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The Post-Brexit Patchwork: EU market access rules for UK firms

On 31 December 2020, at the end of the Brexit transition period, UK firms will lose the passporting rights on which they currently rely to provide financial services in other EU jurisdictions. Instead, UK firms will need to consider the rules of each EU Member State to determine whether, and the extent to which, they will be able to continue providing services to clients in that jurisdiction. 

This step change in UK firms’ market access rights arises as a result of the UK leaving the EU single market. While the existing EU financial services regulatory framework includes numerous third-country regimes based on equivalence, none come close to replicating single market membership. Instead, UK firms will need to navigate a patchwork of national licensing regimes and face restrictions on cross-border business and many other impediments compared with the market access rights that an EU firm would have.

Thought Leadership

18 November 2020

The Post-Brexit Patchwork: EU market access rules for UK firms

On 31 December 2020, at the end of the Brexit transition period, UK firms will lose the passporting rights on which they currently rely to provide financial services in other EU jurisdictions. Instead, UK firms will need to consider the rules of each EU Member State to determine whether, and the extent to which, they will be able to continue providing services to clients in that jurisdiction. 

This step change in UK firms’ market access rights arises as a result of the UK leaving the EU single market. While the existing EU financial services regulatory framework includes numerous third-country regimes based on equivalence, none come close to replicating single market membership. Instead, UK firms will need to navigate a patchwork of national licensing regimes and face restrictions on cross-border business and many other impediments compared with the market access rights that an EU firm would have.

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18 November 2020

The Post-Brexit Patchwork: EU market access rules for UK firms

On 31 December 2020, at the end of the Brexit transition period, UK firms will lose the passporting rights on which they currently rely to provide financial services in other EU jurisdictions. Instead, UK firms will need to consider the rules of each EU Member State to determine whether, and the extent to which, they will be able to continue providing services to clients in that jurisdiction. 

This step change in UK firms’ market access rights arises as a result of the UK leaving the EU single market. While the existing EU financial services regulatory framework includes numerous third-country regimes based on equivalence, none come close to replicating single market membership. Instead, UK firms will need to navigate a patchwork of national licensing regimes and face restrictions on cross-border business and many other impediments compared with the market access rights that an EU firm would have.

19 October 2020

The European Commission 2019 - 2024

On 27 November 2019, The European Parliament confirmed the new class of European Commissioners with 461 votes in favour, 157 against and 89 abstentions. The new President of the European Commission, Ursula von der Leyen, and her team of European Commissioners took office on 1 December 2019 and will drive the EU’s agenda for the next five years. President Von der Leyen, the former German defence minister, says that it will be a “geopolitical Commission,” signalling an intention to position Europe as a heavyweight on the world stage.

Here Clifford Chance experts, including Of Counsel Michel Petite who worked for EU institutions for 27 years and was legal adviser to three Commission Presidents, assess the priorities for the von der Leyen Commission.

02 June 2020

Post-Brexit UK Tariff Regime Published

As of 1 January 2021, the UK Global Tariff (UKGT) will apply at the UK border to goods imported from countries with which the UK does not have a preferential trade agreement. This includes goods from major economies such as China and the US.

It will also apply to imports from certain countries with which the EU currently has preferential trade agreements, including Canada, Japan and Mexico, but which have not rolled over those agreements to the UK’s benefit. If the UK is unable to agree a trade deal with the EU before the end of 2020, the tariffs will also apply to imports from the EU.
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