Switzerland postpones IGA Model 1 implementation to 1 January 2028 – Impact on QI and FATCA Certification requirements

• Switzerland postpones FATCA Model 1 IGA transition to 1 January 2028.
• FFIs and QIs face 2027 certification requirements, including periodic reviews for both FATCA and QI.
• Key deadlines of 1 July 2027 for FATCA and QI certifications and 31 December 2027 for QI certifications if review year 2026 is chosen.
• Early preparations to allow for remediation and timely certification are essential.

Executive summary

The State Secretariat for International Finance (SIF) has confirmed that Switzerland’s transition to the FATCA Model 1 IGA will be delayed until 1 January 2028. As a result, Swiss FFIs must still complete their 2027 FATCA certification covering 2024–2026 under existing FFI agreements. In parallel, the QI Responsible Officer must prepare the 2027 QI periodic certification, which requires an independent periodic review and proactive remediation of any compliance gaps. Key deadlines were set as of 1 July 2027 for most QI and FATCA certifications and as of 31 December 2027 for QI reviews using 2026 as the review year. Early preparation remains essential.

Key highlights

The SIF has confirmed in its Activity Report 2025 that Switzerland’s transition to the FATCA Model 1 Intergovernmental Agreement (IGA) will be postponed to 1 January 2028 (previously targeted for 1 January 2027). Until the Model 1 IGA becomes effective, existing FFI agreements between Swiss financial institutions and the IRS will remain in place. Consequently, Swiss FFIs must still complete their 2027 FATCA certification covering the compliance period 2024–2026.

In parallel, financial institutions must prepare for the upcoming Qualified Intermediary (QI) periodic certification, due in 2027. This certification requires an independent periodic review and robust internal remediation processes.

Key Implications for QI and FATCA

QI Certification (2027)

• The QI Responsible Officer must submit a certification to the IRS based on a periodic review of QI compliance.
• The review must be performed by an appropriately independent and qualified party, typically external to the organization.
• Institutions must demonstrate proactive remediation of any under-withholding or reporting issues identified.

FATCA Certification (2027)

• Swiss FFIs must provide the FATCA certification of compliance for 2024–2026.
• The FATCA RO must ensure the performance of a periodic review and certify the effectiveness of internal controls.

Certification Deadlines

Recommended Actions

• Begin planning for both QI and FATCA certifications to ensure timely and complete submissions.
• Determine the preferred review year for the periodic review (2024, 2025 or 2026).
• Consider conducting a preliminary health check to identify potential compliance gaps early.
• The EY Customer Tax Operations and Reporting Service Team is dedicated to discussing tailored support for QI and FATCA certification processes as well as preparing for the transition to the Model 1 IGA.