After the transition period From 31 December 2020 onwards, the transition period ended, the UK is no longer treated as an EU Member State and various Brexit SIs kicked in. Essentially, the key operative parts of the Regulation (EU) 2015/848 (OJ L141/19), Recast Regulation on Insolvency [EU Recast Regulation on Insolvency] on automatic recognition fell away (see Practice Note: Brexit—impact on Recast Regulation on Insolvency), as well as EU Brussels I (recast), so while jurisdiction to open certain insolvency proceedings for foreign companies may still exist, their subsequent recognition in the other remaining EU Member States may be more problematic. However, although we lose the main operative parts of the EU Recast Regulation on Insolvency, the UK and many EU Member States have sophisticated comity rules. Additionally, EU Rome I is largely unaffected and continues to determine the law applicable to contractual and non-contractual obligations post Brexit. Various Brexit SIs kicked in on 31 December 2020, including: