About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

Brexit: Equivalence is Dead. What Now?

Subscribe to our newsletter

Last week, UK Chancellor Rishi Sunak delivered his first speech at Mansion House, outlining his vision for the UK’s financial services industry.

During the speech, while stating that the UK government’s ambition following Brexit had been to reach a comprehensive set of mutual decisions on financial services equivalence, he conceded that “this has not happened,” and went on to say that the UK now has the “freedom to do things differently and better, and we intend to use it fully.”

So, if equivalence is now officially dead, what does that mean for the future of financial markets in UK and Europe? Clearly, there are changes ahead.

Many market participants would contend that certain aspects of MiFID II do not necessarily protect market integrity or encourage competition, two of the UK regulator’s key aims. In particular, double volume caps (DVCs), the share trading obligation (STO), Large in Scale (LIS) restrictions on dark trading, and the systematic internaliser (SI) regime have all proved controversial.

HM Treasury recognises this, and has now published a wide-ranging consultation paper, which looks to overhaul the UK’s regulatory approach now that equivalence is no longer on the cards. All of the above elements will come under close scrutiny, and regulations will likely undergo significant revision following the consultation process, which runs until 24th September.

Most market participants would probably agree that the guiding principles for regulation should be around what’s best for end investors, i.e. preserving competition, providing choice and open access, and allowing financial intermediaries to secure the best execution outcomes for those investors. Given that policy makers in the UK and EU must surely share these objectives (even if they identify different avenues to achieving them), one would hope for ongoing constructive dialogue across the two jurisdictions.

As covered in our previous report on the topic, firms were generally well prepared for the Brexit transition and have adjusted well.  In Q1 this year, there was a significant shift in equity trading volumes from UK to European MTFs, as expected. Since then however, some of that volume seems to be slowly coming back, particularly in non-lit liquidity. According to figures from data analytics vendor big xyt, while dark trading volumes across Europe have remained at a fairly constant 8% – 9% since the start of the year, in the UK they have risen from 11.5% to 14.5%. Dark trading in UK mid-caps is even more pronounced, at 18%.

If the UK regulator does remove DVCs and the STO, will dark trading increase even further, possibly at the expense of the lit books? Only time will tell. But what is clear is that these recent developments seem to have resulted in a growing sense of optimism around the longer-term prospects for the UK’s financial markets.

 

Subscribe to our newsletter

Related content

WEBINAR

Upcoming Webinar: Hearing from the Experts: AI Governance Best Practices

9 September 2025 10:00am ET | 3:00pm London | 4:00pm CET Duration: 50 Minutes The rapid spread of artificial intelligence in the financial industry presents data teams with novel challenges. AI’s ability to harvest and utilize vast amounts of data has raised concerns about the privacy and security of sensitive proprietary data and the ethical...

BLOG

Key Takeaways from the SEC’s 2025 Examination Priorities

The U.S. Securities and Exchange Commission’s Division of Examinations released its examination priorities for Fiscal Year 2025 in October, placing a strong emphasis on investor protection, market integrity, and compliance with regulatory standards. These priorities, formulated before the results of the 2024 U.S. election were known, reflect insights from past exams and emerging risks, and...

EVENT

AI in Capital Markets Summit London

The AI in Capital Markets Summit will explore current and emerging trends in AI, the potential of Generative AI and LLMs and how AI can be applied for efficiencies and business value across a number of use cases, in the front and back office of financial institutions. The agenda will explore the risks and challenges of adopting AI and the foundational technologies and data management capabilities that underpin successful deployment.

GUIDE

Institutional Digital Assets Handbook 2024

Despite the setback of the FTX collapse, institutional interest in digital assets has grown markedly in the past 12 months, with firms of all sizes now acknowledging participation in some form. While as recently as a year ago, institutional trading firms were taking a cautious stance toward their use, the acceptance of tokenisation, stablecoins, and...