Swiss–UK relations post Brexit

von René Rey (Kommentare: 0)


  • 23.06.2016      UK’s referendum on withdrawal from the EU (leave: 51.9%)
  • 19.10.2016      Adoption of ‘Mind the gap’ strategy by the Federal Council
  • 29.03.2017      Initiation by the UK of the withdrawal process from the EU under Article 50 of the Treaty on European Union (date originally set for withdrawal: 29.03.2019)
  • 17.12.2018      Signing of the air transport agreement
  • 25.01.2019      Signing of the insurance agreement and the overland transport agreement
  • 11.02.2019      Signing of the trade agreement
  • 25.02.2019      Signing of the citizens’ rights agreement
  • 10.07.2019      Signing of a provisional agreement on mutual access to the labour market and a memorandum of understanding on police cooperation
  • 31.10.2019      Signing of a provisional agreement on the coordination of social security schemes
  • 01.01.2020      UK withdrawal from the EU
  • 31.12.2020      Expected end of the transition period


Transition period and negotiations on future EU–UK relations

The withdrawal agreement received parliamentary approval from both sides in January 2020, allowing the UK to for­mally withdraw from the EU at the end of January 2020. The agreement provides, in particular, for a transition period until 31 December 2020, which may be extended by one or two years, subject to both parties’ agreement. During this transition period, the UK will remain part of the EU single market and cus­toms union (but without decision rights). The EU and the UK are also engaged in negotiations on their future relations. If they fail reach an agreement by the end of December 2020 and the transition period is not extended in time (no deal scenario), relations between the EU and the UK will be solely governed by the existing rules of international law (trade rela­tions, for example, would fall under WTO rules).


Consequences for Switzerland of Brexit

The UK was Switzerland’s sixth-largest trading partner in 2018, with a trade volume of over CHF 36 billion. In 2017, the UK was the third most important market for the export of Swiss services, while Switzerland ranked third for British direct investments.

Relations between Switzerland and the UK are largely based on the bilateral agreements between Switzer­land and the EU. The EU and Switzerland have exchanged notes formally confirming that the bilateral agree­ments between Switzerland and the EU will continue to apply during the transition period. The bilateral agreements between Switzerland and the EU will therefore continue to apply to relations between Switzerland and the UK until the end of the transition period on 31 December 2020 (subject to a possible extension).


New Switzerland–UK agreements

In order to ensure as far as possible that the existing mutual rights and obligations will continue after Brexit, Switzerland has drawn up new agreements with the UK which will come into effect when the bilateral agreements between Switzerland and the EU no longer apply to the UK. This means that the substantive provisions of the agreements between Switzerland and the EU will be retained with respect to the UK.

In relation to migration, Switzerland and the UK signed a citizens’ rights agreement on 25 Febru­ary 2019. If the free movement of persons ceases to apply to the UK, this new agreement will protect the rights of Swiss citizens living in the UK – which they acquired under the Agreement on the Free Move­ment of Persons (AFMP) – such as residency and social security rights and the recognition of profes­sional qualifications. Reciprocal conditions will apply to UK citizens in Switzerland.

UK citizens will continue to be exempt from any visa requirement once the UK leaves the EU. The UK, for its part, has given assurances that Swiss citi­zens will also remain exempt from the requirement to obtain a visa.

In the area of migration, two temporary agreements were concluded which would have applied in the event of a disorderly withdrawal from the EU (no deal). The agreements would have eased the admis­sion requirements for citizens of one country wishing to take up gainful employment in the other (agree­ment on mutual access to the labour market) and ensured that the rules on social security were main­tained (social security agreement). As the existing provisions of the Agreement on the Free Movement of Persons (FMPA) will continue to apply to relations between Switzerland and the UK for as long as the transition period lasts, the two agreements will not enter into force and will not be applied.

Source: Federal Department of Foreign Affairs FDFA, Directorate for European Affairs DEA




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