Insights

The UK–Switzerland market just got closer — what it means for UK companies

Two developments in 2026 have quietly reshaped the backdrop for UK companies doing business in Switzerland. Neither rewrites the fundamentals of a Swiss expansion overnight — but together they signal a more open, more predictable market, and they sharpen a few questions worth getting right before you commit capital.

A financial-services corridor has opened

On 1 January 2026 the Berne Financial Services Agreement (BFSA) entered into force. It is a mutual-recognition treaty between the UK and Switzerland covering asset and wealth management, banking, insurance, financial market infrastructures and investment services. Rather than harmonising rules, it takes an outcomes-based approach: each side recognises the other's regulatory and supervisory regime as being of a similarly high standard.

In practice, that lets covered firms serve clients across the border with less duplicative local authorisation. The important caveat: it applies to wholesale and sophisticated clients — professional and high-net-worth, not the retail public — and firms must qualify under sector-specific annexes and notify their regulator (the FCA or FINMA) before relying on it. The first notifications were received in early 2026.

For UK financial-infrastructure, wealth and asset-management businesses, this shifts the cost–benefit of a Swiss presence. Some activity that once effectively required a local entity or a heavy authorisation process may now be reachable cross-border — which materially changes the financial case for how, and whether, to establish locally.

And a broader trade deal is on the way

In July 2026 the UK and Switzerland concluded negotiations on an enhanced Free Trade Agreement — a modernised deal that, for the first time, properly covers services and digital trade, superseding the post-Brexit continuity arrangement. The UK government estimates it could unlock in the region of £5.2 billion a year in additional UK services exports to Switzerland over the long run.

One point of realism: the agreement has been concluded, not yet brought into force. Signing is expected later in 2026, followed by the usual domestic ratification on both sides. So the right posture today is to plan around the direction of travel — lower friction for services, digital and professional mobility — rather than to assume immediate change.

What has not changed — the questions to resolve first

A friendlier backdrop does not alter the practical economics of entering Switzerland. These are the ones that most often catch UK firms out:

• VAT. Switzerland is not in the EU, and its VAT is separate. A foreign supplier must register for Swiss VAT once its worldwide turnover from taxable supplies reaches CHF 100,000 a year — the test is global turnover, not Swiss sales alone — and digital B2C services carry a nil threshold (registration from the first franc). Registration is due within 30 days of liability arising, and the standard rate is 8.1%.
• Structure and permanent establishment. Selling from the UK, working through a local partner, opening a branch, or forming a subsidiary each carry different tax, payroll and permanent-establishment consequences. The BFSA may reduce the regulatory pull toward a local entity for some financial firms — but the tax and PE analysis still has to be done.
• Currency. Pricing in Swiss francs while your cost base sits in sterling introduces a GBP/CHF margin exposure that should be modelled explicitly, not assumed away.
• People and payroll. A first Swiss hire triggers social-security, permit and payroll obligations that are unfamiliar and far from trivial — and often arrive earlier in the plan than founders expect.

The bottom line

The 2026 agreements make Switzerland more accessible for UK firms — particularly in financial services and fintech, where the Berne Agreement directly lowers a barrier. But "more accessible" is not the same as "automatically profitable." The decision still turns on whether your specific opportunity can carry the full cost of entry, and on choosing the operating model that fits the numbers. That is precisely the question a focused financial assessment is built to answer.

This article is general commentary for information only and is not legal, tax or regulatory advice. Where formal opinions are required, they are provided by appropriately qualified Swiss advisers.