Berne Financial Services Agreement (BFSA) Operational Direction and Guidelines for UK Insurers’ Section IV Notifications

How BFSA works

An insurer authorised in the UK can provide covered services to Swiss clients without needing to establish a local presence or seek local authorisation. To do so, they must notify the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA), who will inform the Swiss Financial Market Supervisory Authority (FINMA).

Section IV notifications – PRA direction

Regulation 6 of the Financial Services and Markets Act 2023 (Mutual Recognition Agreement) (Switzerland) Regulations 2025 provides that a UK regulator may, by direction, specify the notification form required under Annex 4 Section IV paragraph B.e of the BFSA. After agreeing the content of the form with the FCA and FINMA, the PRA directs that the notification form required under Annex 4 Section IV paragraph B.e of the BFSA is the form set out in the FCA Connect system.

Important note on completing Section IV notifications

As well as the UK insurer’s details, the notification must include the classes of business the UK insurer intends to carry on in Switzerland and confirmation that the UK insurer satisfies the requirements in Annex 4, Section IV.B. of the BFSA and that the firm will comply with the applicable conditions set out in Annex 4 section VII of the BFSA.

How we review BFSA notifications

Once the form has been submitted on the FCA Connect system, the PRA will review the notification and inform FINMA within 30 days whether the UK insurer satisfies the requirements in Annex 4 Section IV paragraph B a to c, and d i, ii and iv of the BFSA. The PRA and FCA will also confirm whether the UK insurer is of good standing.

Upon receipt of the PRA’s positive confirmation, FINMA has 30 days to add the UK insurer’s details on the FINMA register. The PRA will inform the UK insurer once FINMA’s register has been updated.

BFSA amendment and exit notifications

When a UK insurer amends the classes of business it has previously notified under the BFSA, it should submit a BFSA amendment notification through the FCA Connect system. 
 
When a UK insurer wishes to exit the BFSA it should send a BFSA exit notification through the FCA Connect system.

The PRA will inform FINMA of the amendment/exit within 30 days of receipt. FINMA will have 30 days to amend the UK insurer’s register entry. The PRA will inform the UK insurer once FINMA’s register has been updated.