On Wednesday, HM Treasury explained its approach to “onshoring” financial services legislation post-Brexit: expect a flurry of SIs this summer as a contingency against the possibility that no UK-EU27 withdrawal agreement takes effect. The Bank of England, the PRA, the FCA and the Payment Systems Regulator will assume the regulator roles. Legislation under the European Union (Withdrawal) Act 2018 will create temporary permissions and recognition regimes to allow EU27 firms, including CCPs, to operate in the UK for a period post-Brexit even if there is no implementation period, and to seek authorisation if they want to operate in the UK long term. The EU has yet to reciprocate.