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On 31 January 2020, the United Kingdom (UK) left the European Union (EU). According to the withdrawal agreement, the 12-month transition period then began, during which the EU and UK negotiated the foundation of their future relationship and to conclude an EU-UK Trade and Cooperation Agreement.

Since 1 January 2021, the treaty came into force. While the agreement contains provisions including areas such as trade in goods and in services and cooperation on other aspects, the framework is limited in covering financial services. Instead the EU and UK issued a Memorandum of Understanding to establish a framework for regulatory cooperation on financial services.

Consequently, financial services firms cannot benefit from previously used EU passport. Instead, market access will mainly be governed via the equivalence determinations and decisions. However, as equivalence decisions only exists for a limited amount of EU regulatory frameworks and can be unilaterally withdrawn on short notice, they are not a substitute for the current EU-passporting regime for market participants.

As EU rules ceased to apply in the UK, diverging regulatory frameworks may emerge in the future, which could affect the equivalence of both systems and therefore cross-border market access.

Therefore, market participants should complete their long-term Brexit solution to avoid cliff-edge risks after the equivalence decision expires or will be withdrawn.

We support our customers as a strong partner

Deutsche Börse Group monitors and analyses the post-Brexit environment very closely.  For Deutsche Börse Group, it is of utmost interest that our UK-based clients continue to have access to our infrastructure. Therefore, our business units along our value chain are taking the appropriate measures.

At the same time, we provide support to our clients who plan to relocate their business to the EU. We have established a dedicated Brexit Transition Team to ensure member readiness. 

In addition, with the Partnership Program of the central counterparty (CCP) Eurex Clearing, Deutsche Börse Group has developed a market-led alternative to the clearing of interest rate swaps within the EU. The programme was designed in close cooperation with market participants (such as trading firms, end customers and trading platforms).

Future market access


So far, the European Commission has only adopted temporary equivalence decisions for UK CSDs and UK CCPs, while the UK has already granted equivalence to the EU across a number of financial services areas.