The Post-Brexit Patchwork: EU market access rules for UK firms (November 2020)

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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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