(Bloomberg) -- The lasting impact of the U.K.’s vote to break with the European Union won’t be known for years, but the shift has immediate ramifications for the global technology industry. There are a few issues to be particularly mindful of.
Chaos in the global markets is not an environment that makes investors eager to buy shares in an initial public offering. Any technology startup considering an IPO will likely wait to see how the turmoil following the Brexit vote shakes out.
There has already been a dearth of listings this year and the U.K. vote will only extend the lull. The European telecommunications company Telefonica SA is said to be postponing plans to sell shares of its infrastructure unit Telxius and U.K. wireless unit O2.
Impacts have been felt elsewhere in the world, with Line Corp., Japan’s most popular messaging service, planing to delay the setting of a price range for its initial public offering as a result of the Brexit vote.
The Leave vote opens up potential headaches for anyone concerned with data protection. The U.K. will need to negotiate new data sharing arrangements with both the European Union and the U.S. Right now, the U.K.’s data protection rules are in line with the European Union’s Data Protection Directive, but that regulation is likely to be replaced with a much more stringent General Data Protection Directive by 2018.
In order to continue to move data freely between the U.K. and Europe, the U.K. will have to prove it offers equivalent levels of protection. This will require changes to U.K. law, said Jane Finlayson-Brown, a partner specializing in data protection issues at the law firm Allen & Overy.
Meanwhile, the U.S. and European Union just negotiated a new Privacy Shield Agreement to govern data transfers between the EU and the U.S. This was necessary to replace the so-called Safe Harbor Agreement, which Europe’s top court struck down last year. The U.K. will no longer be covered by Privacy Shield and so will have to negotiate its own data sharing treaty with the U.S.
Many companies, Finlayson-Brown said, may opt to shift their primary data processing centers to the EU since companies must choose an EU data protection agency as their primary data regulator to comply with the new EU rules. And, even if they don’t shift the actual processing of data to the EU they will still need to be regulated by an EU data protection agency. She said companies that might have opted to maintain the U.K. as their main data processing center for Europe will no longer have that option.
Technology companies in the U.K. may no longer benefit from the free flow of people between E.U. countries.
Alphabet Inc., Amazon.com Inc., Apple Inc., Facebook Inc. and other tech giants have built large offices in the U.K., in part as European hubs to recruit engineers and other employees from throughout the region. Young technology companies also have relied on the region’s immigration policies.
According to Tech London Advocates, an industry group for the area’s technology sector, roughly 1 in 5 London tech workers is an EU national and roughly a third are from overseas. Tech companies might consider moving their headquarters to somewhere in the EU if immigration rules become too difficult.
Sonali De Rycker, a partner at Accel Partners, a global venture capital firm with a large European portfolio, said that the ability of U.K. startups to “hire diverse talent locally” was in question following the Leave vote. She said though that for young companies, their ability to innovate and execute was more important than where they are based.
ARM Holdings Plc., the U.K.-based chipmaker whose designs are used in the vast majority of the world’s smartphones, has said that it’s watching carefully to see what sort of rules the U.K. ultimately enacts concerning visas for EU workers “as we employ approximately 200 non-U.K., EU citizens at our Cambridge headquarters.”
Financial services startups have been the crown jewel of the U.K. technology scene. Many of these business’s growth strategies counted on their ability to use regulatory approval in the U.K. to sell services throughout the EU. This ability to “passport” regulatory approval from Britain to any EU country will no longer be the case after Brexit, so U.K. fintech companies will have to get regulatory from an EU jurisdiction as well as from British regulators.
Mike Laven, chief executive officer of cloud-based payments platform Currencycloud, said ahead of the referendum vote that it was already taking steps to become regulated in another EU country as a hedge against the U.K. leaving the 28-nation bloc. Because this can be a time-consuming and expensive process, it may put U.K. fintech firms at a substantial disadvantage compared to rivals based within the EU.
“The harmonization of financial regulation is a huge, huge asset to British financial services firms,” said Tom Blomfield, co-founder of Mondo, a startup financial services company currently applying for a banking license in the U.K., in an interview just ahead of the referendum vote. BrickVest, a 10-person London-based startup that offers retail investors the ability to access commercial real estate deals, said that it will move its headquarters to either Paris or Berlin due to the Leave vote.
"Continental Europe is our key market," said Thomas Schneider, BrickVest’s chief investment officer and one of three co-founders. "We need to be in Continental Europe from a regulatory perspective."
Schneider said he and his co-founders were looking at Berlin, because it offers cheaper costs and many of BrickVest’s real estate deals are in Germany, or Paris, because France may offer an easier licensing process and regulatory framework than Germany.
Schneider said that BrickVest would likely keep a small satellite office in the U.K. to serve British and Asian investors.
U.K. No Longer a Tech Hub?
The U.K. government has invested time and money to develop a technology scene to supplement the country’s finance sector. The vote threatens the results of that effort, as companies and investors question whether the country is the global hub its leaders have tried to establish.
One major selling point for London-based tech companies is that they can sell to the 550 million consumers throughout Europe, an addressable market larger than the U.S. The Leave vote means that it is no longer clear whether the U.K. will continue to be the right place from which to access the European market. Investors may start wondering if it makes more sense to put money into other major European startup hubs.
“The uncertainty may push more money into other major hubs like Germany and Tel Aviv,” said Mark Tluszcz, the co-founder and chief executive officer of Mangrove Capital, a London venture capital firm with $750 million under management. Tluszcz said, however, that he thought London would continue to pull top tech talent from Europe and beyond because it’s “one of the hippest and most diverse cities in the world.”
Startups have already said that the uncertainty leading up to the Brexit vote was making it harder to raise money from investors. Meanwhile, promising U.K. startups including money-transferring company TransferWise and data-service DueDil have said they will expand in other E.U. countries if the U.K. decided to break away. "There’s a risk that some of these businesses will leave," said Russ Shaw, the founder of Tech London Advocates. "Things are going to be in flux for a while trying to understand what all this means."
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