Parliament’s TCA implementation assessment is broadly positive on goods but candid about the stalling of financial services equivalence, the risks around data adequacy, and the gap between what the agreement promised and what the Partnership Council has been able to deliver.
Parliament published its own-initiative assessment of the Trade and Cooperation Agreement’s implementation at the November 2025 plenary, five years after the TCA entered into provisional application. The assessment covers goods trade, fisheries, financial services, data adequacy, and the functioning of the Partnership Council and its specialised committees. The overall finding is that the TCA’s basic architecture is working but that the agreement’s potential in services, and in financial services in particular, has not been realised, and that ongoing regulatory divergence in several sectors is creating friction that was not present at the TCA’s entry into force.
On goods, Parliament notes broadly functional trade flows but sector-specific mutual recognition obstacles in areas including medical devices, professional qualifications, and agri-food safety certification. On fisheries, the annual quota negotiations have produced agreements each year but have remained more contentious than either side anticipated, and the TCA’s 2026 fisheries review is expected to be a significant test of the relationship’s durability. On financial services, no equivalence determinations have been made and no structured financial services dialogue has been formally established, despite both sides having expressed interest. Parliament calls for a dedicated financial services working group under the Partnership Council.
Data adequacy is the area of greatest legal risk in Parliament’s assessment. The UK’s GDPR adequacy decision, which has been reviewed and extended, is subject to periodic reassessment and could be challenged if UK data protection law diverges substantially from the EU framework. Parliament’s resolution flags the UK’s proposed reforms to its domestic data protection legislation as a potential adequacy risk and calls on the Commission to publish clear criteria for what level of divergence would trigger a reassessment. The broader message is that the TCA is underperforming its structural potential, and that closing that gap requires both sides to invest more actively in the institutional mechanisms the agreement created.
