FCA Financial Services Register
The UK has left the European Union (EU) and the Brexit transition period will end at 11pm on the 31st December 2020. When the transition period ends, financial service providers in the UK will no longer be allowed to ‘passport’ their services into European Economic Area (EEA) member states.
The FCA Financial Services register will be off-line from 11pm, 31st December 2020 until 8am on the 4th January 2021. This is to enable the FCA to update the register with details of EEA firms which have notified them of their participation in the Temporary Permissions Regime (TPR).
During this off-line period, EEA TPPs that have notified the FCA of their participation in the TPR, will be able to continue providing the same services in the UK that they could under the passporting authorisation granted to them by their home National Competent Authority (NCA) prior to the 31st December 2020.
From the 4th January 2021, EEA TPPs that have notified the FCA of their participation in the TPR, will be listed on the FCA Financial Services register together with the payment services the FCA has authorised them to provide.
Konsentus Verify Responses
The Konsentus Verify API will not change but UK ASPSPs will have to interpret the responses from Konsentus Verify appropriately as the information from the FCA evolves over the period of time from when the Brexit implementation period comes to an end at 11pm on the 31st December 2020 and the FCA Financial Services Register comes back on-line at 8am on the 4th January 2021.
Konsentus Verify will continue to be able to verify eIDAS certificates issued by EEA QTSPs but it will also be able to verify Open Banking Ltd. certificates (OBWAC and OBSealC) from the 1st January 2021. The Konsentus Verify Sandbox will be able to verify an OBWAC or an OBSealC from the 18th December 2020 for testing purposes. Note, UK registered TPPs can continue using their existing eIDAS certificates until they expire or have been revoked.
Konsentus Verify will return the authorisation data that is available on the EEA NCA and FCA registers. However, as the FCA register will be off-line from 11pm on the 31st December 2020 until the 8am on the 4th January 2021, any EEA ASPSP that receives an API request from a UK registered TPP during this period will continue to see the passporting data that was on the FCA register at 11pm on the 31st December 2020. The FCA will be removing this data but it will not be visible on the register until the FCA brings it back on-line on the 4th January 2021.
Any UK ASPSP receiving API requests from EEA registered TPPs, during the time the FCA register is off-line, will only see the TPP’s authorisation data from its home NCA register. After the 4th January 2021, when the FCA register will include data for TPPs authorised to provide payment services in the UK under the Temporary Permissions Regime, Konsentus Verify will return the TPP’s TPR data as well as its home NCA register data.