From January 1, 2021, there is no further legal basis for a registration according to sec. 8, phrase 1 no. 5 of the German Regulation regarding Insurance Brokers (Versicherungsvermittlerverordnung) if an insurance broker intends to be active in the United Kingdom. With the UK’s final exit from the European Union there is no further basis for the Passporting system in this respect. The same applies to sec. 6 par. 1 no. 6 and par. 2 of the German Regulation regarding Real Estate Loan Brokers (Immobiliendarlehensvermittlerverordnung) with regard to real estate loan brokers.
Brexit consequences for brokers activities in the UK
Existing entries regarding any mediation or broker activity in the UK will be deleted shortly. German brokers who wish to be (further) active in the UK need to obtain an appropriate permission by the Financial Conduct Authority (FCA). There will be no facilitation for brokers if their respective activities in the UK are still being shown in the registry for an intermediate period.
Brexit consequences for Private Limited Companies with administrative office in Germany
Regardless of the Trade and Cooperation Agreement entered into by the UK and the EU on December 24, 2020, freedom of settlement no longer applies to companies under UK law with administrative office in Germany after the end of the transition period (December 31, 2020). There is no legal basis for further recognition of such companies from 2021 onwards.
Transition period for UK brokers
Brokers from the UK need a German brokers permission from January 1, 2021. There is no transitional period.