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Market Access and Implementation
As of July 2025, eligible Swiss investment firms and UK insurers can express their interest in participating under the BFSA by notifying the respective regulators through the following procedures:
For Swiss firms:
- Submit an application via FINMA’s survey and application platform (EHP).
- FINMA review: If successful, FINMA will confirm the firm’s eligibility and good standing with the UK FCA within 60 days.
- FCA registration: Upon receiving FINMA’s confirmation, the FCA will add the firm to its public BFSA register within 30 days.
- Activation: Once listed, the firm may begin supplying services in the UK. Firms will receive a notification when registration is complete.
For UK firms:
- Submit an expression of interest form via Connect.
- FCA / PRA review: If successful, the FCA or Prudential Regulation Authority will confirm the firm’s eligibility and good standing to FINMA within 30 days.
- Swiss registration: Following confirmation, FINMA will complete the process, enabling the firm to access the Swiss market under BFSA provisions.
Benefits
The BFSA offers significant benefits to both Parties, strengthening their financial services sectors and fostering economic growth. It reduces regulatory burdens, enabling firms to focus on their core operations rather than navigating complex compliance requirements. Moreover, it promotes closer cooperation between the UK and Switzerland, including enhanced supervisory collaboration between FINMA and the FCA, which may lead to more effective solutions and innovation in the financial sector.
Switzerland
For Swiss firms, the UK is a vital export market for cross-border wealth management services. The BFSA introduces a forward-looking access framework for Swiss investment services firms, supported by deference commitments. This allows Swiss firms to supply wholesale and high-net-worth clients in the UK without having to comply with UK authorization and prudential measures, reducing regulatory complexity and costs. While certain UK requirements still apply – such as FCA registration and client classification tests – the framework offers a more streamlined and predictable route compared to existing mechanisms.
Swiss insurance firms also benefit from improved access to the UK market. Under the Agreement, they can expand their wholesale offerings without duplicating compliance costs, creating new opportunities for growth. Although insurers operate under UK domestic law rather than benefiting from deference, the UK commits to maintaining open access for professional clients and to consult before introducing measures that could restrict such access. This provides greater certainty and stability for Swiss insurers when planning cross-border operations.
Finally, the BFSA also covers banking services, allowing Swiss institutions to continue accepting deposits and offering lending services to high-net-worth individuals and professional clients in the UK, while applying Swiss law for these activities. This legal certainty strengthens Swiss financial service providers’ ability to serve wealthy private clients, who represent a substantial share of their cross-border business.
UK
For UK firms, the BFSA opens unprecedented access to the Swiss wholesale insurance market, creating new opportunities for growth. UK insurance companies can provide a broad range of wholesale services directly to Swiss corporate clients under a deference framework, relying on UK regulation and supervision rather than duplicating Swiss requirements. A key benefit is the exemption for UK insurance brokers from the Swiss local presence requirement introduced in 2024, allowing them to operate seamlessly on a cross-border basis without establishing a branch in Switzerland.
UK investment service providers also gain targeted simplifications. The BFSA removes duplicative requirements such as registration of client advisers or local exams for services to institutional and professional clients, as well as to high-net-worth individuals who opt to be treated as professional clients. This streamlined approach reduces administrative burdens and facilitates easier provision of services in Switzerland.
In banking, UK advisers can temporarily provide services to high-net-worth private clients within Switzerland without registration requirements, under specified conditions. The BFSA also reinforces existing openness in asset management, preserving portfolio delegation and supporting the UK’s position as a leading global center for asset management.
Conclusion
The signing and entry into force of the BFSA marks a significant step towards greater collaboration and efficiency in the financial services sector between the UK and Switzerland. By streamlining cross-border transactions and reinforcing supervisory cooperation, the Agreement creates a stable and predictable environment for firms operating in both markets. Mutual recognition serves as the foundation of this framework, reducing regulatory overlap while safeguarding financial stability, market integrity and investor protection.
For market participants, the BFSA is not a distant prospect but an immediate reality. Firms should reassess their cross-border strategies, conduct thorough analyses, and prepare for market entry under the new rules. Proactive adaptation will unlock new opportunities and enable institutions to expand their client base across both jurisdictions.
Ultimately, the BFSA sets a precedent for modern financial agreements, balancing openness with regulatory independence and paving the way for innovation and growth. The changes introduced by the BFSA are not just future possibilities but present realities that demand strategic action to secure enhanced market access and a competitive edge in the UK and Swiss financial sectors.