Swiss & UK Regulators Forge Closer Ties in Financial Services

Key Takeaways

• MoU under BFSA: FINMA, the FCA, and the PRA signed a memorandum of understanding to operationalize the Berne Financial Services Agreement.
• Insurance & Investment: The framework enables new cross-border market access in insurance and investment services via mutual recognition.
• What Firms Must Do: Notifications and annual returns, registration in the appropriate register, and adherence to clarified supervisory processes.
• How Supervisors Will Work: Regular regulator-to-regulator dialogue and the ability for an authority to intervene in the country of activity when needed.
• Information Sharing: Authorities will exchange information for supervisory work upon request or spontaneously.

Deep Dive

Swiss and British regulators are tightening the knot on financial services cooperation, giving markets and clients a clearer sense of what to expect as cross-border rules evolve.

On September 22, Switzerland’s Financial Market Supervisory Authority (FINMA) sat down with the UK’s Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA) to sign a memorandum of understanding (MoU). Far from a routine bit of paperwork, the deal sets the ground rules for how the Berne Financial Services Agreement (BFSA), inked back in December 2023, will actually work in practice when it comes into force in early 2026.

From Paper Agreement to Practical Action

The BFSA was pitched as a landmark treaty to smooth recognition of financial services between Switzerland and the UK. But treaties can sometimes gather dust without the fine print. This MoU fills in the blanks. It spells out how regulators will coordinate on everything from the submission of notifications and annual returns to making sure firms are properly listed on supervisory registers.

Perhaps more importantly, it creates space for regular dialogue between regulators on both sides and confirms that each authority has the right to step in and act in the other’s jurisdiction if needed. It also sets up a channel for sharing information, whether prompted by a specific request or offered proactively when one side spots an issue worth flagging.

What This Means for Firms and Clients

The timing matters. Insurance and investment services are specifically called out as areas where the BFSA will expand market access, meaning more firms will be able to operate across borders without running into duplicative barriers. For clients, that means broader choice and, regulators argue, better protection.

FINMA and the UK supervisors say the closer partnership will reinforce stability and integrity in both markets. In plain terms, this means fewer gaps for bad actors to exploit, and more certainty for customers placing their trust in cross-border financial services.

The MoU won’t take effect until the BFSA itself goes live in 2026. But by putting pen to paper now, regulators are signaling they don’t want to wait until the last minute to iron out the details. For the financial sector, it’s a reminder that while politics and treaties set the stage, it’s the day-to-day cooperation between supervisors that determines whether markets feel stable, predictable, and fair.

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