The widespread disruption caused by COVID-19 means Brexit has not necessarily been front of mind for many people prior to the recent ‘endgame’ negotiations between the UK and the European Commission. However, the requirement to meet obligations arising from the UK’s departure from the EU persists, and indeed those obligations continue to evolve. Financial services organizations will need to build on their existing regulatory compliance framework and Brexit readiness activities in order to minimize business disruption in 2021.
The ever-changing regulatory landscape has resulted in newly empowered UK-based regulators and industry-wide financial services organization reclassifications. Regulatory equivalence with EU authorities is living up to expectations as a complex, political and increasingly uncertain exercise; leading organizations to question how intricate regulatory obligations can be adhered to in a timely manner.
COVID-driven implementation delays, coupled with new regulatory powers, have led industry groups to lobby for changes to the introduction of certain EU regulations. e.g. the Clearing buy-in regime under the CSDR regime. Front Office Trading and booking models will also likely be impacted as the trading obligations in 2021 become better known and understood.
Substantial efforts have already been made to adapt to the post Brexit landscape in the shape of:
- new EU entities being established or repurposed
- introducing new booking models
- establishing and testing new regulatory reporting channels
- migration strategies.
- However, organizations have not been able to complete these exercises for a number of reasons. As a result, they will need to refocus their efforts from early in 2021 to address potential commercial and regulatory challenges.
Download this Capco paper to understand the key Brexit considerations for UK financial services regulation, and how they will continue to impact organizations in 2021.
For more information about Capco’s regulatory practice, please contact Tej Patel, Partner.