The EU Commission has reminded firms of the urgent need to complete all contingency planning ahead of the end of the Brexit Transitional Period on 31 December, drawing their attention to documents first published in July 2020.
The Commission’s guidance for financial services firms is available in a series of sector-specific pdf downloads covering:
- Asset Management
- Banking & Payment Services
- Credit Rating Agencies
- Data Protection
- emissions trading
- financial instruments (MiFID)
- Occupational pension schemes
- Post trade financial services (trade reporting and settlement)
As things stand equivalence provisions agreed between ESMA, EBA, EIOPA and the FCA will come into force on 1 January 2021 to permit continuity in wholesale markets infrastructure, payment services and some aspects of reinsurance.
Cross-border services/branch passports allowing firms to do business on a cross-border basis without the need to be authorised by the regulator in each state where it did business, will end and will not be replaced.
There will be no equivalence provision in any other area of financial services.
The guidance has been re-issued in the context of the possibility that a deal may not have been agreed and ratified before the end of 2020.
Given that the talks are focused primarily on trade in goods, with little or no provision for services, it is unlikely that the situation facing financial services firms will now change – deal or no deal.
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