After Brexit, the UK could move closer to the Swiss model in terms of its relations with the EU – although this option was initially rejected. Store Politico reportedthe United Kingdom could move towards sectoral cooperation with the EU – similar to the Swiss Confederation. The new British government under Prime Minister Keir Starmer is seeking an agreement on sanitary and phytosanitary measures to facilitate trade in agricultural products and reduce bureaucratic red tape at the borders.
Charles Grant of the Centre for European Reform in London sees the long-term possibility of Britain developing a “tailor-made, unique institutional structure” that indirectly resembles the Swiss model. Unlike Norway or Iceland, which are members of the European Economic Area, Switzerland has regulated its participation in the internal market on a sector-by-sector basis, leaving out some areas such as services and mutual recognition of product standards.
During the Brexit negotiations, an à la carte Swiss model was considered taboo. But the current British government now sees things differently and is seeking similar agreements in other areas, including chemicals and the mutual recognition of professional qualifications.
The biggest hurdle, however, remains freedom of movement: unlike Switzerland, which had to accept the free movement of people, the UK rejects this, which severely limits market participation. This rejection is reminiscent of Swiss concerns about immigration, which led to a breakdown in negotiations between Bern and Brussels in 2021.
Both the UK and Switzerland are in ongoing negotiations with the EU, as EU law is constantly changing and existing agreements need to be adapted to these modifications.
