TheCityUK has published a short summary paper on transitional arrangements.

Key points in the summary paper include:

  • it is critical for the UK-based financial and related professional services industry, and for other UK and EU businesses, to have urgent clarity from the UK and the EU27 on time-limited, legally-binding transitional arrangements and the principles underpinning them;
  • while businesses will have different cut-off points for activating contingency plans, clarity from the UK and the EU27 about transition will be needed in Q1 2018 at the latest, with significant progress made before the end of 2017;
  • transition should be ‘one size fits all’;
  • transitional arrangements will need to cater for new as well as existing business;
  • without transitional arrangements, firms in both the UK and the EU27 are unlikely to be able to fully benefit from whatever mutual access arrangements are finally agreed; and
  • it is proposed that the interim arrangements cover two periods: (i) a bridging period, often referred to as transitional period, to cover the time between the date the UK exits the EU and the date the new partnership agreement is ratified and becomes unconditional. The bridging period to include a temporary extension of current market access arrangements, including passporting rights for both UK and EU financial services firms; and (ii) an adaptation or implementation period starting on the date the bridging period ends. The design of the adaptation period will depend on the nature of the new UK/EU relationship. TheCityUK suggests certain principles that the adaptation period should be based on including a credible timeframe and continuity of regulatory and supervisory co-operation.

View TheCityUK – Transitional arrangements, 17 October 2017