Eligibility? Activities covered? Clients covered? Application or notification required? N/A N/A N/A N/A N/A N/A N/A

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1 NO DEAL BREXIT TRACKER Governments in European Economic Area (EEA) member states are announcing domestic measures in order to prepare for the UK's withdrawal from the EEA. The table below monitors these developments in each jurisdiction and provides a high-level summary of the relevant provisions, as they pertain to the financial services sector. This table is for information purposes only and has been compiled on the basis of publicly available information. It does not constitute, nor is it intended to constitute, legal advice from Allen & Overy LLP. The information in this table does not provide further detail on relevant exemptions to financial services licensing regimes in EEA member states that may exist independently of the measures that are proposed or have been taken to accommodate the UK s withdrawal from the EU. In the table below, banking services means the activities listed in Annex I to the recast Capital Requirements Directive IV, investment services means the activities listed in sections A and B of Annex I to the recast Markets in Financial Instruments Directive II and payment services means the activities listed in Annex I of the recast Payment Services Directive II. Insurance activities are defined as applicable in the table. refers to business that has been entered into prior to or on exit day and new business refers to business that may be entered into after that date. Where national regimes have addressed lifecycle events under existing contracts, we have set out the relevant proposals below. Austria No financial services specific proposal at this stage. N/A N/A N/A N/A N/A N/A N/A Belgium Draft proposals Otherwise consider using third country licensing regime. The draft law grants authority to the national government to take measures in relation to existing contractual relationships. Not specified at this stage. Not specified at this stage. Not specified at this stage. UK firms should consider using the existing licensing regime for third country firms for new Such authorisation will cover existing business as Where UK firms apply for authorisation under the Belgian third country licensing regime, such authorisation (if obtained) will cover existing For banking services, firms should submit a local branch application to the National Bank of Belgium. For investment services, firms should inform the Belgian Financial Services and Markets Authority that they intend to carry out. For payment services, firms should submit a local branch application to the National Bank of Belgium. Bulgaria No financial services specific proposal at this stage. N/A N/A N/A N/A N/A N/A N/A Croatia N/A N/A N/A N/A N/A N/A N/A N/A Cyprus N/A N/A N/A N/A N/A N/A N/A N/A BK:

2 Czech Republic Draft proposals Transitional relief ends in Only covers activities necessary for the settlement of existing obligations under all types of financial services contracts. Clients or counterparties to contracts evidencing existing obligations only. N/A Denmark Law/rules in force for licensing regime. Draft proposals published for insurers and reinsurers. Consider using existing country firms. A separate regime has been established for UK based insurer and reinsurers. Such entities may not service contracts entered into before 30 March 2019 after 31 Insurance services Seek local law advice for other activities. The Danish regime does not Estonia N/A N/A N/A N/A N/A N/A N/A N/A Finland Law/rules in force. UK firms that have submitted a licence application before Brexit may provide investment services on the basis of and to the extent covered their pre-brexit passport in Finland until their application has been proceed. Relief would not apply to UK branches of EEA firms. A firm s application must be submitted prior to exit day in order to benefit from the relief. The Finnish regime does not. France Law/rules in force. UK central counterparties. UK central securities depositories. Permitting continued access by French firms to UK central counterparties and UK central securities depositories. French participants in UK systems. Certain insurance services. Clients under existing insurance contracts but such contracts cannot provide for the payment of new subscriptions. The activity of entry into new insurance contracts will require a license. Contracts entered into prior to exit day cannot be renewed or provide for payment of new premiums. UK counterparties Permitting novation of master agreements. French counterparties under existing master agreements. Germany Law/rules have passed all essential political steps. Transitional relief depends on whether and how the Germany regulator (BaFin) Retail Professional Depends on how BaFin will exercise its discretion under the Brexit Act BK:

3 exercises its discretion provided under the Brexit Act; in any event ends in German regulator has been provided with discretion to extend this regime to payment services. Eligible counterparties Greece N/A N/A N/A N/A N/A N/A N/A N/A Hungary N/A N/A N/A N/A N/A N/A N/A N/A Iceland N/A N/A N/A N/A N/A N/A N/A N/A Ireland Draft proposals 3-year regime to allow for run-off of insurance and insurance intermediary branches (passporting under Solvency II or the Insurance Distribution Directive). on a cross-border basis (passporting under Solvency II or the Insurance Distribution Directive). Administration of existing portfolio of Existing customers under such contracts. A notification must be made to the Central Bank of Ireland by the UK/Gibraltarian firm within 3 months of the regime coming into effect. N/A 9-month temporary designation for UK settlement finality systems with the option to apply for permanent designation. UK systems which are designated under UK law. Permitting continued access by Irish firms to UK systems. Irish participants in UK systems. A notification must be made to the Central Bank of Ireland and the Minister of Finance by the UK system within 3 months of the regime coming into effect. New systems governed by UK law can apply for designation in the future. N/A Italy Draft proposals 18-month transitional period from exit day for banks, investment firms and electronic money issuers with a branch in Italy. 6-month transitional period for payment institutions, fund managers and electronic money institutions operating on a cross border services basis in order to wind-down business or apply for the relevant licence in Italy. UK banks and investment firms with a branch in Italy or who provide certain crossborder services (subject to certain conditions the transitional relief will not cover acceptance of deposits on a cross border basis). UK electronic money issuers with a branch in Italy. The Italian regime will not cover UK payment service providers or UK funds or UK electronic money issuers without a branch in Italy. Banking services Investment services Electronic money services For UK firms providing services into Italy on a crossborder basis, such activities are limited to (i) per se professional and (ii) eligible counterparties. File a notification with the relevant Italian competent authorities (i.e. Bank of Italy for UK banks and EMIs; CONSOB for UK MiFID investment firms) within 3 business days before exit day. The same regime applies as for pre-existing Firms would be able to undertake new business until the end of the transitional period. During the transitional period, firms would be required to file an application with the relevant Italian competent authorities to continue to operate in Italy after the expiration of the transitional period. Such an application must be filed within 6 months after the commencement of the transitional period. Latvia N/A N/A N/A N/A N/A N/A N/A N/A BK:

4 Liechtenstein N/A N/A N/A N/A N/A N/A N/A N/A Lithuania N/A N/A N/A N/A N/A N/A N/A N/A Luxembourg Draft proposals 1 The transitional relief can last for a 21-month period after exit day subject to discretion of relevant Luxembourg regulator. Not specified at this stage. Not specified at this stage. Not specified at this stage. Payment services. Malta N/A N/A N/A N/A N/A N/A N/A N/A Norway Law/rules in force. The transitional period is undetermined. It is expected to last for a period of one year from the date of the UK s withdrawal from the EU. 2 We expect the same regime to apply for pre-existing We expect the same regime to apply for pre-existing Poland Draft proposals For credit institutions, transitional relief will end in March For investment firms, transitional relief will end in March branches. UK/Gibraltarian firms providing services on a cross-border basis. Banking services (except that credit institutions may not enter into new credit agreements, extend the term of existing agreements, increase the amount of available credit under such an agreement or make amendments which would increase their level of risk). Existing clients only. Investment services (except that investment firms may no enter into new agreements or extend the term of existing agreements). Payment services. 1 We expect further clarification on the Luxembourg proposals in the week commencing on 1 April The Norwegian regulator (the FSA) has the ability to set conditions for the activities of UK firms using applicable relief. The FSA has not made any announcement about how it expects to set conditions, but it is expected that this may include the requirement to notify the FSA prior to, or at the point of, using such relief BK:

5 Portugal N/A N/A N/A N/A N/A N/A N/A N/A Romania N/A N/A N/A N/A N/A N/A N/A N/A Slovak Republic N/A N/A N/A N/A N/A N/A N/A N/A Slovenia N/A N/A N/A N/A N/A N/A N/A N/A Spain Draft proposals Firms will be able to service existing contracts on the basis of their existing authorisation until December 2019 at which point they will be required to obtain new authorisation. branches. UK/ Gibraltarian firms providing services on a cross-border basis. Existing clients only. Must obtain relevant licenses under third-country authorisation regime After the expiration of the transitional period, firms must obtain a licence under the Spanish third country authorisation regime. Sweden Law/rules have passed all essential political steps. Government is expected to amend the licensing regime to permit UK firms to continue to provide services until the end of The Swedish regime does not The Netherlands Final rules Rules will enter into force in the event of a no deal outcome. Until 1 January The Dutch regime does not 3 The Swedish regulator has the ability to extend this transitional relief to retail investors. It has not to date published any plans indicating that it expects to exercise this power. 4 Any notification requirements will be the subject of a separate ordinance to be published by the Swedish government in due course BK: