Status: Please note you should read all Brexit changes to the FCA Handbook and BTS alongside the main FCA transitional directions. Where these directions apply the 'standstill', firms have the choice between complying with the pre-IP completion day rules, or the post-IP completion day rules. To see a full list of Handbook modules affected, please see Annex B to the main FCA transitional directions.

SUP TP 9 Transitional Provisions in relation to the MiFID Regulation


Continuing obligations under the MiFID Regulation




If the condition in (2) is met, SUP TP 9 applies in respect of an obligation or requirement in, or under, the following with which a firm must comply:


the MiFID Regulation; or


a rule under SUP 17 (Transaction reporting).


As at 2 January 2018, a firm is under an obligation or requirement to comply, or to have complied, with a provision referred to in (1) in the version in force on that date.



A firm remains obliged to comply with the obligation, requirement or rule referred to in SUP TP 9.1.1R(1)(a) and (b) until such time as effective compliance is achieved.



SUP 15 (Notifications to the FCA) continues to apply in respect of a breach of a requirement or a rule referred to in SUP TP 9.1.1R.




The purpose of SUP TP 9.1.1R is to ensure that, as appropriate, firms:


comply with the provisions of the MiFID Regulation and SUP 17 (as at 2 January 2018); and


notify and remedy breaches of these provisions whenever those breaches come to light,

notwithstanding the repeal of the MiFID Regulation on 3 January 2018.