As expected, the market access to the EU for UK financial services firms has changed post-Brexit. The implications of the Trade and Cooperation Agreement (“Agreement“) for financial services are more severe than for example trade, and the effects come close to that of a hard Brexit.

Andreas Fillmann explores what this means for UK Financial Services looking at equivalence decisions, general rules under the agreement, the prudent carve-out and the Joint Declaration on Financial Services Regulatory Cooperation in this article.