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October 3, 2019updated 04 Oct 2019 12:37pm

UK government issues no-deal Brexit preparation checklist for tech firms

By Luke Christou

The United Kingdom’s Department for Digital, Culture, Media & Sport has published a checklist for businesses providing technology and digital services to best prepare for a no-deal Brexit.

The technology industry has continued to express uncertainty over Brexit. With the 31 October deadline approaching, it remains unclear whether the UK will leave the European Union with a deal, without one, or at all.

“Whichever way you voted, Brexit has been a huge distraction for businesses and a lot of hours have gone in to preparing for all eventualities,” James Butland, vice president of global banking at fintech firm Airwallex, previously told Verdict.

“We now need certainty from the government so that we can focus on our core mission to build the best product for our customers, globally.”

The “Preparing for no deal Brexit if you provide digital, technology and computer services” checklist

The checklist provides businesses with checks to make regarding their employees, their data, their services, and regarding importing and exporting hardware between the UK and the EU.

The checklist suggest that businesses should:


  • Check if your employees need a visa or work permit and meet any requirements for their profession to work in the country they’re going to
  • Ask your employees to check if they need to apply to the EU Settlement Scheme to continue working in the UK
  • Check what you need to do to make sure you can travel through the border of the country you are visiting


  • Check if you need to change the way you access personal data from the EU/EEA
  • Check if you need to change how you do accounting and reporting


  • Appoint a representative in the EU if you run a large UK-based online business providing digital services in the EU
  • Check if you need to change your contracts to provide licensed content outside the UK


  • Check what you need to do now to make sure you’re able to import hardware from the EU
  • Check if you need to appoint a representative in the EU, and label your goods with your EU importer’s details
  • Get an EORI [Economic Operators Registration and Identification] number that starts with GB to move your goods into or out of the EU

No-deal Brexit preparation checklist “as useful as a chocolate teapot”

The tech industry has repeatedly called for clarity on what Brexit will mean for business, from access to talent to the free transfer of data between the UK and EU.

While the advice offered is of use, the DCMS checklist fails to address these concerns.

“It fails to provide clear or pragmatic guidance on what action is actually required by businesses and where they should be prioritising their efforts,” Jamal Ahmed, a privacy consultant for Kazient Privacy Experts, told Verdict. “It was as useful as a chocolate tea-pot.”

Tech no-deal checklist isn’t “all encompassing”

Peter Galdies, managing director of data governance and privacy consultancy DQM GRC, warned businesses following the checklist to be aware that “it is not all encompassing”.

Businesses will also need to continue monitoring the situation following Brexit to ensure that it remains compliant should changes occur.

“Under EU law, should a no-deal Brexit take place the UK will become a ‘third country’ overnight – meaning we will not be bound by the GDPR’s legislation, and will be able to deviate from its existing strong standards if parliament decides on that course of action,” Galdies told Verdict.

“However, this also means that data from EU countries will not be able to flow freely into the UK, which could end up with disastrous and unpredictable consequences.”

Read more: Tech industry reacts to Brexit latest: ‘Give us certainty’