From Greenland to Svalbard: Scotland’s quest for a differentiated Brexit

On 20 December 2016, the Scottish Government released its blueprint on how Scotland can remain in the European Single Market post-Brexit. From the governing SNP’s point of view, the paper can be seen as a compromise given that it does not advocate Scottish independence. Instead, it proposes that the best outcome for the UK as a whole is to remain in the European Economic Agreement following the ‘Norway model’. It recognises, however, that in the current political constellation this seems unlikely. So, it argues for the continued membership of Scotland in the European Single Market.

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Cameron’s EU reforms: political feasibility and legal implications

David Cameron, the UK’s Prime Minister, has set out his objectives for EU reforms in a speech at Chatham House on 10 November 2015 – objectives which he later clarified in a letter to the President of the European Council Donald Tusk. Cameron’s demands fall in four categories – i) safeguarding Britain’s position in the Union’s ‘variable geometry’; ii) strengthening the competitiveness of the Union’s internal market; iii) bolstering the democratic authority of the EU by strengthening the role of national parliaments in the EU’s decision-making process; and iv) ensure changes to the principles of free movement and equal treatment of Union citizens in access to welfare systems in the host state. The political feasibility and legal implications of these objectives differ quite significantly. More crucially, each of the stated objectives can be interpreted and implemented in different ways. Generally, it seems, Cameron’s success seems to depend on presenting reforms that at the same time address British domestic issues as well as strengthen the EU’s functioning.

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