Temporary Permissions and Contract Continuity for Financial Institutions across Europe

By Rachel Kent, Dominic Hill and FIS lawyers across Europe

While it is still conceivable that a deal with an appropriate transition period will be finalised between the UK and the EU, a "hard Brexit" remains a possibility.  In light of this, the UK and other jurisdictions have published legislation to accommodate the impact of a no-deal Brexit. With the assistance of our team across the jurisdictions, we have compiled information on these measures in respect of the UK, France, Germany, Luxembourg, Poland, the Netherlands, Italy and Spain.

In the UK, the deadline for banks, insurance companies and designated investment firms to notify the Prudential Regulation Authority (PRA) that they wish to enter the "temporary permissions regime" (TPR) has now passed. Firms that will be solo-regulated by the FCA (and whose passports do not include PRA regulated activities) must notify the FCA of their intention to enter into the TPR as soon as possible and, in any event, by the end of 30 January 2020. Other temporary measures will be put in place to run-down existing business.

To read more on temporary measures for incoming EEA firms into the UK and the impact on UK firms carrying on business in the EEA, access our multi-jurisdictional note here.  

If you would like further information or to discuss how your business may be affected by Brexit, please get in touch with your usual Hogan Lovells contact or any of the country contacts in the document.