Brexit is once again making headlines in the United Kingdom. As is often the case, the focus is on what London wants from its relationship with the European Union, with proposals ranging from a more ambitious "reset" in areas such as pharmaceuticals, chemicals and electric vehicles to rejoining the EU outright.
But understanding what the U.K. can realistically secure from Brussels is just as important.
The EU's different models of integration — from a customs union, such as the one with Turkey, to full access to the single market through the European Economic Area, enjoyed by Norway, Liechtenstein and Iceland — are well established.
More recently, another arrangement has been added to the list: the EU-Switzerland Bilaterals III package, a patchwork of more than 100 bilateral agreements resulting from decades of negotiations and now revised.
This agreement offers some useful lessons the U.K. could apply when reshaping its trade relations with the EU.
This article is part of the The Parliament's special policy report "The EU's trade question."
UK can learn from Switzerland
For a long time, the EU viewed Switzerland's bilateral approach with skepticism. It was seen as overly complex, creating persistent difficulties in ensuring that Bern kept pace with changes in EU law in exchange for market access.
Consequently, the new package addresses many of these concerns by introducing dynamic alignment in areas where Switzerland participates in the single market, alongside formal enforcement and dispute settlement mechanisms.
In addition, it replaces the ad hoc system for setting financial contributions with a permanent mechanism under which Switzerland will pay 350 million Swiss francs (nearly €383 million) annually to help reduce social and economic disparities across the EU.
For the EU, Brexit reinforced the need to balance access to the bloc's benefits with corresponding legal and financial obligations, ensuring that countries outside the Union could not enjoy the same advantages as member states.
The new EU-Switzerland package offers a clear indication of what the right balance looks like: Switzerland gains access to parts of the single market — including industrial goods, agriculture and food safety, electricity, air and land transport — in exchange for dynamic alignment with EU rules, regular financial contributions and the free movement of people.
This creates several challenges for EU-U.K. relations.
First, it makes clear that London would need to abandon its red line against the free movement of people if it wants a significantly deeper trade relationship with Brussels.
Such a shift would prove politically difficult at a time when public concern over immigration remains high in the U.K.
London would also need to accept a permanent financial contribution to the EU.
Both requirements remain politically unacceptable to the current British government.
Would the EU replicate it?
Furthermore, it is far from certain that the EU would want to apply the Swiss model to the U.K. Some figures, including the European Commissioner for Trade and Economic Security, Maroš Šefčovič, appear open to the idea, though they acknowledge it would take time.
Not all member states are likely to share that view and many will think carefully about whether it is in their interest to grant the U.K. access to parts of the single market for goods, while enjoying the freedom to set their own rules for British powerhouses such as AI and financial services.
At the heart of the debate is the fact that, post-Brexit, the U.K. is simultaneously a political ally and an economic competitor.
The Swiss bilateral path was never intended to serve as a model. Whether its modernized version can evolve into one remains uncertain.
First, the package must still be approved by Swiss voters in a referendum expected in 2027. Whether both the EU and U.K. will then show the flexibility needed to make such a relationship work is an entirely different question.
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