Germany: As previously reported the German regulator (BaFin) has published its reaction to the EU-UK Trade and Cooperation Agreement (TCA). The German regulator states that the provisions of the TCA will apply to financial services only to a limited extent and repeats that the UK service providers will no longer be able to use the European passports as of January 2021.

On 31 December 2020, BaFin published a limited national relief measure in the insurance sector. By way of general administrative order (Allgemeinverfügung), the regulator has allowed for a run-off of existing business of UK and Gibraltar insurance undertakings and institutions for occupational retirement provision (IORPs) that have operated under the respective European passports on a cross-border basis so far. However, BaFin has imposed certain conditions. In particular, the UK entities must terminate the existing contracts with clients as soon as possible.

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