Impact of Article 50 extension on the UK Temporary Permissions Regime

Following the agreement last week between the UK and the EU to extend Article 50 until 31 October 2019 11pm GMT (see our earlier post), the FCA has now confirmed that it will extend the notification window for incoming EEA firms and fund managers to enter the UK Temporary Permission Regime (“TPR“) to the end of 30 May 2019. Fund managers that need to update their existing TPR notification as a result of the FCA’s extension should also notify the FCA that this is the case by 16 May 2019.

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Preparing for Brexit: EEA Firms – UK Temporary Permissions Regime (“TPR”)

The UK FCA and PRA propose to implement the TPR if the UK leaves the European Union on 29 March 2019 without an implementation (or transitional) period, to ensure that EEA firms currently operating under an incoming passport (either from a UK branch or on a cross-border services basis into the UK) can continue to carry out regulated activities in the UK until they receive new direct authorisation by the UK regulators. For more information, please see our HSF briefing РUK Temporary Permissions Regime placemat