Ten years after the Brexit referendum, the bilateral financial services agreement between Britain and Switzerland is no longer just a niche regulatory achievement. It is being held up as the template for how Europe should do cross-border finance.
When the finance ministers of the United Kingdom and Switzerland signed the Berne Financial Services Agreement (BFSA) in December 2023, it attracted modest attention outside specialist circles. Six months after the agreement came into force on 1 January 2026, its influence has grown far beyond what either side might have expected. A landmark report published on 8 June by UK Finance and law firm Freshfields now explicitly proposes a future UK-EU Financial Services Agreement modelled on the BFSA — placing this quiet bilateral deal at the centre of Europe’s post-Brexit financial architecture debate.
From Bilateral Deal to Continental Blueprint
The UK Finance report, Unlocking Growth Through a Stronger UK-EU Financial Services Partnership, sets out a three-stage roadmap for rebuilding the UK’s financial services relationship with the European Union. Its short-term proposals focus on maximising existing cooperation mechanisms. Its medium-term ambitions include a mobility agreement for skilled professionals, modelled on the UK-Swiss arrangement. But the boldest recommendation sits in the longer-term column: a bespoke UK-EU Financial Services Agreement explicitly inspired by the BFSA.
What makes the BFSA distinctive — and increasingly attractive as a model — is its reliance on outcomes-based mutual recognition rather than rule-by-rule alignment. Under the agreement, the Swiss Financial Market Supervisory Authority (FINMA) and the Financial Conduct Authority (FCA) each acknowledge that the other’s regulatory framework achieves equivalent outcomes, without requiring identical rules. For Swiss firms licensed under FINIG — the Financial Institutions Act that governs asset managers, fund management companies, and securities firms — this means serving UK wholesale and institutional clients without obtaining separate FCA authorisation.
It is a fundamentally different approach from the EU’s equivalence regime, which has been criticised as slow, politically motivated, and prone to sudden withdrawal. The BFSA offers something more durable: a treaty-level framework with structured dialogue built in.
A Week That Tells the Story
The timing of the UK Finance report was not accidental. The same week saw the House of Lords begin its second reading of the Financial Services and Markets Bill on 8 June. Clause 37 of that Bill empowers HM Treasury to create overseas recognition regimes — precisely the kind of legislative plumbing needed to operationalise agreements like the BFSA at scale. The Investment Minister noted during the debate that the Bill “supports the international competitiveness of our world-leading financial services sector” and would make “business across borders easier without compromising consumer or financial protections.”
This week, the connection becomes even more tangible. The Point Zero Forum, co-hosted by the BIS Innovation Hub and the Monetary Authority of Singapore, runs from 23 to 25 June in Zurich. Senior Bank of England officials — including Deputy Governor Sarah Breeden and Head of Future Technology Tom Mutton — are participating in panels on tokenised assets and digital financial infrastructure. It is a practical illustration of what cross-border collaboration looks like beyond the treaty text: regulators from London and Zurich sitting in the same room, working on the same problems.
Why It Matters Now
The numbers provide useful context. The UK exported £33.7 billion in financial services to the EU in 2024 — roughly a third of its total financial services exports — and that figure has grown approximately 50% since 2015 despite Brexit. The UK financial services sector contributed £224 billion to GVA in 2025, accounting for around 8% of the economy and 20% of total exports. More than 80% of European derivatives and foreign exchange trading still takes place in London.
Against that backdrop, the UK-Swiss corridor represents something more than a bilateral arrangement between two mid-sized economies. Switzerland manages roughly $2.2 trillion in cross-border wealth — more than any other country — whilst London remains the world’s largest centre for international financial intermediation. The corridor connecting them handles a disproportionate share of global private wealth flows.
For firms operating in this space — whether Swiss asset managers looking to reach UK investors, or UK-based advisers navigating Swiss structured product markets — the BFSA has reduced a significant layer of regulatory friction. The outcomes-based approach means that a FINMA-licensed firm meeting Swiss standards can access UK wholesale clients directly, whilst the structured dialogue mechanism ensures that regulatory divergence is managed rather than punished.
The broader significance, though, is what the BFSA’s success implies for the rest of Europe. If outcomes-based mutual recognition can work between Bern and London, the argument for extending the same logic to Brussels becomes considerably harder to dismiss. TheCityUK, the industry body representing UK-based financial and professional services, has estimated that the sector’s £26 billion trade surplus with the EU could grow substantially under a more cooperative framework.
Six months in, the BFSA is no longer just a Swiss-UK story. It is the proof of concept that the rest of Europe’s financial services relationship with Britain has been waiting for — and the blueprint is already being drawn.
