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Mirror Mirror: Can the UK Adopt the Swiss-EU Relationship Amidst Brexit?

by Patricia Zanini Graca 

In June 2016, the United Kingdom (UK) held a referendum in which its citizens voted on whether the UK should leave or remain in the European Union (EU). The result was 51.9% in favor of leaving. Since then, the Britons decided to exit from the EU, over a thousand days have passed and yet, British Prime Minister Theresa May has asked to postpone Brexit one more time until June 30, 2019. The EU is the one who holds the power to approve the UK request for an extension.

In terms of their relationship with the EU, both the UK and Switzerland have had a long relationship with the bloc. Prior to the EU, Austria, Denmark, Norway, Sweden, Portugal, Switzerland, and the UK all signed an agreement to establish the European Free Trade Association (EFTA) in 1960. Then in 1973, the UK left the EFTA to join the European system of economic integration known as the European Economic Community (EEC). During the same year the free-trade agreement between Switzerland and the EEC came into force. While the UK joined the EU, Switzerland decided on a different strategy which led Switzerland to be outside of the bloc. In 1992, the Swiss held a referendum in which they voted to decide whether Switzerland should leave or remain in EU; the Swiss voted 50.3% in favor of leaving the EU.

Today, Switzerland has a unique relationship with the EU because it is a member of the EFTA, but unlike other EFTA members such as Norway, it is not a member of the European Economic Area (EEA). In addition, Switzerland enjoys access to the EU’s single market while being under no legal obligation to adopt new EU legislation. Switzerland is also outside the EU’s customs union, but is still able to strike independent trade deals as it pleases.

The tangled Swiss-EU relationship comprises more than 120 agreements since 1973. However, one of the most important agreements, the Agreement of Free Movement of Persons (AFMP), came into force in 2002. The AFMP entitles Swiss and EU citizens under certain conditions to choose their workplace and residence freely within the territories of the contracting parties. The AFMP is pivotal because the Swiss economy is dependent on foreign workers and it gives better opportunities for Swiss nationals in the EU. Also, the AFMP leads to mutual, gradual, and controlled access to labor markets through transitional arrangements and protects employees by ensuring compliance with pay and working conditions in Switzerland.

Two of the main key points of the UK Withdrawal Agreement are the movement of UK-EU citizens and the return of a physical border between Northern Ireland and the Republic of Ireland. A major concern is that EU migration has been good for the UK, through increasing national economic performance and improving the public finances. There are roughly 3.8 million EU citizens living in the UK who need legislative protection to guarantee their rights since they are contributing to the UK economy. Thus, the UK’s new bill on immigration should take into consideration the EU immigrants who do not have an automatic right to residence and work, contrary to what happens with freedom of movement within the EU.

Today, the UK has two two immigration systems: the first, for EU citizens which allows the free movement of people within the EU area, the second, for non-EU citizens which is regulated by UK immigration law. Thus, EU citizens have the same rights as UK citizens, including the right to send their children to school, to use the National Health System, to go to university, to claim benefits, to work and move freely. The major issue on the new bill is that it grants the Home Secretary the power to decide whether settled EU citizens who arrived prior to March 29, 2019 have the same rights they do now. There is no obligation or legislative protection to guarantee that EU citizens will continue having the same rights.If the UK decides to follow Switzerland’s model, European citizens living in the UK and UK citizens living in the EU may not have their rights to live and work in their current place of residence disrupted by Brexit. Since 2002, citizens of EU member states or EFTA countries such as Iceland, Liechtenstein and Norway have the right to visit, live and work in Switzerland, although some restrictions apply for newer EU members and all EU/EFTA need a residence permit for longer stays.

Switzerland has a population of 8,48 million, of which 2.1 million are foreigners – and more than two-thirds of them are from the EU and EFTA countries. The high number of foreigners makes Switzerland a cosmopolitan migrant society. According to Fortune Magazine, Switzerland is home to some of the largest global companies. It has one of the highest concentrations of Fortune 500 companies. An influx of skilled EU immigrants has been beneficial to highly qualified Swiss nationals. Almost one in three employees in Switzerland holds a foreign passport. At the same time, the country takes pride in having boasts one of the most innovative economies in the world. The Swiss neutrality preserves the free movement of people, which is an essential part of its ties with the EU – Switzerland’s biggest trading partner and lifeblood for its export-reliant economy.

However, not all Swiss agree with it. In 2014, the Swiss adopted the popular initiative against mass immigration, led by Swiss People’s Party (SVP), the dominant national-conservative and right-wing populist political party, to curb immigration with quotas. The initiative was approved by 50.3% of voters. Although some Swiss feel like losing their jobs for EU nationals, the Swiss unemployment rate is low compared to EU countries. It is 3.5% among Swiss nationals and 7.5% among foreigners; whereas in the EU is 6.6% and in the euro zone , 8.0%. The EU has responded by playing hardball with Switzerland on the country’s attempts to limit free circulation of people across the border, by presenting a new framework agreement which would hinder Switzerland’s unique position to deal with the bloc. This Swiss-EU new framework envisages making Switzerland join the energized EU. Without the migrant labor force which contributes to vital taxes, jobs, investment, and expertise, the Swiss economy would collapse.

Though the UK has a more robust economy than Switzerland and its exports and imports with the EU are of a different magnitude, the migrant labor force has also boosted the UK’s economy in the last decades. Furthermore, the fact that Switzerland accepts freedom of movement with the EU and partakes in several other accords with the EU presents a viable alternative and could be emulated by the UK.


Patricia Zanini Graca, a second-year graduate student at Seton Hall’s School of Diplomacy and International Relations. Patricia holds an MBA in Business and Marketing. Patricia is the Executive Editor at the Journal of Diplomacy, a UN Digital Representative at the Center for UN and Global Governance Studies, an Abd El-Kader Student Fellow and the Director of International Affairs at the Graduate Diplomacy Council. She specializes in International Organizations and Global Negotiations & Conflict Management. Her interests are human rights, gender equality and corporate social responsibility.


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