Analysis of the Potential Brexit Impact on the United Kingdom and the European Union

Peter Csanyi

Stephen F. Austin State University

Abstract

The goal of this paper is to describe and analyze the ‘Brexit’ and its potential impact on the

European Union. Any discussion of a Brexit should be set against the backdrop of an increasingly

convulsive European landscape. The merits and shortcomings of the European Union should be

judged not in isolation, but through the lens of their implications upon a broader postwar

European order that Britain has helped to build and sustain for nearly seven decades. US strategic

retrenchment, Germany's economic and political pre-eminence within the EU, and Russia's

attempts to recreate a sphere of influence in Eastern Europe are likely to disrupt the European

balance. Brexit could exacerbate each of these disruptive trends – with negative ramifications for

UK national security. Conversely, by leveraging its membership of and influence within the EU,

Britain could help revitalize the transatlantic relationship, mitigate the specter of a German-

dominated EU, and check Russian revisionism in Eastern Europe.

This analysis tries to focus on the impact on the UK as well as the European Union. Even though

the analysis expects that while the biggest impact of Brexit would be on the UK, there can be

little doubt that there will also be a significant impact on the rest of the EU. The impact of Brexit

on British businesses, the UK economy and wider British interests would be severe and felt

across multiple channels. The direct impact on the rest of the EU’s economy would be also

obvious, but still less significant. However, Brexit would have a wider political impact on the

EU, both by disrupting internal political dynamics and because of the risk of political contagion if

the ‘proof of concept’ of leaving the EU encourages disintegrative forces in other member states.

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Introduction

The European Union (EU) is a unique partnership in which member states have pooled

sovereignty in certain policy areas and harmonized laws on a wide range of economic, social, and

political issues. The EU is the latest stage in a process of European integration began after World

War II, initially by six Western European countries, to promote peace, security, and economic

development. Today, the EU is composed of 28 member states, including most of the formerly

communist countries of Central and Eastern Europe.

EU members share a customs union, a single market (in which goods, people, and capital

move freely), a common trade policy, a common agricultural policy, and a common currency (the

euro) that is used by 19 member states (collectively referred to as “the Eurozone”). Twenty-two

EU members participate in the Schengen area of free movement, in which individuals may travel

without passport checks. In addition, the EU has taken steps to develop common foreign and

security policies, has sought to build common internal security measures, and remains committed

to enlargement, especially to the countries of the Western Balkans.

The EU is largely viewed as a success story and as a cornerstone of European stability and

prosperity. Currently, however, the EU faces a range of political and economic pressures,

including slow growth and persistently high unemployment in many EU countries, as well as the

rise of populist political parties, at least some of which harbor anti-EU or “euroskeptic”

sentiments (as well as anti-immigrant views). Such factors are complicating the EU’s ability to

deal with a multitude of internal and external challenges. Among the most prominent are the

refugee crisis and “Brexit”.

In voting to leave the EU, the British people have unleashed a process potentially as

complex as it is unpredictable. Because the impact of EU law was so large, and because the

British state itself had adapted its structures and procedures to cope with membership, ending

membership implies unpicking much that is embedded in the UK legal, political and

administrative systems. The implications range from the obvious reshaping of relations between

the UK and the EU, to changes in the structure of the British state, to potentially profound

alterations in the relations between the nations that make it up.

The Brexit process will test the UK’s constitutional, political and legal frameworks and

bureaucratic capacities to their limits - and possibly beyond. Not all these changes are directly

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attributable to the referendum or the EU issue. Ultimately, Brexit will be driven by politics and

the preferences of powerful political actors in both the UK and the remaining EU Member States.

That process will be profoundly shaped, however, by the legal constraints upon all sides, and the

far-reaching implications of the need to unpick such an embedded and complex relationship.

The United Kingdom’s EU Referendum and Subsequent Steps

In January 2013, David Cameron, the incumbent UK Prime Minister, promised a poll would be

held if the Conservatives were returned to power at the next general election in 2015 and voters

would be asked to choose between renegotiated membership or exiting the European Union. PM

Cameron said the referendum would be a decision on the UK's "destiny" and, if he secured a new

relationship he was happy with, he would campaign "heart and soul" to stay within the EU. He

argued that "disillusionment" with the EU had been at an all-time high and simply asking the

British people to carry on accepting a European settlement over which they had had little choice

was likely to accelerate calls for the UK to leave. However, he also believed Britain's national

interest was best served in a flexible, adaptable and open European Union and that such a

European Union was best with Britain in it.

On the other side, against the backdrop of economic unrest in the Eurozone and an

ongoing migrant crisis, UKIP (Nigel Farage) and other supporters of a possible British exit from

the EU increased over the past several years.

German and French political leaders countered by warning that the UK could not pick and

choose its membership terms while simultaneously advocating Britain should continue its

membership. Some public polls in France and Germany favored a British exit. The United States

warned against a British exit from the European Union, arguing that it would reduce the British

"voice" in the EU as well as not being in the national interest of the United States. In response to

David Cameron's January 2013 speech on the EU, several countries submitted their views on the

proposal and as to UK-EU relations. The U.S. Obama administration expressed its belief that the

United Kingdom is stronger in the European Union, and that the EU is stronger for having Britain

as a member. French President François Hollande, speaking at the European Parliament, said

there could be no à la carte option for European Union membership. Australian Foreign Minister,

Bob Carr, said Australia recognized the UK's strength and resilience and looked forward to

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seeing it continued as a leading economy and effective power (Hewitt, 2013). Strong effective

membership of the EU contributed to this.

In May 2013, the Conservative Party published a draft EU Referendum Bill and outlined

their plans for renegotiation and then an In-Out vote if returned to office in 2015. The draft Bill

stated that the referendum must be held no later than 31 December 2017.

After the success of the Conservatives in the United Kingdom general election, which

took place on 7 May 2015, PM Cameron kept his word about the EU referendum. However, at

first, Cameron went to work renegotiating the UK-EU relationship, including changes in migrant

welfare payments, financial safeguards and easier ways for Britain to block EU regulations. In

February 2016, he announced the results of those negotiations, and set June 23 as the date of the

promised referendum believing that the UK stays in the EU.

The United Kingdom voted in a referendum on 23 June 2016 to leave the European

Union. It was a result, which would have dramatic implications for the future of the global

economy, international relations and the European continent. Immediately after the results of

referendum (51.9% of Britons voted for Leave and 48.1 voted for Remain) the UK Prime

Minister, David Cameron, gave notice of his intention to resign (United Kingdom public sector

information website, 2016).

After Cameron’s resignation, the new Prime Minister, Theresa May, did not want to

trigger the Article 50 of the Treaty on European Union (Gordon & Moffatt, 2016) process before

the end of 2016 due to the need of a debate as to whether the UK Parliament needed to approve

the triggering of Article 50. The Article 50 provides for a Member State to leave the EU, either

on the basis of a negotiated withdrawal agreement or without one. The withdrawal agreement will

probably contain transitional arrangements and it, or a separate agreement, will provide for the

UK’s future relations with the EU. There is no precedent for such an agreement, but it will

probably come at the end of complex and lengthy negotiations. The latest date to trigger the

Article 50 was determined by PM Theresa May on 31 March 2017. However Britain's Supreme

Court ruled that the UK government must hold a vote in parliament before beginning the process

of leaving the European Union (The Supreme Court, 2017). This decision was a small

complication for Prime Minister Theresa May to trigger the legal mechanism by the end of

March, but the UK Parliament approved the process on time. Doing so would open the door for

EU negotiations, which are likely to last two years.

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The withdrawal agreement is likely to cover many individual rights. But if there are areas

not covered by a withdrawal agreement, or if the UK leaves without an agreement, the question is

whether British citizens and businesses in Europe would – and European citizens and businesses

in the UK – be able to rely on any ‘acquired rights’, either under EU law or general international

law. The EU Treaties say nothing about rights acquired during the currency of the EU Treaties

automatically continuing after a Member State leaves the EU. There is no explicit ‘survival

clause’ protecting acquired rights or covering the survival of claims based on EU law (Bowers &

Lang, 2016).

General international law principles of certainty, stability, non-retrospectivity and mutual

interest suggest some kind of continuing protection for individuals when the UK leaves the EU.

The 1969 Vienna Convention on the Law of Treaties (Vienna Convention on the Law of Treaties,

1969) probably protects only the rights acquired under a treaty by states, not by individuals; and

customary international law might protect some individual rights acquired under a treaty, but the

scope of these rights is not clear and might not extend to rights of residence, for example.

There are few alternatives for the UK to EU membership. The UK might seek to join the

European Free Trade Association (EFTA), remain in the European Economic Area (EEA) and

therefore continue to have access to the single market. But this would mean allowing the free

movement of people and contributing to the EU Budget. Or the UK could decide to go it alone

and negotiate bilateral agreements with the EU along the lines of the Swiss model. The UK might

decide to confirm and enhance its historic ties with other English-speaking nations in the

‘Anglosphere’. The Government has already been talking informally with the USA and Australia

about future trade relations (Merrick, 2017).

We know only one fact for sure. Almost each possible trade relationship between Great

Britain and the European Union after Brexit will be less advantageous for the Britons than

remaining in the EU. The worst scenario would be a missing trade agreement with the EU - the

British economy would be about 4.9% weaker by 2029. Of course, it would have a negative

influence on the EU’s economy as well, but it would be relatively small.

Even the so-called “soft Brexit”, what means that Britain would be a part of free market,

would not be positive economically than the EU membership. Return to the rules of World Trade

Organization would decrease the influx of direct foreign investments from the EU to Great

Britain roughly 7.8 billion dollars.

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The best option for Britain out of the EU would be only a complex, trilateral agreement on

free trade between the UK, the USA (direct investment of $3.4 billion) and the EU (direct

investment of $3.4 billion). However, this scenario is less likely.

Certainly, Brexit would also have mainly a negative influence on the US interest in

Europe. The European Union without Great Britain would be more willing to create barriers for

companies and businesses beyond the EU, what would also have an impact on the US companies

and the US economy.

Either would require prolonged negotiation followed by compromises and still impose

sizeable costs. A lack of clarity over what would replace EU membership is just one reason why

the path to Brexit-and beyond -would be long and uncertain, taking ten years or more.

Possible Brexit Effect on the Future Shape of the UK

The June 2016 referendum result in favor of ending the UK’s membership of the EU will

have direct consequences for each of its four nations, which voted differently on whether to leave

or remain. In particular, Brexit will challenge the existing arrangements for the devolution of

political power to Scotland, Wales and Northern Ireland. The UK government faces a challenge

of two unions. As it seeks to extricate itself from its union with 27 other European states, it also

faces an inter-governmental challenge within the union of the constituent parts of the UK.

In the years since it joined the European Economic Community in 1973, the UK has

embarked on a project to devolve political power to Scotland, Wales and Northern Ireland. This

has reordered legislative and policy competences away from the UK’s parliament and

government, and granted powers and responsibilities to the devolved governments and

legislatures. In this process, many competences were devolved in part because they are

predominantly legislated and enforced at the EU level. It is not clear what will happen when these

competences are repatriated from the EU and to what extent they will be given directly to the

devolved administrations.

In the negotiations over its exit from the EU, the UK government will have to contend

with the demands for a role from the governments of Scotland, Wales and Northern Ireland. Each

administration has different interests and concerns that they wish to be accommodated within the

UK’s negotiating position. And, most notably in the case of Scotland, the future relationship

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between the UK and the EU that they seek is difficult to reconcile with the current position of the

UK government.

Furthermore, as devolution has progressed the line between domestic and foreign policy

has become blurred in a wide range of areas including energy, the environment, agriculture and

trade. This expanded agenda for the UK’s overall external relations has been pursued with and

through the EU. As it embarks on ‘renationalizing’ these issues, the UK government will have to

reconcile the fact that devolution has granted many policy powers to Scotland, Wales and

Northern Ireland. Reconciling the process of Brexit with devolution will also create a spillover

challenge for the UK’s foreign policy. Prior to the referendum, the devolved administrations had

already sought to establish, to differing degrees, their own profiles in external affairs. The

outcome of the referendum has given these efforts renewed impetus. This could mean that the

UK will show a more multifaceted profile to the EU, its member states and third countries after

Brexit (Whitman, 2017).

As pointed out above, devolution was designed and implemented during the UK’s

membership of the EU. Europe also provides a discursive framework for nationality demands to

express themselves in a transnational context and for the elaboration of post-sovereign visions of

self-determination that do not involve a complete rupture with the UK. Brexit will therefore

remove an important external support system for the UK constitution.

The least constitutionally disruptive means by which the divergent policy interests of the

devolved nations could be accommodated within the current state structure would be for

Scotland, Northern Ireland and Wales to take advantage of the repatriation of competences, along

with existing powers, and to shadow EU, rather than UK policies in some fields. They might

align with European environmental policies and participate in future initiatives within a revived

social pillar using non-legislative mechanisms. Agricultural policy might be more difficult, given

the reliance on UK funding and the need to maintain a single UK market without advantaging

farmers in one part of the UK.

A step on from this is the possibility that Scotland and Northern Ireland might remain part

of the EU, at least for some purposes, while remaining within the UK. All sides are agreed that

closing the Irish border would be a serious mistake and that some accommodation will have to be

made. This could take the form of keeping the historic common travel area and some cross-

border institutions. It is difficult, however, to envisage Northern Ireland being within the Single

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Market and the rest of the UK being outside it without controls on trade in goods and services

between Northern Ireland and Great Britain. In Scotland, there has been talk of a ‘reverse

Greenland’ under which EU law would not apply in England and Wales (as it does not in

Greenland) but would apply in Scotland and Northern Ireland. However, the Greenland analogy

is hard to make, since Greenland is a sparsely populated island remote from Denmark, not the

core of the state containing 80 per cent of the population. Nor is it possible to see how Scotland

and Northern Ireland could exercise full Member State competences, including in reserved areas

(which extend to foreign and security policy). Even if this were technically possible, it would be

politically unacceptable both to the UK and the EU. There would also be all the internal market

and border issues discussed above (Political Studies Association, 2016).

The most radical option, permitting those nations which voted for remain to do so, whilst

the rest of the UK leaves, is secession from the UK. Scotland would become independent, and

perhaps either continue as a successor state to the UK, or more likely join as a new member.

Northern Ireland could retain membership through unification with the Republic. Scotland’s First

Minister has floated the option of a second independence referendum but this faces huge

difficulties. The idea of independence-in-Europe which the Scottish National Party (SNP) has

pursued for some thirty years is based on the logic that with both Scotland and the UK in the EU,

trade and border issues between the two would be unproblematic. But with Scotland in and the

UK out of the EU, there would be a hard border between the two. Polls do not suggest that

Scottish voters would be ready to abandon the UK market in order to remain within the European

one. If the UK were to negotiate access to the Single Market, however, that would make Scottish

independence more viable (Kettle, 2016). Irish unification would keep open the border between

the two parts of Ireland, but leave a hard border with the UK, which would not be acceptable to

unionist opinion. In any case, there is little prospect of a referendum on reunification succeeding.

There is no clear resolution to any of these issues but Brexit will have a big impact on

devolution. It may lead to a recentralization as the UK reconstitutes itself as a sovereign polity; or

to further decentralization with the devolution of EU competences. In either case, the process will

be difficult and controversial.

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The United Kingdom and the European Union after Brexit

More than one and a half year after the UK referendum on EU membership, there are still

few details regarding how and when the UK will leave the EU. But one thing is clear: the

remaining EU states have priorities of their own, and the UK Government will have a hard time

finding a proposal that can satisfy both its partners on the continent and its domestic audiences.

Since the UK’s referendum on 23 June, Prime Minister Theresa May has – as would be expected

– toured many European capitals to meet EU heads of governments. British representatives have

also attended several EU Council (Council of Ministers) and European Council meetings in

Brussels. Obviously, Brexit has been a major issue at these meetings. However, the tone has

hardened as the months have passed. The UK Government has failed to ease concerns over how it

wishes to pursue Brexit – in terms of both process and content. Confronted with this situation, the

message from the remaining EU members is by now remarkably cohesive: now it is up to the UK

and the EU to discuss about the terms of departure and any future arrangements. It is also clear

that whatever deal the UK seeks to get, none of the remaining members will agree to an

arrangement that looks attractive to their own euro sceptics. Brexit has thus united the EU27 to a

degree rarely seen before. It has even increased popular support for the Union in several member

states. This may be short-lived, but it has come at an important time, as EU governments seek

solutions to the numerous problems besetting the continent. These problems outweigh the

challenges of Brexit and hence take precedence when government representatives meet.

In the immediate aftermath of the referendum, all the remaining member state

governments openly voiced their regret - and several even their strong concerns - about the

British decision. German Chancellor Angela Merkel appeared visibly shaken by the outcome.

Britain has several close allies in the EU, and research has shown how a group of countries often

side with the UK when negotiating legislation and seeking political agreements. These countries -

including the Netherlands, the Scandinavian countries, and at times the Czech Republic, Poland

and Germany - will greatly miss the UK’s liberal, progressive and outspoken voice. Yet, while

several of these countries first expressed the hope that a solution would be found to keep London

‘closely involved in EU affairs’, attitudes are now quite different. The UK Government is seen as

working opportunistically with only UK interests in mind and little consideration for wider

European issues and priorities. Therefore, support for the British has declined significantly even

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amongst London’s erstwhile friends. Even Denmark, the UK’s ‘little brother’, which usually

follows closely in its footsteps, has made clear that any concessions that do not benefit

Copenhagen will simply be rejected.

This is not to suggest that all EU27 countries share the same concerns when it comes to

Brexit. Different countries and regions in the EU will be affected differently by the UK’s absence

from the table, in both economic and political terms. By now, it is also clear that negotiations will

be closely coordinated among the EU27, with a strong role for the EU institutions’ appointed

negotiators, in particular European Commission negotiator Michel Barnier and European Council

President Donald Tusk. In this way, national leaders can rely on the EU institutions to deliver

tough messages on their priorities in the negotiations without having to confront the British in

informal, bilateral meetings (Hagemann, 2016).

Coordinating a common EU position is also necessary as the continent prepares for

political uncertainty in a number of member states. The year 2017 was an election year in France,

Germany, the Netherlands and the Czech Republic. The results of these elections still can have

different influence. And in the EU institutions, the European Parliament may have to clear its

agenda after the departure of Martin Schulz, who decided to return and become an important part

of Germany’s policy. Taken together, these events may significantly alter the political landscape

on the continent relatively quickly, and everything about the UK’s relationship with its European

partners looks uncertain as a consequence.

If the UK leaves the EU the impact would depend on the new relationship between the

UK and the EU. The UK’s options are the following: The Norwegian model, involving

membership of the European Economic Area, would not give the UK the political flexibility

required to justify Brexit. By contrast, a much looser model in which the UK trades with the EU

on a most-favored nation basis would give flexibility, but seriously jeopardize trade and

investment. The most likely models are either a Swiss-style series of bilateral accords governing

access to specific sectors of the single market or a comprehensive FTA. Either would require

prolonged negotiation followed by compromises and still impose sizeable costs. A lack of clarity

over what would replace EU membership is just one reason why the path to Brexit-and beyond -

would be long and uncertain, taking ten years or more.

The impact of Brexit through the trade and investment channels would be most severe in

the UK. The rest of the EU would also feel the impact through several other channels. The EU

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would lose an influential, liberalizing member, shifting the balance of power in the European

Council. It would become harder to block illiberal measures. Moreover, there would likely be a

new regulatory dynamic with the UK outside the EU. The UK may seek to undercut the EU on

standards impacting on the business environment; but this in turn may create a healthy regulatory

competition by putting pressure on the EU from the outside to be more liberal in its policies.

There is little prospect of London being dislodged as Europe’s leading international

financial center. The existing EU regulations would make it harder for London to serve European

markets, particularly (but not only) for retail banking and euro trading. Some business would be

likely to move to Eurozone financial centers or be lost to Europe.

Brexit in economic terms would be most evident in trade policy. While the UK would

likely be free to strike new trade deals based on domestic priorities it would have less leverage

and be a lower priority than the EU for other countries. The UK would also face the huge

challenge of renegotiating the existing EU deals that would no longer apply. The EU would

likewise be a less attractive partner at a time when it is only second priority for the US and Japan

and a lower priority for many emerging countries.

It seems that the member states most exposed to Brexit will be the Netherlands, Ireland

and Cyprus. Each has very strong trade, investment and financial links with the UK and in the

cases of the Netherlands and Ireland are closely aligned in policy terms (Irwin, 2015). Among the

larger member states Germany would be affected through several channels, but perhaps most

profoundly by the loss of the UK as a counterweight to France in policy debates. France may

welcome the absence of the UK in policy debates, but like Spain has substantial direct

investments in the UK. Italy is less directly exposed to Brexit, while Poland’s interests are

concentrated on the impact Brexit would have on the EU budget and the large number of Polish

residents in the UK (as well as so many Czech and Slovak residents). All member states would,

however, regret the loss of international influence enjoyed by the EU without the UK and the

damage that Brexit would do to the esteem of the EU globally.

Conclusion

For many supporters of the European project, the EU has entered “uncharted territory,” and for

the first time in its 60-year history, they worry that at least some aspects of EU integration may

be stopped or reversed. Others contend that there is a chance that the multiple crises currently

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facing the EU could produce some beneficial EU reforms and ultimately transform the bloc into a

more effective and cohesive entity. I think there are two possible future scenarios for the EU

based on the current situation and relationships between the member states of the EU:

1. The EU will largely continue to function as it currently does, without any significant

treaty changes or decision making reforms, and find some degree of common solutions to

crises such as those posed by Greece’s economic situation and increasing migratory

pressures. The EU will continue to pursue integration and common policies where

possible, with or without the UK as a member.

2. The EU will become a two-speed entity, consisting of a strongly integrated group of

“core” countries and a group of “periphery” countries more free to pick and choose those

EU policies in which they wish to participate. Some analysts suggest that a two-speed EU

already exists in practice, with varying membership on a range of EU initiatives, such as

the Eurozone, Schengen, justice and home affairs issues, and defense policy. Others

suggest that a formal two-tier structure could undermine solidarity and create frictions

between “core” and “periphery” member states.

The impact of Brexit on British businesses, the UK economy and wider British interests

would be severe and felt across multiple channels. Both the path and the endpoint, in terms of the

new relationship between the UK and the rest of the EU, would be uncertain, compounding the

costs to the UK.

The direct impact on the rest of the EU would be also significant. The export, supply

chain, investment and policy interests of many large corporates would be adversely affected, but

perhaps the single biggest impact will be on the cost of raising finance in Europe, which is likely

to increase.

Brexit would have a wider political impact on the EU, both by disrupting internal political

dynamics and because of the risk of political contagion if the ‘proof of concept’ of leaving the

EU encourages disintegrative forces in other member states. Europe would also lose esteem and

influence around the world. Member states would be affected in different ways and to different

extents. This will most likely influence ways in which states are willing to engage and

accommodate the UK during the pre-referendum negotiation. All member states would however

feel the impact of Brexit, both politically and economically.

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