The UK's transition period under the Brexit Withdrawal Agreement ended at 11 pm on 31 December 2020 and the EU-UK Trade and Cooperation Agreement (TCA), signed on 30 December 2020, did not address services in a substantive manner. For now, the provision of financial services between the EU and the UK is subject to the WTO's General Agreement on Trade in Services (GATS) trade rules in financial services.
The most significant impact of this for UK (re)insurers and intermediaries has been the loss of the benefit of their former passporting rights across the European Single Market (see below) and similarly for European (re)insurers and intermediaries that passported their services into the UK.
In the short term, the industry must await the European Commission's decision on equivalence for (re)insurance under Solvency II and more generally whether the EU and UK will agree a joint Memorandum of Understanding on financial services by the mutually agreed deadline of 31 March 2021. In the medium to long term, it will be interesting to see how the inevitable divergence of the Solvency II and Insurance Distribution regimes impact on the separate industries in the EU and the UK.