On 31 October 2025, the Financial Services and Markets Act 2023 (Mutual Recognition Agreement) (Switzerland) Regulations 2025 (SI 2025/1145) were published on legislation.gov.uk, together with an explanatory memorandum.

Background

The Regulations, made on 30 October 2025, will make changes to UK legislation to implement the UK’s commitments under the Berne Financial Services Agreement; the financial services mutual recognition agreement signed by the UK and Swiss governments in December 2023.

Overview

The Regulations will permit Swiss firms eligible under the agreement to offer cross-border investment services to wholesale and sophisticated high net worth clients in the UK. In particular, the regulations add an exclusion into the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 to allow Swiss firms registered with the FCA for certain investment services to provide those services without needing authorisation. They also amend the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 to ensure that Swiss registered firms can make financial promotions in certain circumstances without needing authorisation or approval.

Next steps

The Regulations will come into force on 1 January 2026.