With progress on the EU-UK Memorandum of Understanding coming to a halt last year, and equivalence decisions not expected for the majority of the policy areas of the financial services industry, divergence between EU and UK rule-making is expected in the years to come. The EU has already begun reviewing a number of its core regulatory frameworks, and the UK has recently concluded a Future Regulatory Framework Review, with legislation expected soon to mark the shift away from the European status quo.

Participants in both the EU and the UK financial markets will need to track the divergence between the two regulatory regimes to understand the different obligations they will be required to uphold going forward. Cicero/amo’s EU and UK public affairs teams have prepared a divergence tracker, setting out the direction of travel in each region and the resulting divergence, which will be updated as policy in the two jurisdictions develop. For a bespoke tracker examining a broader policy ecosystem (including rules pertaining to insolvency, long term investments, cloud services, data and more) as well as more detail on each policy area feel free to approach our team.

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