Why do I need to create new authorisations for my clients UK bank accounts?
Before Brexit, an EEA-authorised AISP could "passport" into the UK and access UK accounts on the strength of its home-state (Irish) registration. Passporting between the UK and EEA ended at 11pm on 31 December 2020. Since then, EEA firms can no longer passport into the UK and must be directly authorised or registered by the FCA
This is why a CBI-registered Irish AISP cannot lawfully access UK-domiciled accounts, and a UK-registered entity cannot access EEA accounts — each jurisdiction requires its own regulated entity.
Circit Limited, is registered with the Central Bank of Ireland (CBI) as an Account Information Service Provider. Its UK entity, Circit UK Limited, is a separate company registered with the FCA
What will change on the client side?
The connection flow itself stays the same — your client will still see the familiar Circit consent screen and connect their account in a few clicks. The only visible change is that clients granting access to a UK-domiciled account will now be asked to accept a Circit UK Limited Terms of Service, reflecting the fact that UK accounts are accessed under our FCA registration rather than our Irish one.
What accounts are affected?
Any account domiciled in the UK — meaning it's held with a bank regulated in the UK — is affected, regardless of which country your client or your firm is based in. This includes clients' UK bank accounts even where the client entity itself is based outside the UK.
Accounts domiciled in the EU/EEA are not affected by this change and continue to be accessed via Circit Limited under our Central Bank of Ireland registration, as before.
What if my client has a UK and EU bank account with the same bank?
You, the auditor, may be required to selected two different banks from the Circit list, the European bank, and the UK bank, if your client has accounts domiciled across these regions.
How will this be reflected in our terms of service?
Before connecting an account, clients will be presented with Terms of Service that make clear which regulator applies to that specific connection:
UK-domiciled accounts are accessed by Circit UK Limited, registered with the Financial Conduct Authority (FCA) as an Account Information Service Provider. The UK Terms of Service can be found here
EU/EEA-domiciled accounts continue to be accessed by Circit Limited, registered with the Central Bank of Ireland (CBI) as an Account Information Service Provider. The EU Terms of Service can be found here
In practice, this means the Terms of Service a client sees will automatically match the jurisdiction of the account they're connecting — so a client with both a UK and an EU account will see two sets of terms, one for each entity, during the connection process.
Does this have any impact on my current commercial agreement?
No. Circit UK is a 100% subsidiary of Circit Limited. There is no impact on your commercial agreement, and all current obligations from Circit Limited will continue to be met.