UK Treasury's overseas recognition regime starts 28 Nov
From 28 November 2025, the UK will run a formal process for recognising overseas financial rules. HM Treasury’s Financial Services (Overseas Recognition Regime Designations) Regulations 2025, approved by both Houses of Parliament and made on 30 October 2025, set out how designations are created and managed. The instrument applies across the UK and is published on the UK legislation website.
Quick definition: an “overseas recognition regime designation” is a ministerial decision that the law and supervisory practice in another country or territory delivers the same overall effect as the UK’s rules in a given area of financial services. “Territory” can include the European Union or another international organisation. Think of it as an outcomes test rather than a line‑by‑line copy of the UK rulebook.
Why it matters: recognition decisions can cut duplicate checks when business crosses borders. HM Treasury’s July 2025 guidance says recognition may let some overseas firms serve UK clients directly, align requirements on UK firms when they deal in overseas markets, or remove duplicate reporting. That affects costs, competition and the services you use, from insurance to trading.
What changes on 28 November is the plumbing, not the country list. This regulation builds the framework; it does not itself name which places are recognised. Designations will follow using the powers listed in the Schedule. For now, the structure links into two areas you’ll see in textbooks: the overseas insurance regime in the 2023 prudential rules, and the Short Selling Regulations 2025.
How decisions are made is straightforward. The Treasury leads, but it can ask the regulators for technical advice and data. Regulation 4 allows the Treasury to require information or advice from the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA) and the Bank of England. Even without a formal request, regulators can share advice to inform a possible designation.
Co‑ordination and transparency are built in. Regulation 5 requires the Treasury, the FCA, the PRA and the Bank of England to agree and maintain a memorandum explaining how they will work together on making, amending or revoking designations and on sharing information. The Treasury must lay a copy before Parliament and publish it so the public can read it.
Designations are flexible. Under Regulation 3 the Treasury may impose conditions or limits, and it can revoke or vary a designation if circumstances change. That means recognition can be partial, time‑limited or updated to keep pace with standards while protecting UK objectives.
Confidentiality rules are updated to fit this process. Regulation 6 brings information the Bank of England receives for these decisions under the Financial Services and Markets Act 2000 confidentiality framework. In practice, sensitive material stays protected, while allowing the Bank to share it with the Treasury when needed for a designation decision.
There are tidy‑ups in connected laws that exam questions love. For insurance, Regulation 7 updates the 2023 Insurance and Reinsurance Undertakings rules by removing the words “or Gibraltar” from the definition of “overseas jurisdiction” in Regulation 10. For short selling, Regulation 8 clarifies that “territory” includes the European Union and any international organisation or authority made up of countries or territories.
Where this sits in the bigger story matters. If you studied the 2019 EU Exit instrument on “Equivalence Determinations” (S.I. 2019/541), you’ll recognise the idea. That earlier regime was revoked by the Financial Services and Markets Act 2023. This 2025 instrument restates and updates the approach, placing the UK on an outcomes‑based recognition model that fits today’s post‑Brexit rulebook.
What to watch next as a reader or student: two milestones. First, the joint memorandum from the Treasury, FCA, PRA and Bank of England will be laid before Parliament and published, giving us a public map of who does what. Second, expect the Treasury to consult and then bring forward specific designations for particular jurisdictions under the insurance and short selling regimes, each with its effect and any conditions explained.
Study pointers and key dates to remember. The draft regulations were laid on 15 July 2025 under the affirmative procedure; both Houses approved them; the instrument was made on 30 October 2025; and the rules start on 28 November 2025. Names to note are Lilian Greenwood and Stephen Morgan, the Treasury Lords Commissioners who signed the instrument. For the legal text, use the UK legislation website; for policy context, HM Treasury’s guidance published in July 2025 is your best primer.