Whatever happens in parliament and even if Brexit is delayed for a period, there are essentially three possible outcomes to Brexit. Either the UK revokes article 50 and remains in the EU, or it ratifies a withdrawal agreement with the EU and leaves pursuant to that withdrawal agreement (a ‘deal Brexit’) or it leaves without a withdrawal agreement (a ‘no deal Brexit’).
As a matter of politics it is not possible to predict the outcome. It is therefore important to understand what a deal Brexit or a no deal Brexit would mean for you. The work to onshore EU financial services and securities law into UK domestic law undertaken by the UK Government, the FCA and the Bank of England under the EU (Withdrawal) Act 2018 is now drawing to a close. EU agencies have also now clarified their own position in relation to certain questions. The legal and regulatory consequences for issuers of either a deal Brexit or a no deal Brexit are therefore becoming increasingly clear.
This document was updated in October 2019.