Skip to main content

Clifford Chance

Clifford Chance


Germany prepares for 'No deal Brexit' – Update

14 December 2018

The German Federal Government has published a draft law to preserve market access for UK firms offering banking business or financial services in Germany under the European passport regime for a transitional period in case of a "no deal Brexit". The government draft is based on the draft prepared by the German Ministry of Finance in November (see our Brexit briefing of 23 November 2018). The draft includes certain additions and useful clarifications on the scope of this transitional regime.


  • Extension of EU passport for banking business and financial services for transitional period
  • BaFin to implement transitional regime by way of general decree
  • Licensable activities may be continued for a transitional period to the extent closely connected to existing contracts at the time of Brexit
  • Targeted EU measures take precedence

Download PDF