Switzerland Delays Model 1 IGA

Switzerland Delays Model 1 IGA

On June 27, 2024, the U.S. and Switzerland signed a new FATCA agreement changing Switzerland from a Model 2 Intergovernmental Agreement (IGA) jurisdiction to Model 1 IGA jurisdiction starting in 2027. However, on January 26, 2026, Switzerland’s State Secretariat for International Finance SIF announced that the earliest entry into force of the U.S.-Switzerland Model 1 IGA is scheduled for January 1, 2028.

Model 2 IGA

The U.S.-Switzerland Model 2 IGA entered into force on June 30, 2014. Pursuant to the U.S.-Switzerland Model 2 IGA, Swiss Participating Foreign Financial Institutions (PFFIs) submit annual FATCA reporting directly to the U.S. Internal Revenue Service (IRS) after obtaining the consent of the reportable U.S. clients. If such client refuses to give consent, the U.S. government must request related information from the Swiss government.

Swiss PFFIs have also had the burden of submitting to the IRS a one-time Certification of Preexisting Accounts (COPA) and a Periodic Certification every three years. These obligations will continue until the Model 1 IGA actually comes into force.

Model 1 IGA

The Swiss Federal Council approved the mandate for negotiations with the U.S. to switch to a Model 1 IGA on October 8, 2014 and ultimately signed a Model 1. The implementation process is currently under way but will come into force at least one year later than previously announced.

The change to a Model 1 IGA will impact Swiss FIs in a variety of ways including:

• Tracking new Swiss law and guidance

• Updating internal policies and procedures

• Adapting internal reporting systems for differences between IRS IDES and the Swiss Federal Tax Administration (FTA) portal

• Communicating with clients that reporting will be mandatory not based on individual client consent

• Training staff

Delay Implications

Reporting Swiss FIs will continue to follow the Model 2 IGA processes. This includes submitting Y2025 and Y2026 reporting directly to the IRS through IDES by March 31, 2026 and March 31, 2027 respectively and submitting COPA and Periodic Certifications through the IRS FATCA portal by July 1, 2026 and July 1, 2027. Depending on the start date of the U.S.-Switzerland Model 1 IGA and the final Swiss FATCA guidance, use of IDES and the submission of COPAs and Periodic Certifications may extend beyond 2027.

Click to read the Switzerland’s State Secretariat for International Finance SIF January 26, 2026 announcement.

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