Today will see the formal notification by the UK government under Article 50 of the Lisbon Treaty that the UK intends to leave the Union (for example, see here on the BBC web site). Officially the process takes 2 years, which would place the “Brexit” date at the 29th March 2019.

The energy and commodities market will likely see an impact: On the financial regulation side, the FCA made clear on the day after the Brexit vote that MiFID II will carry on, since it starts to apply prior to the exit date. Market participants will wish to know how exactly rules such as MiFID II will work under a UK regime alongside the EU regime. Similarly, it is not yet clear how matters such as trade reporting will be handled. Will data that involves a UK counterparty need to be reported to a separate trade repository? Could there be double reporting? The likely objective of the government is to retain some sort of equivalence, for example as referred to in this article on the Reuters web site. Others, such as those mentioned in this article on eFinancialCareers, take a different view.

On the energy side, the impact on the wholesale market is also unclear, as can be seen in the recent white paper from the UK government, which can be found here. The question of the impact on REMIT, especially data reporting, as well as the implementation of the Winter Package and general participation in the Energy Union, remains to be seen.

Until now, the likely outcome has mainly been the subject of speculation. Once the notification has been given, we will eventually earn the actual facts of the Brexit, and be able to plan for the real impact that the UK’s departure will have on how regulatory obligations are met.