Switzerland Delays Model 1 IGA Again
- Elizabeth A. McMorrow
- 9 minutes ago
- 2 min read
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. Then 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 was scheduled for January 1, 2028. The SIF has announced another delay to no earlier than January 1, 2029.
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 on June 27, 2024.
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 annual reporting directly to the IRS through IDES and submitting COPA and Periodic Certifications through the IRS FATCA portal.
Click to read Switzerland’s SIF June 29, 2026 announcement. https://www.sif.admin.ch/en/fatca-agreement
For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.