What does it mean to you as a Corporates & Institutions customer?
The UK is due to leave the European Union (EU) on 29 March 2019. Until then, Brexit will have no immediate impact on our Corporates & Institutions customers in relation to the products and services provided by Danske Bank. Regardless of the final outcome of the ongoing negotiations between the UK and the EU on Brexit, we expect to be able to continue to provide our current banking- and investment services to you in, to and from UK.
On 15th January 2019, the UK’s House of Commons voted on the tabled Withdrawal Act, proposed by Prime Minister Theresa May. The result of this vote was ‘No’ with MP’s voting 202 for and 432 against. Ministers within UK’s government now have until 21st January to deliver a plan B and agree a way forward.
Regardless of the outcome of the political process, we expect to be able to continue to provide our services to our customers.
How is Danske Bank connected to the UK?
Danske Bank is a Nordic bank licensed in Denmark and operating in the UK under our EU banking license (EU passport). We offer banking- and investment services to UK C&I customers either from our UK entities (London Branch and Northern Bank) or as cross-border services from our EU entities, mainly from Denmark, Sweden, Norway, Finland or Ireland. We also provide financial services from UK to our mainly Nordic market customers.
Possible Brexit scenarios and what they mean to Danske Bank C&I customers
We have prepared for a number of scenarios to ensure that we are ready to embrace the outcomes whether a deal is negotiated or not. At the moment we see four possible Brexit scenarios as illustrated in red colour in the figure below:
On 25 November 2018 the EU and the UK signed a Withdrawal Agreement for the UK’s departure from the EU on 29 March 2019. The EU UK Withdrawal Agreement allows Danske Bank to continue to serve our customers in, to and from UK as today until end of 2020 (the transition period). The Withdrawal Deal needs to be approved by member states plus the UK and European parliaments.
On 15 January the UK’s House of Commons rejected the Withdrawal Agreement. In case UK later on decides to accept an amended version of the Withdrawal Act, we expect that Danske Bank will continue to offer the same banking- and investment services to our C&I customers as we do today, in, to and from UK. In case we will need additional UK licenses after the end of the transition period, we will prepare for this, so we can continue to serve our customers without disruption to the extent possible.
"No Deal Brexit"
In case UK decides to leave the EU without a deal, Danske Bank expect to be able to continue our current banking- and investment services in and to the UK either via our UK entities (Northern Bank and London Branch), via the UK Temporary Permissions Regime or as services exempt from UK regulation, e.g. via the UK FSMA rules on Overseas Persons Exemption (OPE).
Depending on the final outcome of the EU-UK negotiations, we may face restrictions on certain services provided from our UK entities to customers in EU. If so, Danske Bank expect to be able to continue to provide the same banking- and investment services to EU C&I customers from one of our EU entities.
In case UK decides (e.g. via application for EEA membership) to renegotiate the Brexit terms into a form that will allow UK to continue its current access to the EU internal market for financial services, Danske Bank will continue to offer banking- and investment services in, to and from the UK under our EU-passport as today.
In case UK decides (e.g. via a new referendum) to stay in the EU, Danske Bank will continue to offer banking- and investment services in, to and from the UK under our EU-passport as today.
What does Brexit mean?
“Brexit” is the abbreviation used to describe the UK’s exit from the European Union (EU). The UK voted to leave the EU following a referendum in June 2016. In March 2017, the UK Government started the process of leaving the EU by triggering Article 50 of the Treaty on European Union. The UK is expected to remain a member of the EU until 29 March 2019. There should be no immediate impact on your everyday banking services.
What is article 50?
Article 50 of the Treaty on European Union is a provision in law which sets out how a Member State can leave the EU.
What is the Withdrawal Deal?
In November 2018, the EU and UK signed a Withdrawal Deal on the UK’s departure from the EU, including a transition period until 31 December 2020. They have also agreed a top level political agreement on the future UK-EU relationship which is not legally binding at this stage.
What happens next?
The Withdrawal Deal now needs be approved by member states and the UK & European Parliaments. It is expected that the full future EU-UK deal, including for financial services will be worked through during the transition period.
What does it mean for me as a customer?
Nothing has changed as a result of the announcement. There will be no immediate impact on your everyday banking services.
The UK is expected to remain a member of the EU until 29 March 2019 and the transition period that then follows should be on the same terms we have today.
What is the transition period?
It is a period of time between 29 March 2019 and 31 December 2020 to allow businesses and others to prepare for the moment when the new post-Brexit rules between the UK and the EU begin.
In March 2018, the European Council announced that a political deal on a transition period had been agreed ahead of the UK’s withdrawal from the EU. And at the end of April 2018, the European Central Bank indicated that EU passporting rights would remain in place for UK firms during the proposed transition period.
What is EU passporting?
EU passporting allows us as a bank to sell our financial services to customers in all EU countries, so that it’s as easy for us to lend to a customer in another EU country as it is to lend to a customer in Copenhagen. It also means that our UK entities (Northern bank and London Branch) can sell their financial services in the UK as well as into EU countries.
Why will EU passporting be removed when the UK leave the EU?
Passporting is intrinsic to the EU Single Market and will not be available to the UK in case of a Hard Brexit. The UK Government in its July 2018 white paper stated that its proposal for the economic partnership would include new arrangements on services and investments that provide regulatory flexibility.
How will Danske Bank operate in the UK without EU passporting in case of a Hard Brexit?
We provide banking- and investment services to our UK C&I clients, either via our UK entities (London branch and Northern Bank) or as cross-border services from our EU entities, mainly from Denmark, Sweden, Norway, Finland or Ireland. We currently offer these services under our EU passport, but have prepared for necessary re-licensing to ensure continued access to offer services to our UK C&I clients also in case of a Hard Brexit.
Amongst other things, we have applied for UK license for our London Branch acting as Third country incoming branch of Danske Bank. The UK Prudential Regulation Authority and the UK Financial Conduct Authority are currently processing our application jointly with similar applications from other EU27 banks. We currently expect to receive this authorisation prior to 29 March 2019, which will allow us to continue our current UK Services to our clients on an uninterrupted basis. In the unlikely case we do not receive the authorisation prior to 29 March 2019, we will be able to continue our current UK Services during the next three years under the UK temporary permissions regime.
Consequently, Dansk Bank will be able to continue to offer banking- and investment services to our UK C&I clients also after Brexit.
What is the UK temporary permissions regime?
The UK Government have proposed a Temporary Permissions Regime, which in case of a Hard Brexit with effect as from 29 March 2019 will allow existing providers of financial services from EU27 into the UK on the basis of EU passporting to continue such activities for an interim period until March 2022.