The UK-Switzerland Financial Services Mutual Recognition Agreement: A Model for a Future UK-EU Relationship?
Rambod Behboodi & Leonie Van Haeren
What the paper says
Almost four years following Brexit, in December 2023, the United Kingdom and Switzerland signed a mutual recognition agreement in the financial services sector. The ‘Berne Financial Services Agreement’ covers areas such as asset management, banking, investment services, and insurance. This paper provides the first analytical review of the Agreement by placing it within the broader theoretical framework of ‘regulatory divergence’ and ‘mutual recognition’. This paper starts with a basic taxonomy of regulatory ‘deference’, including institutional frameworks used to achieve regulatory and prudential objectives in the financial services sector. It then highlights the sensitivities at play and analyses the modalities and mechanisms of divergence and deference. The paper reviews negotiated examples, including the UK-Switzerland mutual recognition agreement, before identifying the path forward in the UK-European Union relationship in the financial services sector.
Evidence weight
Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40
| F · citation impact | 0.50 × 0.4 = 0.20 |
| M · momentum | 0.50 × 0.15 = 0.07 |
| V · venue signal | 0.50 × 0.05 = 0.03 |
| R · text relevance † | 0.50 × 0.4 = 0.20 |
† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.