We’ve previously explored what will happen to transaction reporting under a no-deal scenario, but what about if a deal is agreed?
If the agreement Boris Johnson has put in place with the EU is backed by UK MPs, then the UK will leave the EU on 31 October 2019 with the original transition period in place, being until 31 December 2020.
What will happen to Transaction Reporting under the new deal, from the 1 November 2019?
There will not be any significant changes.
TRAction will continue with the existing EMIR and MiFIR laws, Trade Repositories (TRs) and Approved Reporting Mechanisms (ARMs) until the end of 2020.
What will happen under the new deal, being from 2021 onward?
On the new Brexit day of 1 January 2021, the UK would leave all the institutions and structures of the EU. It will also mean the UK exiting judicial structures including the European court of justice, security and defence arrangements and agreements such as data sharing.
It is still unclear what will be the impact on EMIR and MiFIR Reporting will be, however we anticipate that clients domiciled in the EU will need to report to EU-based (as it will then be constituted) TRs and ARMs. Investment Managers and firms in the UK will need to continue to submit reports in the current format, but likely to UK-based TRs and ARMs, until such a time any changes are made by the FCA to EMIR and MiFIR to create a divergence from the current EU directives and regulations.