been a distinct uptick in interest from UK brokers, looking to market their services to potential Swiss institutional clients.
No Extra Paperwork Required
If your firm is already authorised by the FCA, PRA or Bank of England, and is actively providing financial services in the UK, you are now able to solicit business and provide those same services to Swiss clients on a cross-border basis, without needing additional Swiss authorisation. Under the agreement, Switzerland will defer to your existing UK regulatory permissions for this purpose.
In practice, this means that UK brokers can now market their services to institutional Swiss clients without having to seek separate approval from FINMA, the Swiss financial regulator.
Just One Notification Before Direct Marketing in Switzerland can Commence
The BFSA also allows brokers to send employees, or Client Advisers, to Switzerland on a temporary basis to meet and conduct business with clients directly. Under the agreement, firms must simply conduct a one-off notification to the FCA before commencing any type of activity on the ground in Switzerland.
In addition to the FCA notification, firms would also need to ensure:
• Client Advisers meet the relevant Swiss FINSA conduct and knowledge requirements (broadly equivalent to UK standards)
• Appropriate professional indemnity insurance is held
• Affiliation with the Swiss ombudsman is sought (if required); and
• A disclosure document is provided to any potential Swiss client before services commence.
The notification is also a one-off requirement and does not need to be repeated each time an employee travels to Switzerland.
Temporary is the Magic Word
It’s worth noting that the BFSA applies only where a firms Swiss activity is of a temporary nature. Should on the ground services and staffing become regular, amounting to a permanent position in Switzerland, local authorisation should be sought.
Get in Touch
If you have any questions about how the BFSA may affect your firm, or if you would like assistance with the FCA notification process, please do not hesitate to get in touch with us at ComplyCraft Consulting.