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: Agility as Alpha: How Trading Infrastructure Determines Who Wins in Volatile Markets

Date: 21 May 2026 Time: 10:00am ET / 3:00pm London / 4:00pm CET Duration: 50 minutes Tariff shocks, geopolitical realignment and macroeconomic regime shifts are redrawing the investment landscape faster than most firms’ technology stacks can keep up. For hedge funds and asset managers, the ability to move quickly into new asset classes, geographies or...

BLOG

STS Digital and Haruko Integrate to Give Institutional Options Traders Unified Risk View

STS Digital, the regulated principal trading firm specialising in digital asset derivatives, has integrated with institutional portfolio management provider Haruko to deliver consolidated risk and position reporting for options traders. The integration allows institutional clients who trade vanilla and exotic options on STS Digital’s platform to view those positions on an aggregated basis alongside activity...

EVENT

TEST Event page 1

Now in its 15th year the TradingTech Summit London brings together the European trading technology capital markets industry and examines the latest changes and innovations in trading technology and explores how technology is being deployed to create an edge in sell side and buy side capital markets financial institutions.

GUIDE

Risk & Compliance

The current financial climate has meant that risk management and compliance requirements are never far from the minds of the boards of financial institutions. In order to meet the slew of regulations on the horizon, firms are being compelled to invest in their systems in order to cope with the new requirements. Data management is...