UK Post-Brexit Compliance: What EU Companies Must Know in 2026
Since Brexit, the UK's regulatory framework has been diverging from the EU. Understanding these differences is critical for dual-market operations.
UK GDPR: growing differences
The UK retained the GDPR as "UK GDPR" but is proposing changes through its Data Protection and Digital Information Bill: simplified research rules, modified cookie consent, and flexible legitimate interest assessments. The EU's adequacy decision for the UK, granted in 2021, is subject to renewal and depends on divergence levels.
FCA Consumer Duty
The FCA's Consumer Duty requires financial firms to deliver "good outcomes" for retail customers. This goes beyond MiFID II, requiring proactive demonstration that firms act in customers' best interests. For EU fintechs entering the UK, this is a critical new requirement that Cleo maps alongside existing EU obligations.
UK AI regulation: sector-specific approach
While the EU has the prescriptive AI Act, the UK pursues principles-based, sector-specific AI regulation. Existing regulators (FCA, ICO, Ofcom, CMA, MHRA) each develop domain-specific AI guidance. Companies in both markets face fundamentally different compliance architectures. Cleo maps both approaches simultaneously, highlighting overlaps and divergences.
Frequently asked questions
How does UK GDPR differ from EU GDPR?
- While largely mirroring EU GDPR, the UK version has different adequacy mechanisms, independent ICO guidance, and proposed reforms including simplified research exemptions and reduced cookie consent requirements.
Sources & references
Related resources
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