Many regulatory and legislative changes have been put on hold or are being slow-walked due to the global pandemic, including the transition away from LIBOR. The FCA's approach is that there likely will be continued use of LIBOR-referencing products into Q4 2020 but that all newly-issued Sterling LIBOR-referencing loan products that expire after the end of 2021 should cease by the end of Q1 2021.

While regulatory delay on the LIBOR transition is welcome (given firms have so much else to think about), firms should continue to work with advisers and counterparties as much as possible in order to be prepared.