Swiss–UK relations post Brexit

Swiss and UK flags
Swiss and UK flags: the UK's withdrawal from the EU has an impact on relations with Switzerland. © FDFA

As of 1 January 2021, Switzerland's relations with the United Kingdom (UK) are governed by new bilateral agreements. Until then, Swiss-UK relations in key areas, such as trade and migration, were based on the bilateral agreements between Switzerland and the European Union. As these no longer apply to the UK as of 2021, the Federal Council has concluded new agreements based on its Mind the Gap strategy, which aims to ensure legal continuity and safeguard mutual rights and obligations. 

The 11-month Brexit transition period agreed between London and Brussels expired on 31 December 2020, at which point the UK left the single market and customs union and EU international agreements ceased to apply in relation to the UK. This means that Switzerland and the UK moved to a new stage in their relations. Although the Switzerland-EU agreements continued to apply to the UK throughout the transition period, they ceased to apply from 2021 onwards. As of 2021, the follow-up arrangements apply, among them several new Switzerland-UK agreements.

These new solutions emerged on the Swiss side from the Mind the Gap strategy adopted by the Federal Council in October 2016, a few months after the Brexit vote on 23 June of that year. The objective of the Mind the Gap strategy was to safeguard and, where possible, build on the rights and obligations applicable between Switzerland and the UK. The Federal Council set up an FDFA-led interdepartmental steering group to coordinate the strategy.

Switzerland and the UK were largely able to retain their existing legal relationship. All in all, the Federal Council negotiated seven agreements with the UK government.

Alongside these seven agreements, Switzerland and the UK have also been determining the shape of their future relations. For instance, on 30 June 2020 the two countries issued a joint statement regarding closer cooperation on financial services. Switzerland and the UK issued another statement on 21 December 2020, which sets out their intentions to explore ways to enhance cooperation on migration. The Trade Agreement also includes provisions on further discussions between both countries in order to develop and intensify their economic and trade relations.

The free movement of persons between Switzerland and the UK ceased to apply at the end of 2020, which means that access to the job market as of 1 January 2021 is governed by national legislation. In Switzerland access to the job market is regulated by the Federal Act on Foreign Nationals and Integration. The Federal Council has also introduced a separate quota for 2021, allowing 3,500 UK nationals to work in Switzerland.