Transitional directions

The documents linked to on this page set out the full legal effect of the Temporary Transitional Power (TTP).

To understand the legal framework of the TTP, firms should read:

These draft directions assume the Treasury's legislation to which they refer is amended to refer to 'IP completion day' (11pm on 31 December 2020) rather than 'exit day'.

We propose to make the final TTP directions towards the end of the transition period, and expect to publish them in December.

Annex A to the main FCA transitional direction sets out how the TTP applies and where it does not apply to legislation, including BTS. Given the complexity of the legislative framework and the effect of the TTP on law, it is necessary to set out what modifications are made to the law in some detail. 

Annex B (FCA Rules) to the main FCA transitional directions sets out how the TTP applies and where it does not apply to FCA rules. The TTP does not apply to rules that apply only to temporary permission firms (including Part 6 financial services contracts firms) and temporary marketing permission managers etc. However, the rules themselves include provision to ensure that the transition is smooth.

The TTP does not apply to various FCA rules, including:

  • FEES rules and levies rules applying to the temporary permission regime and various rules in: PRIN, GEN, MIPRU, IPRI(INV), COBS, ICOBS, MCOB, BCOBS, CASS, MAR, SUP, COMP, COLL, CONC, FUND, LR, PRR, DTR
  • rules referring to UCITS management companies specified in Annex B

To see the links to our previous draft transitional directions, annexes and explanatory note, go to the previous TTP updates page.