The EU EEA passporting right to provide regulated services is hardwired into financial regulations and constitutes a key feature of the single market, available across both EU member states and EEA EFTA states (“EU EEA firms”). In principle, availability is simultaneous between any EU EEA state and any other EU EEA state
In contrast, third-country firms outside the EU and EEA rely on third-country regimes to offer regulated services. Those regimes grant access to one EU EEA market at a time, or in rare cases the entire EU EEA single market. Details vary for each regulation or directive. In some cases, such regimes simply do not exist.
Within the EU, the United Kingdom benefits from passport to other EU EEA states. Conversely, EU EEA states can access the United Kingdom market.
Outside the EU, the United Kingdom is likely to be considered a third-country. Accordingly, UK firms would fall back on third-country regimes.
Below is a comparison of EU EEA passporting against third-country regimes from the perspective of the United Kingdom aiming to access the EU EEA single market. How firms in EU EEA states – or other jurisdictions – would access the UK market is out of scope.
EU EEA Passporting
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