On March 29, 2017, Britain invoked Article 50 following the referendum held on June 23, 2016, in which 51.9 percent of the participating UK electorate voted to leave the EU. Though the UK will officially leave the EU by March 29, 2019, followed by a transition period of 21 months, the exit decision itself triggered exchange rates so volatile that it became difficult for businesses to maintain clear visibility on their international transfers. Brexit will eventually have an impact on business, payment service providers, and consumers—but it will largely depend on how the UK’s future trading relationship is going to be with the EU.
In the absence of clarity of the eventual shape of Brexit, certain financial institutions are planning for the “hard” Brexit scenario and making decisions about locations, hiring and technology changes. From a payments perspective, banks are reviewing their solutions across liquidity (notional pooling, cash concentration), payments (SCT, SDD, high-value payments, FX), cash management services (virtual accounts, receivables management) and Euro-denominated products to continue to operate across borders.
Post the transition period, the UK might also lose direct access to Euro Clearing & Settlement Mechanisms (CSMs) such as TARGET2, EBA EURO1 and EBA STEP2. UK banks may need to build Euro-clearing propositions in Europe to handle affiliates and third party/correspondent bank high-value clearing, which would involve rerouting transactions, indirect memberships via Europe branches, Nostro setups, reviewing charging models, etc.
Non-EU financial institutions will not be able to use their UK branches to pay and collect funds after Brexit takes place, and would need to consider transferring SEPA access sponsorship from the UK to European branches. However, if they remain part of the European Economic Area (EEA) and the European Free Trade Association (EFTA), they can continue to take advantage of SEPA.
Acquiring players may have to move their headquarters to other European markets and take new contracts to operate in the EU. Splitting acquiring entities means significant overhead by dividing scheme submissions across multiple BINs. Card machine providers would need to reclassify their machines as international or inter-regional so that customers and merchants are aware of all the changes while making card payments. The UK’s interchange classification will significantly affect merchant pricing, with open questions around the UK’s registration as part of the EEA post-Brexit impacting interchange base costs. Also, unknown regulatory position post-Brexit on key issues such as interchange caps and card surcharges.
PSD2 is applicable to UK banks since it came into effect in January 2018. Banks have already spent more than GBP750 million in preparation for the regulation, but once UK has officially left the EU, the UK Open Banking initiative is more likely to replace PSD2 and potentially have limited impact on a practical level.
The UK startup ecosystem massively supported the “Remain” vote as it provides them easy access to the Single Market, which is an important asset for startups’ business development potential. Now they are quickly adapting to the fast-changing environment—and developing cross-border business is typically part of the tech entrepreneur’s DNA.
While negotiating exit from the EU, it is important from a payments perspective that there is no detriment for customers or businesses, and that the UK economy continues to operate smoothly. Without any solid evidence on the changes to current legislation, firms need to ensure that compliance and change teams are on the front foot to meet the requirements of the new ecosystem.