The UK’s withdrawal from the EU (Brexit)

The United Kingdom is an important economic partner for Switzerland. At present, relations between Switzerland and the United Kingdom are predominantly governed by the bilateral agreements with the European Union (EU), which will cease to apply to the United Kingdom after it leaves the EU. The trade agreement signed on 11 February 2019 in Bern ensures the continuation of the economic and commercial rights and obligations between Switzerland and the United Kingdom arising from the agreements between Switzerland and the EU. It lays the foundations for future economic and trade relations between Switzerland and the United Kingdom, both in the event of a ‘disorderly Brexit’ (‘no-deal’) and in the event of an orderly withdrawal (‘deal’).

The withdrawal agreement negotiated between the United Kingdom and the EU envisages a transition period set to run from the day the United Kingdom exits the EU until at least 31 December 2020 (‘deal scenario’). During this period, the United Kingdom will continue to be part of the single market and the customs union. Under this scenario, the existing terms of the Swiss-EU bilateral agreements will continue to apply between Switzerland and the United Kingdom, with no changes to the current status quo. In this case, the trade agreement would enter into force after the end of the transition period.

The withdrawal agreement between the UK and the EU has not yet been ratified. It may yet be that there is no transition period and that the UK leaves the EU without a deal. In the event of no deal, the trade agreement between Switzerland and the United Kingdom will be applied provisionally from the day the United Kingdom leaves the EU.

The trade agreement replicates the vast majority of the trade  that apply under the bilateral agreements between Switzerland and the EU: the Free Trade Agreement, the Agreement on Public Procurement, the Agreement on the Fight against Fraud, the Agreement on Mutual Recognition in relation to Conformity Assessment, the Agricultural Agreement and the Agreement on Customs Facilitation and Security. Some of these agreements between Switzerland and the EU focus (to varying extents) on the harmonisation or recognition of equivalence of rules between Switzerland and the EU (2009 Agreement on Customs Facilitation and Security, certain sections of the Agricultural Agreement including the ‘Veterinary Agreement’ Annex, and certain sections of the Agreement on Mutual Recognition in relation to Conformity Assessment) and so cannot be fully replicated at this stage.

The implications for businesses of the UK’s withdrawal from the EU are explained in detail in the following document: Economic relations between Switzerland and the United Kingdom after Brexit (as of  October 2019) (PDF, 227 kB, 31.10.2019).

Under its Mind the Gap strategy, Switzerland also has agreements with the UK on air traffic, insurance, transport and citizens’ rights. There is also a temporary agreement between the two countries to safeguard access to their respective labour markets. More information can be found here:

Switzerland–UK relations post Brexit.

Texts of the agreements signed between Switzerland and the United Kingdom on 11 February 2019

Text of the Memorandum of Understanding signed between the SECO and the Department for International Trade

Last modification 31.10.2019

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