The UK and Switzerland governments are negotiating a Mutual Recognition Agreement (MRA) that will create more integrated UK-Switzerland financial markets. The UK financial and related professional services industry sees real opportunity for MRA negotiations to establish a new gold standard in cross-border regulatory and supervisory cooperation. The UK-Switzerland FTA should support this process by recognising the importance of the MRA, stating how regularly regulators should meet under the MRA, and outlining the principles that should underpin future UK-Switzerland financial regulatory cooperation, including mutual recognition and regulatory deference.
The FTA should encourage financial regulators to seek mutual compatibility of regulatory frameworks, develop consistent regulatory approaches on an outcomes basis, promote regulatory co-operation in new financial services (FinTech, digital assets, and AI) and share best practices on cybersecurity and operational resilience. It should provide for industry involvement in UK-Switzerland regulatory dialogues.
The UK should seek ambitious FTA commitments to enable UK businesses to provide cross-border services into Switzerland in the following sectors:
Switzerland is mostly open to UK business establishment, but some restrictions remain. The UK should seek to liberalise Swiss commercial presence rules, removing barriers in the following areas:
igital trade is essential for financial and professional services businesses. The UK and Switzerland should commit to a high standard digital trade agreement that:
The UK should work to maintain existing data adequacy arrangements with the EU and Switzerland to enable personal data to flow between the UK and Switzerland in frictionless ways.
Financial and professional businesses succeed when they have access to skilled talent. The UK and Switzerland both offer strong talent pipelines: both countries could benefit from an FTA that helps UK and Switzerland professionals work in each other’s country. The UK should extend the UK-Switzerland Services Mobility Agreement (SMA) beyond its current time limit and extend the length of stay for UK professionals in Switzerland. UK and Switzerland negotiators should achieve faster visa turnaround times, reduced administrative costs for business visas, and clearer definitions of who can get a business visa. Spouses and children should be able to accompany professional workers.
Mutual Recognition of Professional Qualifications (MRPQ)
The UK has a temporary MRPQ agreement with Switzerland. The agreement needs to be extended. The UK should also ensure the FTA delivers a clear path for the recognition of UK professional qualifications in Switzerland. The UK and Switzerland should agree an MRPQ framework based on the MRPQ terms in the UK-EEA EFTA FTA, which required EFTA and UK authorities to recognise each other’s professional qualifications subject to certain conditions being met.
Green and sustainable finance
The UK and Switzerland should work together to support the green transition. The FTA should call for both countries to develop aligned approaches to green finance disclosure standards, green ratings, and green taxonomies. The UK should seek Swiss recognition of UK requirements for premium listed companies to disclose their consistency with Task Force on Climate-Related Financial Disclosures (TCFD) requirements in their annual reports. The UK should urge Switzerland to follow its approach of using International Sustainability Standards Board (ISSB) standards as the backbone to its disclosure regulations. The FTA should ensure industry engagement in UK-Switzerland green finance regulatory dialogues.
