How long does it take to join the EU? Why the UK in 2026 isn’t Finland in 1992

Posted on 22nd October 2026 by admin

This post originally appeared on the UK in a Changing Europe website.

 

Andy Burnham’s announcement last month that he wanted to start a dialogue about the UK’s future relationship with the European Union has prompted a wave of contributions pitching the advantages of various particular models.

But, as we move into what the Prime Minister says he intends to be a careful discussion about how European policy fits into his wider vision for the UK, it seems useful to provide some more context around particular claims being made.

One such instance is the question of how long it might take the UK to once again become a full member of the EU.

For those critical of such an option, there are plenty of cases highlighting how it is no quick fix: Serbia is into its twelfth year of negotiations, North Macedonia has been an official candidate for membership since 2005 and has still not started substantive negotiations. Even in the much-heralded urgent case of Ukraine , which sped from submitting an application to join in February 2022 to opening negotiations 22 months later, there is no suggestion that these will close any time soon.

Of course, the UK is neither a relatively small West Balkan state, nor a war-torn Ukraine. Indeed, it might be argued (as it in a recent report from Best for Britain) that where there is a high level of existing policy alignment and clear political will then things can move much faster.

Finland is the poster-child of the ‘speedy’ accession. From applying in in March 1992, it took only two years and nine months to become a member state in January 1995.

This speed can be explained by a number of factors. Most obviously, Finland had spent the two years prior to its application negotiating participation in the European Economic Area (EEA), which effectively extended the EU’s single market into neighbouring countries. Given that the bulk of what the EU did at that time was linked to that domain, this left relatively little to be covering in the accession negotiations.

Second, Finland was one of the least picky accession states: as David Arter has noted, the country did not ask for any exemptions or opt-outs from EU policy, unlike its neighbour Sweden. Apart from some difficulties in translating the Common Agricultural Policy to marginal Arctic cultivation, there were minimal points of friction, further aided by the relatively small size of the Finnish economy overall, as compared to the EU’s.

Finally, Finland had come out of a fundamental change in its geopolitical situation. Having had to practise delicate non-alignment under the shadow of the Soviet Union, the collapse of communism (and much associated trade), the country had to make a conscious choice about reorientation. The lack of realistic alternatives to the EU, especially once Sweden had decided that the EEA was insufficient, helped to underpin the political choice. While it would be wrong to claim very broad and deep political consensus for membership, it was certainly still the most enthusiastic of the countries looking to join the EU immediately after the end of the Cold War.

So where does this leave the UK?

Like Finland, the UK has substantial areas of regulatory policy that still maps closely to the EU. While some divergence has occurred, the country has much less distance to close than states that have never previously been part of the EU.

However, apart from this it is hard to draw many useful parallels between the two.

Notwithstanding the changes in the geopolitical realm since the 2016 referendum, the UK has not undergone the same kind of transition that Finland did in the early 1990s; indeed, we are only now producing the start of a debate about whether Brexit arrangements still work. It is notable in this context that Burnham’s starting point was not geopolitics, but barriers to trade.

Moreover, as has been clear in recent months, the UK is unlikely to be a relatively pliant partner to the EU in any accession negotiations, but rather one with significant interests and a desire for special treatment.

British pushback on raising tariffs on Chinese EVs as a price for participation in the Made in Europe package under discussion in Brussels joins resistance to EU students paying domestic university fees as topics to be resolved ahead of the November summit. And such issues pale in comparison to the discussions that will ensue during an accession process on British participation in the Euro and the Schengen zone, as well as budgetary contributions.

And the EU itself has cooled on enlargement in general: no country that has joined this century has managed to do it in less than 7 years and 11 months, start to finish. That is partly because the states involved have had further to travel in transitioning their economics and polities to the EU’s requirements, but it is also because member states have become increasingly worried about the impacts that enlargement has on them (namely in terms of migration and financial assistance). Those are both quite marginal concerns in the UK’s case, but there is also a wider concern about how increasing membership dilutes the weight of any one member, making them less able to secure their interests: here, the arrival of a large country like the UK is liable to unsettle many of the arrangements put in place since it left.

And it is this very fact of being a re-accession that will cause perhaps the biggest difficulties. From the EU’s perspective, the UK decided barely a decade ago to leave the Union. There is understandable concern in European capitals that the current swing towards closer integration might be followed in relatively short order by a swing back to radical divergence: the fragmentation of  party politicsin the run up to the next general election make the prospect of a Reform or Conservative-led government a clear possibility. All this even before (not always correct) memories of the UK as an ‘awkward partner’ during its membership make EU politicians ask whether the costs of a UK return outweigh the benefits.

Any credible estimation of how long re-accession would take needs to be mindful of this and recognise that the chances of managing it within the life of a single parliament are very small indeed.

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A dialogue on Europe, but with whom?

Posted on 15th October 2026 by admin

We are a few weeks past Andy Burnham’s speech about wanting to re-open the question of the UK’s long-term relationship with the EU.

Since then, there has been a fair amount of (sometimes hyperventilated) comment and discussion about what this relationship might look like, usually in flavours of Why My Prior Preference Was Right Then And Right Now.

But one thing that has been missing is any more detail about what Burnham actually, specifically has in mind for this ‘dialogue’. Indeed, it’s not even clear who the dialogue might be between.

Monday’s statement to Parliament might have been that moment, as the Prime Minister dropped a bunch of international matters on the floor of the House. That neither Iranian involvement in the Fairford incident nor future UK-EU relations was felt to be serious enough to merit a statement of their own points both to a busy time in international relations and to Burnham’s standing intention to focus more on domestic matters (logically, given that these are much more immediately likely to secure votes in a general election).

But the statement was very light on details too. Other than that he will do something around the time of the 20 November summit to ‘present options’, we have no guidance on process, who’s involved, how long it will take, whether any decisions will come out of it, nor what actions will flow from any decisions that are made.

As a best guess – and it is a guess – Burnham will do some kind of high profile speech to start a form of public consultation/debate, presumably with a nominal end-point that will get captured in a reflection document. That document either gets debated in Parliament as the basis from some new mandate to negotiate or – more likely – becomes the basis of a new Labour party manifesto commitment for the next general election.

Given that Burnham was repeatedly pushing back not only on indicating a preference option but also on going across existing red lines, it’s hard to see him trying for anything more than this, certainly within this Parliament.

None of this is intrinsically wrong, but with only just over a month until the summit the absence of any articulated plan, especially one where “[a]t every stage, the British public will be the boss”, seems to confirm the extent to which this whole project was sprung on government by Burnham, leaving it running to catch up. That in turn points to a more extended process, to set up lines for the next Parliament, rather than any hurried dash to set new policy.

From a European perspective that might be the better way of doing things too. Given understandable concerns about whether this is simply another swing of the Brexit pendulum, the effort to seek out more consensual and non-partisan policy positions might better enable the exploratory talks that this development seems likely to produce. Of course, should there be a Conservative/Reform-led government, the limits to that will be all too obvious.

In the meantime, it is useful to keep watching how the plans develop and who gets to set those decisions, especially if there is a genuine commitment to popular involvement.

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Party conferences and the EU

Posted on 8th October 2026 by admin

A short post this week, partly because I’ve got other things on, more because my cunning plan to summarise where parties are on ‘Europe’ came a bit unstuck.

Either they’ve kept quiet on the matter or they’ve offered much talk. Probably only the LibDems of the national parties have both adopted a new policy objective and talked explicitly about how it fits with their wider plans. Sadly for them, that got rather overtaken by Burnham’s commitment to look at the ‘different options‘, which everyone seems to be taking as a pathway to a re-accession commitment in the next manifesto.

While Burnham’s move is the big one from the season, it shouldn’t obscure the other developments we’ve seen.

ECHR withdrawal has become a mundane part of both Reform and Conservative policy, grounded solely within the frame of controlling borders and immigration. Neither party seemed to make much of the effects of withdrawal generally, let alone its impact on UK-EU relations. As a reminder, the Trade & Cooperation Agreement provides for extensive retaliatory measures and suspensions of provisions should one party leave the Convention; a provision including in large part for just this kind of scenario.

This incidental collapsing of much of the architecture of relations is part of a wider piece by these parties to move beyond Brexit, which they now singularly fail to defend as a success. Indeed, it was telling that Kemi Badenoch’s only mention of Europe in her speech yesterday was to argue that re-opening things was a waste of time:

“Can you imagine having to go through that again? So much time lost. Arguing with ourselves, arguing with the EU, going round and round in circles, businesses not knowing whether they should invest. He [Burnham] wants to do it all again. I think that is a terrible idea.”

The absence of substantive thoughts on either process or direction of policy should Burnham actually get moving on all this does not suggest that the Conservatives will find it as easy as they might have thought beforehand.

As a final observation, the absence of anyone arguing that the status quo is working points to medium-term instability in policy. Those on the left seem to want to explore well beyond the current red lines, while the right affects to be unconcerned about causing a major argument with the EU.

What the EU itself wants does not appear to be a major concern at this stage, but the volatility that British politics continues to display is likely to reinforce more cautious voices across the Channel that worry about making any kind of deal that might come unstuck very quickly.

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“And there are different options”

Posted on 1st October 2026 by admin

Well, it feels like I picked a good time to start trying to blog more.

Andy Burnham’s speech to the Labour party conference has fired the gun on something that felt pretty unlikely just a few weeks ago: a debate about the UK’s relationship with the EU.

Given that one month ago I myself was arguing that silence reflected a likely low profile for EU affairs for Burnham, I am forced to reconsider my position, which I happily do, even if I’m not yet fully sold on how far this new process will go.

Burnham’s speech highlighted the degree to which we shouldn’t oversell the move right now. The section on the EU was pretty short and vague in its intent, coming after a much more impassioned and developed exploration of social care; even electoral reform got more of a commitment than Europe.

But Burnham did move the dial in saying that Brexit had done “more harm than good”. With that came the implication that red lines might have to change or go, something confirmed by subsequent remarks that leave all options on the table.

As someone who’s spent years saying we need to have a public debate about what the UK’s relationship with the EU should be, including the costs and benefits of different options, it’s very odd to hear an actual Prime Minister say just that, and I guess I should feel more positive than I do.

Part of my hesitancy is that there’s a big gap between saying you want a debate to see if you can find a consensus picture and actually doing that. As we know, there has been a lot of talking about what individuals would like to see happen (as last week) which largely involves ignoring inconveniences like other people having ideas (and votes) too. Like the EU itself.

On this, Burnham has not said much, although there appears to be some recognition that there’s no point in coming up with a plan that won’t fly in Brussels or national capitals.

Moreover, there is also a tendency in British discussions to date to treat ‘Europe’ as a separate box from the rest of politics. If we might learn one thing from Brexit, then it is that involvement in the system of European integration comes with extensive and deep entanglements across the full range of economic and political life, in ways that aren’t immediately apparent. To flip that on its head, any discussion of European policy will also have to consider government policy in general, since the former can only be sustainable if it is married to the latter and the conceptualisation of the UK’s development.

Here, Burnham has been less explicit and given the relative disconnect of social care or electoral reform from the EU’s remit we might wonder if there becomes a splitting off of European work to allow the other items to press on.

And finally, despite everything we’ve experienced in the past decade, we risk forgetting that most people don’t have strongly held views on European integration or British policy. Preferences are relatively shallow and liable to shift, depending on what information you give people, a point highlighted by some polling over the summer by Britain Elects. More pertinently, the ability of campaigners to reframe options in active political debates was well demonstrated by the Leave campaign in 2016, building on long experience in articulating eurosceptic arguments; something largely absent in Remain.

This is perhaps where Burnham has been least adventurous. He seems to know his own mind on much of his politics and has previously expressed a desire for much closer EU relations, but here seems determined at this stage not to prejudge a debate where a consensus view might not quite match his.

Fair enough, but in the prospective of having to defend going across red lines, up to and including rejoining, there needs to be much more development of the rhetorical lines and arguments that will convey the logic and imperative of that change.

Go back to the conference speech and the section on the EU, which I include here:

Later this year, there will be a UK-EU summit where one of the issues on the agenda will be how we best work together on immigration.

And beyond that we will work to secure gains for our industries most harmed by Brexit.

Conference, these are important concrete steps.

But they are not enough.

I say this to you and the country.

We will not give Britain the clear path we need into the rest of the century until we decide on a long-term relationship with what is still our largest market.

I cannot say to you truthfully that where we are is good enough.

Brexit has done more harm than good.

We need to restore a higher level of growth and prosperity for Britain.

So, I will take the opportunity around the summit to lay out to you, to lay out to the country, what I believe the different options are for Britain’s long-term relationship with our European partners.

And there are different options.

And I will see if we can find consensus around one which will give us clarity about our position, and the future of the continent we live in.

So is this just about ‘growth and prosperity’ and ‘markets’, or does ‘the future of the continent’ cover something more? Burnham will recall that owning the rational argument in 2016 didn’t cut it against the emotional lines that Leave advanced, but we wait to see if he has his own take to bring to the matter.

So we wait for some more flesh on the bones of this moment. Potentially, it opens up a path to major movement in British policy, even if that seems likely to be limited to manifesto commitments in the general election to break current red lines. Certainly, the initial response has been at the better end of expectations, with generally positive reactions in Labour and more muted lines from Reform and the Conservatives (partly reflecting their focus on the pension triple lock, where they think there’s more traction).

The possible unblocking of the reset negotiations to allow for a late November summit is an important contextual development here, since it is a marker of how serious Burnham is about moving forward. The uncertainty here is that university fees seems to be parked in the youth mobility deal, something that had been a big EU ask: if it has been disconnected, then that suggests the EU is also up for moving things promptly and amicably. If that turns out not to be the case, then we are back to underlining the centrality of EU preferences in all this.

In the meantime, it might be helpful to start laying the groundwork for what’s coming. The following graphics offer a summary of possible models and some key points to keep in mind as the debate starts. As ever, my interest in how we might move towards a grounded and resilient relationship that works for most people means that I’ve got to step up on providing useful and impartial support, so if you have any questions or queries then do just ask.

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Today in motivated reasoning news

Posted on 24th September 2026 by admin

It’s party conference time, so everyone’s pushing their ideas into the public domain, hoping they will get picked up by the faithful (and the media) just at the point that policy might get changed.

The IPPR have a useful report on the costs of not having mutual recognition of conformity assessment with the EU, highlighting how this might generate much more economic impact than any of the reset dossiers. Sadly, it doesn’t appear to engage with why the EU has steadfastly refused to even discuss such an agreement for the past several years (spoiler: there’s no good reason for them to do it).

But the eye has been caught much more by the latest report from the Tony Blair Institute, with a foreword from the man himself. This prompted some initial thoughts from me.

At one level, there’s quite a lot to be positive about from the work. It rightly argues (as I’ve been trying to since, well, ages) that the UK needs to develop a more positive vision of what its relationship with the EU should be, grounded in an understanding of how that fits into the country’s development and position in the world, rather than being driven by unhappiness with How Things Are.

It also is correct to note that the UK can’t avoid this, given its exposure to the EU (economically and geopolitically). If Britain gets a cough when Europe sneezes, then being involved in helping Europe not get poorly makes sense.

But these good points are lost in what follows, which reads much like Tony’s Special Wishlist of All The Things.

By becoming a progressive and dynamic place and setting a goal of rejoining within the next decade, the UK can more effectively press for new deals with the EU that serve the former’s advantage (calculated by a “Power Maximising Test” that will tell us all what the right level of cooperation is for any given area).

That in turn will also allow the UK to stop the EU doing bad things that hurt it and the UK, because everyone will see that’s the right thing.

Oh, and the EU itself will be simultaneously a much more powerful and effective global actor, speaking with one voice on all manner of things, while also being a “Europe of nation states”, i.e. one that lets each country do what it wants when it needs to.

There is minimal sense that the EU understands itself to have the dominant position in the relationship, as the larger and the less-needy party, nor of how it will see being told how to sort itself out by politicians from a country that – not that long ago – decided it wanted out of the organisation altogether.

There’s also no recognition that the EU has never, ever let itself be changed by non-members’ preferences or needs, and has repeatedly used the accession process to require massive adjustments on the part of the acceding state.

To take one obvious example, the then EEC developed its Common Fisheries Policy in the early 1970s precisely because several new states with large fishing waters wanted to join and the existing members wanted to embed their preferences about access and management before the new lot got a say. Just like the new EU made choices about institutional arrangements and funding for agriculture and regional development before admitting Central and East European states in the 2000s: if only I could remember the name of the guy in charge in the UK back then.

I find it very hard not to lay this at the feet of Blair himself, given how closely this all reads to his previously stated views on the matter. The helpful sections on specific domains of cooperation get lost in the over-extrapolation the report authors are asked to make, for example.

Given that the initial response to the report has been generally as bad as might be expected, it’s tempting just to write this off as Late Stage Blairism and move on.

But again, the diagnosis of the failings of the current (and historic) British approach to European policy still stands up, as does the need to start building an alternative grounded in a positive mission and set of objectives that tie into the country’s wider development.

I don’t think bathwater can be either stupid or ridiculous, but there is still a baby to be saved in all this, and whether that’s done will be a much better marker of whether the UK has got beyond Brexit than anything else in all this.

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Will this do?

Posted on 10th September 2026 by admin

I’ve been spending the week at the UACES conference in Prague, talking about lots of things to do with European Studies. However, one the things that didn’t come up very much was UK-EU relations. It’s almost as if most people don’t have it on their minds.

The moment it did come up was during the panel I took part in on the post-Brexit UK, where I talked about the instability of the relationship with the EU, something I’ll be returning to presently. My basic argument was that whatever happens, there isn’t a resilient foundation on which to rest and from which to act.

One question that did come up was whether the current relationship – low-key and benign, if unexciting – wasn’t in fact serviceable enough for our needs. After all, neither side seem that bothered about either a return to the fun times of the Brexit years or starting up a journey to re-accession. London and Brussels have got back in the habit of talking to, and listening to, each other, so can we not just assume that we can work it out as we go? Indeed, in a purely practical sense, if the relationship is as it is, does it not just to suffice, since we’ve not got another one to use instead?

My response to this fits my usual diagnosis of the failings of UK-EU relations, namely that an absence of clear strategic objectives on either side of the relationship mean that the dominant mode is a mix of neglect and bursts of crisis management. Put differently, the absence of obvious problems doesn’t mean that everything’s fine.

For a recent example, consider the mini-fuss over marmalade labelling earlier this year.

As part of the (generally pretty smooth) negotiations on an SPS agreement, DEFRA released a list of EU legislation that UK businesses would have to comply with once the deal is done; a rare example of useful forward planning.

That list got almost no media interest at the time, but some weeks later a story dropped on GB News about how the deal would mean that henceforth marmalade would have to be labelled with which fruit it was made of, and this would be a terrible imposition on already hard-done-by companies.

That almost all marmalade currently on sale in the UK already has such labelling was no barrier to a little (but still much larger than the previous) pile of media pieces appearing. Bendy bananas redux, if you will.

In short, the level of public, media and political interest is low, leaving everyone exposed to silly season pieces (and ill-intentioned actors, should they feel so inclined).

A more serious version of this appeared just as I was putting this piece together.

Politico reported that November’s summit won’t see agreement on ‘Burnham’s big new Brexit deal’, which as readers of this blog will know shouldn’t be news, since Burnham has no deal, big, new or otherwise.

That anyone, including the reporter who definitely knows better, should think that this was the case points to the non-management of expectations by either side and the substantial risk of relations entering into vicious circles of briefings and counter-briefings.

In short, the absence of strategic visions for the relationship in either London or Brussels means that there is no master narrative for politicians to cleave to and to smooth out the small bumps in the road.

As much as technical relations seem to be pretty functional, even these evidently rely on a cadre of people who have built up enough experience of working together out through the original Brexit negotiations, but who are liable to be churned by their respective employers with no robust mechanisms for preserving institutional memory.

None of these issues should be a surprise to anyone, since they have been evident for a long time, and indeed much flagged by the small number of people still focused on the matter. But the concern has to be that the current model of getting by will not have the resilience to cope with the next crisis, whatever that might be.

 

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Not even a new ‘reset’: The minimalist Burnham agenda on the EU?

Posted on 3rd September 2026 by admin

The arrival of the seventh Prime Minister in Number 10 since the 2016 referendum is an opportunity to try once again to get to grips with British European policy.

In practice, this is not a problem of wrestling Lots of Things, but instead more about trying to work out whether the absence of visible activity is a function of a very tight ship, or of a lack of activity.

Undoubtedly, negotiations on the May 2025 reset agenda in the Common Understanding has progressed well, to the point that several dossiers are largely wrapped up: SPS and ETS are the two big ones. Internal Energy Market talks finally got underway in the early summer too, the last big element to get going.

At the same time, once it became clear that Keir Starmer was stepping down, the EU decided to pause everything, there being little point in making deals with a departing leadership. Moreover, the arrival of a new PM might also offer new opportunities for the EU to secure more concessions, especially if Andy Burnham was really that much more pro-cooperation and wanted to get a quick win.

The evidence of the first couple of months of Burnham suggests that this has not been the case. Indeed, as the tracker below (mildly sarcastically) suggests, Burnham’s time in power has been marked by talking about pretty much anything apart from EU policy.

The ‘regular’ EU-UK summit heralded by the Common Understanding, and already rather uncertain by the time of the May anniversary of the first one, has only been pushed back since, with Burnham’s recent talk of November feeling more aspirational that definite. This is not a government in a rush to press forward on things, despite Burnham’s repeated invocations of the damage of Brexit to the economy.

From what little he has said, the impression is very much one of continuity-Starmer: use the reset process to secure some wins, plus avoid the worst effects of the continual activity of the EU to protect and promote its interests. The language about ‘Made in Europe’ reflects another common thread to Starmer, once the UK had determined the potential impacts on high-profile sectors of the economy and the possible leverage of working together in Europe in the face of – how to put it? – debatable international relations.

However, all of this has been very much off-camera, without much grandstanding by either side, neither of whom really feel any value in kicking up a fuss. Even the failure of SAFE talks was managed away without too much hand-wringing and with efforts to find other ways of building defence procurement cooperation.

But there has been one exception.

Youth mobility has become the poster-child of the reset, and the one with the most conspicuous disagreements.

As a reminder, the two sides have always had different positions with regard to the fundamentals of any scheme, grounded in its purpose, scale and operationalisation.

Since the 2025 summit, those gaps (on caps on numbers, university fees and permitted activities) have not definitively closed down. Instead, there has been a steady drip-feed of briefings by both sides to try to signal intent and (less often) offer possible landing grounds.

The following is a list of all Financial Times stories that include such briefings, the paper being a convenient shared space for negotiators:

  • 7 November 2025. ‘EU officials’ flag the need for the scheme to be drawn up as a binding legal instrument, rather than the memoranda of understanding the UK has with other third countries
  • 5 December. A leaked EU ‘draft text’ has no cap on numbers, and gives EU students access to UK university fees
  • 15 March 2026. ‘UK officials’ offer to give way of fees, in return for a cap and other concessions
  • 5 June. ‘UK officials’ reiterate their offer on fees
  • 3 July. The ‘Commission’ says the proposed cap is too low, EU nationals need to be exempt from the NHS surcharge and have access to UK fees
  • 13 July. ‘EU diplomats’ say the cap offered by the UK is a ‘non-starter’ and repeat points on the surcharge and fees
  • 18 August. ‘EU diplomats’ again say the cap offered is too low, but might consider something in the ‘low 100ks’, and say fees is ‘vital’
  • 23 August. A leaked UK negotiating brief from ‘UK officials’ says Starmer was willing to concede on fees and up to 100k on the cap, in return for access to Made in Europe or steel tariffs

This procession suggests a number of points that speak to the wider relationship.

Firstly, the UK has moved further than the EU on these points. We might reasonably assume that the EU will get domestic fees, but without any evident quid pro quo on caps or other dossiers. Indeed, when such cross-linkage has been mentioned by the UK, the reply from the EU has been very dismissive. This reflects the underlying asymmetry in the relationship: the UK needs this more than the EU, and the EU knows this.

Secondly, this is as much evidence as we have that Burnham is not going to stray very far at all from Starmer’s positions: The PM was talking again about Made in Europe in his first PMQs this week. Whether that helps or hinders progress on negotiations remains to be seen, but the sense that Brussels was ultimately underwhelmed by Starmer’s translation of rhetoric to action does not look set to be challenged by Burnham any time soon.

Finally, it points to the perils of low-stakes negotiating. None of the items on the table will be of notable macro-economic significance for either side, but instead act as markers of good intent and willingness to try to keep the wheels spinning on the minimal architecture of the Trade & Cooperation Agreement’s free trade area. Part of this might be the anxiety over who will be in power in the UK following the next general election, but more of it is that neither side see their relationship as either particularly important or in need of urgent attention. With plenty of other things to be getting on with, this is something that lacks any strong sense of pressure to wrap things up.

Of course, it’s still early days, but if the last seven PMs have taught us anything, then it’s that their revealed preferences on EU policy are pretty clear, pretty quickly.

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The boundless mystery of Assimilated EU Law?

Posted on 30th January 2026 by admin

This piece was originally published on the UK in a Changing Europe site.

It’s something of a truism to say that Brexit is a process, not an event, but nowhere is this more evident than in the UK’s continuing difficulties in managing the pieces of legislation it adopted during its time as a member state of the European Union (EU).

As we close in on a decade since the 2016 referendum, it is apparent that there is still no final and definitive list of that legislation, nor clarity about what should be done with it all. With multiple negotiations in train on renewed cooperation between the UK and the EU, that will raise increasing problems for both sides.

Following withdrawal, the then-Conservative government largely turned its back on things European; partly because of the Covid-19 pandemic and partly because of the intense discomfort the issue had wrecked within the party over the previous decade. But one area that continued to pop its head up was Retained EU Law (REUL) – assorted Statutory Instruments, primary and secondary EU legislation, case law and more which the UK adopted as a member state, and copied over as ‘assimilated’ UK law during the Brexit process.

Business Secretary, Jacob Rees-Mogg, introduced legislation in September 2022 which would see all REUL expire by default at the end of 2023 under a ‘sunset clause’, except in cases where ministers actively chose to retain or reform specific pieces. That legislation, which was to become the Retained EU Law (Revocation and Reform) Act, was intended to mark a definitive break with REUL and a restoration of British sovereignty.

However, it very quickly became apparent that there was no clear record on what that might cover, which made it impossible to know whether it served any useful function or whether revocation might cause unanticipated consequences for either domestic or international obligations. With much push-back from legal scholars, businesses and other groups, as well as backbench rebellions, the final Act took a much more limited approach, abandoning the sunset clause and instead revoking only 600 items of REUL, while instigating a process for identification and review of everything else.

This process centres on a database – the REUL dashboard – which details every known item of REUL and case of reform. It has just had its regular six-monthly update, to list some 6,925 items, alongside regular reports to Parliament on progress.

The latest update is the eight substantive revision of the database from its original 2,417 items in January 2023 and marks approximately two years since the last step-change in the overall picture. Back in early 2024, over 1,700 new items were added, following the completion of a new scoping exercise across Whitehall.

Since that point, a further 168 items have joined the list, including 14 in the most recent period. This discovery includes EU decisions similar to those that have been on the Dashboard for years, and domestic legislation nearly 30 years old, highlighting the difficulty of ensuring a comprehensive coverage.

But such top line figures, which are the lead indicator on the Dashboard, mask a second kind of problem; namely that the data isn’t as robust as you might expect, or as is needed for this entire exercise to have meaning.

The database still contains several items that are there as queries as to their possible inclusion. Such cases have occurred before – for instance the removal of initial entries about the effect of several articles of the Treaty on the Functioning of the EU.

There are also instances where multiple references to specific provisions of an item have been rolled into a single entry, as with the Social Security Contributions and Benefits Act 1992, which started as four separate elements.

However, more common has been a one-off entry that appears to be within scope of the REUL Act, but then seems to disappear. To pick one example, the January 2023 list mentions Commission Delegated Regulation (EU) 2018/631, which appears to have been revoked in 2020, but then disappears from the database entirely. While this might be understandable as something pre-dating the exercise, it is noticeable that the previous item in the database, Commission Delegated Regulation (EU) 2018/63, was similarly repealed in 2023, but still remains present.

Different again is the Sexual Offences Act 2003. The January 2023 entry clearly indicates its role in implementing an EU Council Decision that was subsequently listed in the database, but which makes no reference back to the Act. While these might be treated as a package, the lack of complete cross-linkage makes it very hard to know what item has what status.

In total, while there are 6,925 entries in the current Dashboard, it is possible to identify approximately 7,500 unique entries across the period since the first release. Some 600 items that appeared at some point in the past (often more than once) are absent from the Dashboard today.

Such inconsistencies are a function of the complexity of the UK’s membership of the EU. Some 40 years of incorporating a large volume of legislation – often through secondary instruments – with no immediate need to keep comprehensive and exhaustive records has left an almost impossible task for those in the Department of Business and Trade who run the Dashboard.

However, given that the programme of reviewing Assimilated EU Law appears continues under the Labour government, with 22 amendments and 19 repeals in the last six months, the need for clear, consistent and accessible data remains as high as ever.

At the same time, the demand on resources within the civil service to conduct such reviews also represents an opportunity cost, especially at a time when the government is embarking on multiple negotiations to pull the UK closer towards the EU in legislation-rich topics such as sanitary and phytosanitary standards and emissions trading.

Absent a clear strategic objective, there is a risk that officials spend time reviewing, amending or repealing REUL which they will soon have to be reinstate or amend once again: from decisions about SPS processes to regulations verification of emissions data.

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New year, same old UK-EU relations?

Posted on 7th January 2026 by admin

I notice it’s been some six months since my last post here, which reflects on both the new pace of UK-EU relations and the lack of anything useful to add to the debate.

I did bestir myself to write about the return of finance-based framing back in November, as various people noticed this was a thing, but even that was a very brief matter (albeit one we might return to).

Even the recent number of press stories launched by Labour about the new for a closer relationship currently lack any great depth: the items that are being mentioned relate to stuff already on the reset agenda, which have themselves moved at a glacial pace. The failure of SAFE negotiations in November was undoubtedly a set-back and one that helped to move up the ERASMUS+ decision some weeks later, but this has deflected attention from the lack of quick movement elsewhere. Even the Spain-UK treaty on Gibraltar, agreed last June, is still to be put through ratification.

At best, this suggests that things might be moving forward, rather than are demonstrably doing so. Even if we make allowances for the likely cross-linkage of ETS, SPS and Youth Mobility, there risks being little to show come the next EU-UK summit, whose date is still to be fixed.

Ultimately, this reflects on the lack of urgency for either side. The EU has many other more pressing things to attend to right now, while British policy is caught up in the general funk about the government’s central strategic purpose. Moreover, none of the reset elements will actually make a huge difference to those involved, beyond helping to remove some points of friction and to rebuild trust.

However, with Labour languishing in the polls, the EU might be forgiven for wondering whether it’s worth moving now on more relations, when a new British government might come along a tear those apart in three years’ time: witness the flourishing adoption of ECHR withdrawal on the right that continues to contain no concern about the impact on the TCA/WA.

This all said, it’s good not to be too downbeat about things. The rhetoric remains positive, negotiations do continue and British public opinion is still relatively benign on closer links.

As such, I’m going to try to be more active this year as we move through the reset, looking both at the specific elements and the wider relationship. As ever, I’m always very happy to produce graphics on particular things: just contact me and I’ll be on it.

In the meantime, here are some updates of the main trackers on WA/TCA meetings and the progress on the Strategic Partnership. As always, you can follow the links to the PDFs with clickable links to source documents.

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Tracking the UK-EU reset

Posted on 5th June 2025 by admin

Following the EU-UK summit last month, I’ve finally got my ducks in a row on trying to track the substance of what follows.

You’ll recall that apart from the Security & Defence Partnership, there was not a single definitive legal instrument. Instead, there was lots of language about ‘working towards’ things or ‘exploring possibilities’: all very nice, but not really enough in an era of questions about the depth of international commitments.

Hence the tracker. As I’ve noted in my Bluesky thread on this, I’m only tracking those elements that seem to produce a formal agreement between the parties: potentially the list could grow, but let’s wait and see.

Rob Francis has written that Commission mandates for SPS, ETS linkage and Youth Experience aren’t coming until the autumn of this year, so formal negotiations seem unlikely until the back end of 2025. Given that each of these could throw up a bunch of issues (such as how much the UK is prepared to accept EU rules, and how much this is going to cost in contributions), reaching an agreement on any of these by the time of next spring’s summit looks hopeful.

Hence the tracker covers the entire lifetime of this Parliament.

Of course, if polls continue to be as unclear as now, the shadow of a non-Labour government is liable to cast a shadow on any negotiations from about 2027 onwards (given the time it’ll take to conclude, ratify and implement any individual deals), so this is the best opportunity for both sides to nail things down and minimise the chance of new administrations making bold choices.

As for the rest of the list, I’ve seen nothing to indicate timelines. Even if most of it is highly technical, it’ll still need work and political attention, something that’s been in short supply so far.

So the big question is whether long-term incentives will outweigh short-term distraction.

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