The Berne Financial Services Agreement (BFSA) between Switzerland and the United Kingdom entered into force on 1 January 2026. It establishes for the first time a clear legal basis for cross-border market access in the area of financial services and enshrines a practice that has been established between the two countries for many years.

The agreement was based on a joint statement issued by the finance ministers of both countries on 30 June 2020. The BFSA is largely based on mutual, results-based recognition of regulation and supervision. The aim is to gradually open up market access, create legal certainty and deepen cooperation between two of Europe's most important financial centres.

Significance and advantages for asset management

• International market access is a key strategic priority for the Swiss asset management industry.

• The BFSA strengthens the attractiveness and competitiveness of Switzerland as a financial centre.

• It forms a solid basis for the needs-based further development of market access, especially for professional clients.

• Access to the UK market under defined regulatory conditions is clearly regulated for Swiss asset managers.

• The BFSA creates legal certainty thanks to a reliable legal basis for cross-border asset management activities.

• The BFSA creates a level playing field by ensuring client protection, market integrity and financial stability through equivalent regulatory standards.

• The BFSA strengthens international cooperation, underlines Switzerland's role as a reliable partner and can serve as a blueprint for further bilateral market access agreements.

AMAS expressly welcomes the BFSA and, together with its members, is supporting the implementation phase. Findings from practical application are being incorporated into the ongoing dialogue with the Federal Administration. AMAS is working closely with the British Investment Association in this regard. AMAS continues to actively promote open markets, reliable framework conditions and a future-oriented Swiss financial centre.