Britain and Switzerland have begun the first joint review of how firms are using their cross-border financial services agreement. HM Treasury's joint statement, published on 5 November 2026, says the agreement's Joint Committee met for the first time during the financial dialogue in London on 4 November. Officials and supervisors discussed take-up and the agreement's operation, with further reflection planned before their next dialogue in Switzerland in the second half of 2027.

Key facts

  • The Berne Financial Services Agreement took effect on 1 January 2026.
  • Its first Joint Committee discussed firm usage and supervisors' experience on 4 November.
  • The existing framework covers specified services and client categories, with domestic authorisation and registration requirements.
  • The next financial dialogue is planned for Switzerland in the second half of 2027.

What access can firms already use?

The November meeting concerns oversight of an agreement already in force. The joint statement says both delegations welcomed its implementation and agreed to consider its functioning and development further. It reports no numerical measure of take-up. Their positive assessment therefore comes from the two governments, while the concrete next step is continued review through their bilateral dialogue.

For British insurers, the practical access is to selected non-life insurance business for large Swiss corporate clients, without requiring Swiss authorisation for those covered services. The Financial Conduct Authority's guidance explains that firms must meet eligibility requirements, including appropriate UK authorisation. UK insurance intermediaries also benefit from an exemption from the requirement for a local presence in Switzerland, although the relevant Swiss supervisory framework otherwise continues to apply.

In the other direction, eligible Swiss firms can provide covered investment services to UK professional clients, eligible counterparties and high-net-worth clients. The FCA describes a system of recognition of regulatory outcomes: for specified activities, the host country defers to the supplier's domestic authorisation and prudential requirements. The arrangement consequently concerns defined wholesale and sophisticated-client business rather than unrestricted access across all financial services.

Before the agreement, Swiss investment services firms could use the UK's Overseas Persons Exclusion or seek UK authorisation. The FCA says those existing routes remain available. A firm cannot use the agreement to register the same service, instrument and client category for which it already holds the relevant UK permission.

What must happen before business can start?

Registration remains an operational condition. For eligible UK insurers, the FCA/PRA verifies eligibility and good standing within 30 days; FINMA then has 30 days to enter the firm on its public register. For eligible Swiss investment firms, FINMA's verification period is 60 days, followed by up to 30 days for FCA registration. Business under the relevant route begins after entry on the register.

The dialogue brought together HM Treasury, Switzerland's State Secretariat for International Finance and supervisors including the Bank of England, FCA, Swiss National Bank and FINMA. Alongside the agreement, they discussed financial stability, non-bank intermediaries, artificial intelligence, cryptoassets, stablecoins and sustainable finance. Digital-finance discussions included the digital pound, Switzerland's Project Helvetia and Britain's digital gilt and securities sandbox work.

The Joint Committee is the mechanism for reviewing implementation and application. The FCA separately notes that the agreement normally receives a review every five years unless the parties agree otherwise. For firms considering the route now, the existing eligibility and registration rules remain the practical starting point; the next bilateral dialogue provides the published window for the governments' further assessment.