Brexit – transitional permissions regime for intermediaries governed by the law of the UK or Gibraltar

As a consequence of Brexit, (re)insurance and ancillary insurance intermediaries governed by UK or Gibraltar law no longer benefit from the European passport: this means they are no longer authorised to pursue their activities in Belgium.

These intermediaries could, however, benefit from a transitional permissions regime that will temporarily enable them to continue their activities in Belgium. The Royal Decree of 22 December 2020 (published in the Belgian Official Gazette on 31 December 2020) introduced a transitional regime which allows (re)insurance and ancillary insurance intermediaries established in the UK or in Gibraltar, and who were already authorised to pursue their activities in Belgium before Brexit, to temporarily pursue their activities relating to the insurance contracts concluded before that date, without being enrolled in the register held by the FSMA.

Intermediaries who wished to benefit from the transitional regime had to notify the FSMA within two months of 1 January 2021 at the latest. It is therefore no longer possible to invoke this regime.

This regime ended on 30 June 2022. Since that date, insurance intermediaries governed by the laws of the UK or Gibraltar may not carry out (re)insurance distribution activities in Belgium, unless they are registered in the register of insurance intermediaries and ancillary insurance intermediaries, held by the FSMA.

Any questions about this regime can also be sent to