Since the UK left the European Union, passporting rights for financial services have ended, fundamentally changing how UK financial professionals work with EU-based clients.

For financial advisers, accountants, and solicitors, this issue often arises unexpectedly — especially when a long-standing client relocates to Spain, France, Portugal, or another EU country.

Suddenly, a previously straightforward advisory relationship may fall into a complex regulatory environment involving cross-border financial regulation.

In this guide, we explain:

• What passporting is and how it worked before Brexit
• Why passporting matters for UK advisers with EU clients
• What changed after Brexit
• What to do if a client moves to the EU
• Practical solutions for continuing to support clients compliantly

If you work with internationally mobile clients or expatriates, understanding these rules is essential.

Passporting was a system within the EU Single Market that allowed financial services firms authorised in one EU country to operate across the entire European Economic Area (EEA).

Under this framework, firms regulated in one member state could:

• Provide services across EU borders
• Establish branches in other EU countries
• Serve EU clients remotely without needing additional licences

Passporting was enabled by EU regulations such as:

• MiFID II (Markets in Financial Instruments Directive)
• UCITS Directive
• AIFMD (Alternative Investment Fund Managers Directive)

These rules created a single financial services rulebook across Europe.

The UK previously benefited enormously from this system, as London was Europe’s largest financial services hub.

More information on passporting can be found via the Financial Conduct Authority (FCA)

Before Brexit, the UK was the largest exporter of financial services within the EU.

UK financial firms were able to serve millions of EU clients seamlessly — including expatriates, international investors, and business owners.

According to the UK Office for National Statistics, financial services exports to the EU represented a significant portion of the UK’s service exports before Brexit.

However, after leaving the EU, the UK became classified as a “third country” under EU financial regulation.

This means UK firms no longer have automatic access to the EU single market for financial services.

More information on post-Brexit financial regulation is available from the European Commission.

When the Brexit transition period ended on 31 December 2020, UK financial services firms lost their passporting rights.

This means UK firms must now use alternative routes to serve EU clients. These typically include:

1. Establishing an EU subsidiary

To regain access to the EU market, some firms have opened regulated offices in EU jurisdictions such as:

• Ireland
• Luxembourg
• Germany
• France

2. Obtaining local regulatory licences

Firms may apply for authorisation within a specific EU country.

However, this usually only allows them to operate within that country, not across the entire EU.

3. Partnering with an EU-regulated firm

Another option is collaborating with an EU-based adviser who holds the necessary regulatory permissions.

This is often the most practical route for many UK advisers.

4. Restricting advice to UK matters

In some cases, advisers may still provide guidance on:

• UK pensions
• UK investments
• UK assets

However, the scope of what is permitted depends on the regulatory interpretation of each EU country.

A common scenario today is when a UK client relocates abroad.

Examples include:

• Retirement in Spain or Portugal
• Relocation for work to France or Germany
• Permanent moves within the EU

If you are not authorised to operate in the client’s country of residence, you may face regulatory limitations on continuing to provide advice. 

Possible actions include:

• Stopping regulated financial advice
• Referring the client to an EU-regulated adviser
• Working alongside an EU-based advisory firm
• Restricting your role to UK-only financial matters

Many UK advisers working with expatriates now collaborate with international specialists such as expat financial planners who are structured to operate cross-border.

Some advisers choose to refer EU-based clients to specialist firms focused on expatriate financial planning.

For example, Galileo Wealth provides guidance for internationally mobile individuals in areas including the following:

• Pension planning
• Retirement planning
• Cross-border investment strategies

UK solicitors can still work with EU clients, but the legal landscape has changed.

Before Brexit, solicitors benefited from EU directives that allowed easier recognition of legal qualifications across member states.

Now, solicitors may need to:

• Register with a local bar association
• Work in partnership with EU-qualified lawyers
• Establish a legal presence in an EU country
• Regulatory requirements vary widely between EU member states.

Guidance is available through the Law Society of England and Wales.

Accountants can usually continue working with EU clients, but tax and regulatory complexities often arise when a client relocates.

These may include:

• Tax residency changes
• Reporting obligations
• Double taxation issues
• Local compliance requirements

Clients moving abroad should also understand how EU regulations such as MiFID, AIFMD, and GDPR may affect their businesses or investments.

UK advisers should ensure clients obtain appropriate local tax and financial advice where necessary.

When a client relocates abroad, transparency and proactive communication are essential.

Best practice includes:

• Explaining regulatory limitations clearly
• Protecting your client relationship with honest advice
• Introducing clients to trusted international advisers
• Ensuring a smooth transition to compliant cross-border advice

Many expatriates require specialist guidance on areas such as pension transfers, cross-border investments or international retirement planning.

For example, expats often explore solutions like International SIPPs for managing UK pensions abroad.

If your client moves abroad, their financial situation may become more complex. Issues often include cross-border taxation, pension transfer decisions, investment reporting requirements or estate planning across jurisdictions.

Working with a firm experienced in expatriate financial planning can help ensure clients remain compliant while maintaining continuity in their financial strategy.

Galileo Wealth specialises in helping expatriates across Europe manage pensions, investments, and long-term financial planning.