A framework to agree reciprocal market access in financial and professional services between the UK and EU post-Brexit has been developed jointly by a law firm and advisory group.
The framework would be underpinned by mutual recognition of each other’s regulatory and supervisory regimes, enabling firms to continue trading with minimal disruption to their customers. It has been developed by Hogan Lovells and the International Regulatory Strategy Group (IRSG), and is set out in a paper published this week, Mutual recognition—a basis for market access after Brexit.
The paper covers criteria for access, mechanisms for maintaining regulatory alignment and dispute resolution. It suggests basing criteria for access on existing global standards such as those set by the Basel Committee on Banking Standards. A joint UK-EU forum could be established to monitor regulation and supervision, including input into proposed new legislation. It sets out a range of dispute resolution models.
Rachel Kent, partner at Hogan Lovells, said: “Earlier this year the IRSG concluded that the focus of the government’s Brexit negotiations should be on delivering a bespoke UK-EU deal rather than reforming or adapting existing EU third country equivalence regimes for market access. This follow up report develops how a bespoke arrangement could work in practise.”
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