About a-team Marketing Services
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: The Vanishing Close: Rethinking Trade Surveillance for Always-On Markets

Date: 2 December 2026 Time: 10:00am ET / 3:00pm London / 4:00pm CET Duration: 50 minutes Global markets are moving steadily towards longer and increasingly continuous trading. Extended-hours initiatives in US equities, the growth of overnight venues and the emergence of new markets and instruments are challenging assumptions that have underpinned trading and surveillance systems...

BLOG

CFTC’s Selig Sets Out Agenda for Leaner Rules and Faster Markets

Michael Selig has placed derivatives regulation at the centre of the US competitiveness agenda, using his keynote at the ISDA annual meeting to call for a more proportionate rulebook, deeper SEC and CFTC alignment, and a clearer path for innovation in swaps, clearing, tokenised collateral and market structure. He framed the CFTC’s task as keeping...

EVENT

Digital Assets & Tokenisation Briefing, New York

A-Team Group’s Digital Assets & Tokenisation Briefing assembles an exclusive group of CxOs and senior technology innovators. These leading market practitioners and infrastructure providers are collectively building the digital rails and decentralised networks that will power Wall Street 2.0.

GUIDE

Regulatory Data Handbook 2026 – Fourteenth Edition

Welcome to the fourteenth edition of A-Team Group’s Regulatory Data Handbook. Supervisors increasingly expect firms to demonstrate which rules apply, which data supports each obligation, who owns the control and how exceptions are identified and resolved. Policies and implementation programmes must now be supported by records that can withstand regulatory scrutiny. This edition examines material...