With the UK and EU having announced the breakthrough on its Trade and Cooperation Agreement ( TCA) the next steps for financial services firms will be if policymakers will turn to granting a decision on equivalence for a “third country”. From January 1, 2021, the UK will, following the end of the Brexit-transition period and the TCA, be treated by the EU as a “third country”. The EU has been reluctant to indicate whether it would grant an equivalence decision irrespective of the UK having implemented EU financial services legislation but having stated it would diverge in defined areas going forward. EU legislation refers to those jurisdictions that are not part of the European Economic Area (