What to check if you're dealing with an EEA firm in supervised run-off (SRO) or contractual run-off (CRO), or a fund in the temporary marketing permission regime (TMPR).
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Before 31 December 2020, when the Brexit transition period ended, financial services firms authorised in the European Economic Area (EEA) could use the passporting regime to provide services in the UK.
They could do this either via having a physical presence in the UK (known as a branch passport), or by providing services from their home state without a UK branch (known as a services passport).
Importantly, this meant they didn’t need to be authorised in the UK.
EEA fund managers could also use the passporting regime to market their investment funds in the UK without these managers or their funds being authorised by us.
But since the end of the transition period, EEA firms can no longer passport into the UK. Instead, they may need to be authorised and regulated by us or the Prudential Regulation Authority (PRA).
Similarly, EEA fund managers can no longer market their funds in the UK using a passport. Instead, they must use other routes.
To avoid any disruption to you when the passporting regime ended, the Government established the:
Temporary permissions regime (TPR): The TPR allowed EEA-based firms to continue operating in the UK for up to 3 years after the end of the transition period. The TPR ended on 31 December 2023 and there are no longer any firms in the regime.
Financial services contracts regime (FSCR): The FSCR automatically applies to EEA-based firms and allows them to wind down their UK business in an orderly fashion and exit the UK market.
Temporary marketing permission regime (TMPR): The TMPR allows managers of EEA-based investment funds to continue to temporarily market investment funds in the UK.
The TMPR for EEA AIFs (alternative investment funds) has now ended, but these firms may be able to market their funds to professional investors under the National Private Placement Regime.
The TMPR for EEA UCITS funds (undertaking for collective investment in transferable securities) was due to end in December 2025, however it’s been extended to December 2026.
What this means for you
These temporary regimes mean that if you dealt with a financial business based in the EEA that previously passported into the UK, it can continue to provide services to you while it winds down its UK business.
However, these businesses may not give you the same protections as UK authorised firms if something goes wrong. For example, you may not be protected by:
- the UK’s Financial Services Compensation Scheme (FSCS), which is designed to protect you if a firm goes out of business or stops trading
- the UK’s Financial Ombudsmen Service, which is a free service that settles complaints between consumers and financial services businesses
So, if you’re dealing with an EEA firm or investment fund, find out more about these temporary regimes and how they affect you.
About the FSCR
The FSCR automatically applies to EEA-based firms and allows them to wind down their UK business and exit the UK market.
Firms in the FSCR may have entered the TPR and left it without getting full UK authorisation. Or they may have entered the FSCR directly.
Firms in the FSCR must not deal with new UK clients and haven’t been authorised or assessed by us or the PRA.
How to tell if a firm is in the FSCR
There are 2 parts to the FSCR. EEA firms may either be in:
Which regime a firm is in will generally depend on whether it had:
- a physical presence, such as a branch, in the UK
- a UK top-up permission
- UK-based agents (for payments and e-money firms)
A top-up permission covers services that firms couldn’t provide via the passporting regime, such as debt counselling or debt adjusting.
You can find out which regime a firm is in by using our Financial Services Register. It will be clearly stated at the top of the firm’s page.
Supervised run-off (SRO) regime
If a firm is in the SRO regime, it means that it:
- is authorised in an EEA member state
- had a passport into the UK in place on 31 December 2020
- has a branch in the UK or has a UK top-up permission, or for payments/e-money firms has/had UK-based agents
- has not been authorised or assessed by us or the PRA (and for banks and insurers, any individuals shown as ‘approved’ on the FS Register may only be approved for regulatory purposes. They may not have been assessed by us or the PRA)
Firms in the SRO regime should only be dealing with existing customers and business. They shouldn’t be dealing with new customers or selling you any new products (unless an existing contract says that they must do so).
Firms in the SRO regime should also include specific wording in their letters or emails to you, making it clear that they are in the FSCR. Check the bottom of any letters or emails you have received from the firm.
Check if you’re protected if the firm fails
If you were covered by the FSCS before the end of the transition period, you’ll still be covered when dealing with firms in the SRO regime.
However, FSCS cover doesn’t apply in all cases. Many firms that didn’t have a UK branch won’t be covered by the FSCS, and you may not be covered by an EEA compensation scheme.
If you’re dealing with a firm in the SRO regime, it should tell you about how your money is protected. If you don’t hear from the firm, you may want to ask them for more information.
The FSCS has also published information about the different scenarios in which cover will and won’t apply.
Check how to complain
If you’re dealing with a firm in the SRO regime, you’ll still be able to complain to the Financial Ombudsman Service if your complaint isn’t dealt with by the firm.
However, you may not be able to refer a complaint to a dispute resolution scheme in the firm’s home country, as there may not be one available. And if there is a scheme, it may be harder for UK customers to use.
You may want to ask the firm for more information about how to make a complaint.
If you have any concerns about a firm in the SRO regime, you should contact us.
Contractual run-off (CRO) regime
If a firm is in the CRO regime, it means that it:
- has been authorised in an EEA member state
- had a passport into the UK in place on 31 December 2020
- did not have a physical presence in the UK (was providing services to UK customers exclusively from its home state)
- did not have UK-based agents (for payments and e-money firms)
- has not been authorised or otherwise assessed by us or the PRA
- is not regulated by us or the PRA
Firms in the CRO regime are not authorised or regulated by the FCA or the PRA. However, we do have some very limited powers in relation to firms in the CRO regime.
Firms in the CRO regime should only be dealing with existing customers and business. They shouldn’t be dealing with new customers or selling you any new products (unless an existing contract says that they must do so).
They must also tell us if they have UK business to wind down. If they do, their CRO status will be clearly stated at the top of the firm’s page on the FS Register.
Check if you’re protected if the firm fails
If the firm is in the CRO regime it won’t be covered by the FSCS, but it may be covered by an EEA compensation scheme.
The firm should write to you to explain this. If you don’t hear from the firm, you may want to ask them for more information.
Check how to complain
If you’re dealing with a firm in the CRO regime, you won’t be able to complain to the Financial Ombudsman.
You may be able to take your complaint to a dispute resolution scheme in the firm’s home country, but it may be harder for UK customers to use. So, you may want to ask the firm for more information about how to make a complaint.
If you have any concerns about a firm in the CRO regime, you should contact us.
About the TMPR
Before 31 December 2020, you may have invested in an EEA UCITS fund that was marketed in the UK and managed by an EEA-based fund manager.
This fund manager was likely using the passporting regime to market these funds in the UK. This meant that the funds didn’t need to be authorised by us.
EEA fund managers can no longer market their funds in the UK via the passporting regime. But if you notice that an EEA UCITS fund is being marketed, the fund may be part of the TMPR.
You can find out if a fund is in the TMPR for EEA UCITS by checking the FS Register. It will clearly state this at the top of the fund’s page.
If the fund is not part of the TMPR, or if you have any concerns, you should contact us.
Check if you’re protected if the fund fails
You won’t generally have access to the FSCS for claims relating to the management of a fund in the TMPR. You should check what cover you have (if any) with the fund manager.
Check how to complain
If you’ve invested in a fund that’s in the TMPR, you won’t generally be able to complain to the Financial Ombudsman about the management of the fund.
EEA fund managers should have an approach to dealing with complaints. There should also be alternative dispute resolution schemes in the relevant EEA country. However, this option may not be available and, if it is, it may be more difficult for UK investors to use.
You may want to ask the fund manager for more information about how to make a complaint and what you can do if you’re unhappy with their response.