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Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
IP completion day definition

What does IP completion day mean? The point in time marking the end of the Brexit implementation (transition) period for UK legal purposes. In practice, it is the trigger date used in UK statutes, statutory instruments and contracts to determine when EU law stopped applying and when UK amendments took effect. It is defined in legislation: section 39 of the European Union (withdrawal agreement) Act 2020 fixes “IP completion day” as 11.00 p.m. on 31 December 2020 (UK time). Key legal effects include: establishing the snapshot for “retained EU law” under the European Union (Withdrawal) Act 2018; altering the supremacy and direct effect of EU law as...

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Derivatives after IP completion day: UK and EU rules on market access, CCP recognition, EMIR clearing/reporting/margin, trading, benchmarks and short selling

Practice notes
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ARCHIVED: This Practice Note has been archived and is no longer being maintained.

Through the transition period, core EU rules effectively continued to apply for Derivatives practitioners (see Practice Note: Brexit—impact on finance transactions [Archived]); from IP completion day, however, the landscape alters markedly.

This note offers a high-level overview of IP completion day’s practical implications for derivatives lawyers and signposts fuller guidance.

MARKET ACCESS FOR SWAP COUNTERPARTIES

Key EU and UK legislation and Brexit SIs

  • Directive 2014/65/EU (EU MiFID II) and Retained Directive 2014/65/EU (UK MiFID II)
  • Regulation (EU) No 600/2014 (EU MiFIR) and Retained Regulation (EU) No 600/2014 (UK MiFIR)
  • Directive 2013/36/EU (EU CRD IV) and Retained Directive 2013/36/EU (UK CRD IV)
  • The EEA Passport Rights (Amendment, etc., and Transitional Provisions (EU Exit) Regulations 2018, SI 2018/1149
  • The Financial Services Contracts (Transitional and Saving Provision) (EU Exit) Regulations 2019, SI 2019/405

Key changes in practice from IP completion day

UK banks and investment firms — Passporting: Until the close of the implementation period, a UK bank or investment firm that held permission to carry out...

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Web page updated on 21/05/2026

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