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Financial services sector

With the end of the Brexit transition period and the onshoring of key pieces of EU financial services legislation into UK law, there have been a number of changes to the UK’s financial services framework. The resources outlined below will help you navigate those changes and identify key publications, including in relation to the UK’s temporary permissions regime and equivalence decisions.

UK developments 

Brexit SI Toolkit

Following the success of A&O’s regulatory temporary permission regime (TPR) tool, we have developed two new toolkits which enables firms to manage and implement the changes to onshored EU law resulting from a no deal Brexit.

The UK Government is onshoring key pieces of EU financial services legislation into UK law through statutory instruments (SIs) with UK regulators onshoring relevant technical and implementing legislation through binding technical standards made by way of exit instrument (BTSs). The SIs make extensive changes to the EU legislation. The amendments introduced by the SIs and BTSs are expected to come into force on 1 January 2021, following the end of the implementation period. The UK Government as well as the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) are providing limited transitional relief in respect of some of these changes. UK firms and EEA firms doing business in the UK will need to consider the operational and compliance implications of such changes required (i) immediately on 1 January 2021; and (ii) on the expiration of any applicable transitional relief. Since the application of such onshored EU legislation and the regulators’ transitional relief differ in certain instances depending on whether you are a UK firm or an EEA firm, we have developed two toolkits; one for EEA firms and another for UK firms. Each toolkit does the same and covers the same onshored legislation, simply with a different, tailored perspective. 

For more information download the toolkit flyer or get in touch with your usual A&O contact.


Brexit Statutory Instruments tracker

  • IP Completion Date
    This table sets out the Brexit SIs that amend onshored retained EU legislation and will come into force at the end of the implementation period (IP Completion Date). The table also provides details of key UK financial services legislation to be amended by each SI. 

Temporary Permissions Regime – UK regulator publications

  • This table sets out the regulators publications in relation to the Temporary Permissions Regime.

Binding technical standards and rule-set changes – UK regulator publications

  • This table sets out the PRA and BoE publications relating to the binding technical standards and rule-set changes.
  • This table sets out the FCA publications relating to the binding technical standards and rule-set changes.

Equivalence

  • This table summarises existing third country provisions within EU financial services legislation and outlines whether the European Commission has taken an equivalence decision for each provision in relation to both the UK and other third countries. We also highlight whether relief is available under the UK regulators’ temporary transitional powers (TTP) or because of a UK equivalence decision

EEA Transitional Measures Tracker

  • This table summarises the current position across the EEA.

Additional client bulletins

Brexit Statutory Instruments – a series of briefings: 

The UK Regulator’s Approach – our commentary  


Other insights

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Brexit Law - the way ahead