Managing differentiated disintegration: Insights from comparative federalism on post-Brexit EU–UK relations

Andrew Glencross

doi:10.1177/1369148120968516

Andrew Glencross

Open Access

https://doi.org/10.1177/1369148120968516

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Abstract

This article applies insights from comparative federalism to analyse different models for managing future EU–UK relations. The argument is that the stability of the EU–UK relationship before as well as after Brexit is best understood by examining the presence of federal safeguards. Drawing on Kelemen, four types of safeguards are identified as the means for balancing centrifugal and centripetal forces. During the United Kingdom’s European Union membership, the strong glue provided by structural and judicial safeguards was undone by the weakness of partisan and socio-cultural ones. However, each post-Brexit scenario is characterised by weaker structural and judicial safeguards. The most stable outcome is an indeterminate Brexit that limits the incentive to politicise sovereignty and identity concerns by ending free movement of people and reducing the saliency of European Union rules. Such stability is nevertheless relative in that, from a comparative perspective, federal-type safeguards were stronger when the United Kingdom was still in the European Union.

Highlights

The United Kingdom (UK) government’s decision to accept the mandate of the 2016 Brexit referendum and withdraw from the European Union (EU) left unanswered the question of how exactly to disassociate from the single market
How politically sustainable are any of the spectrum of post-Brexit options, especially knowing that the strictures of EU membership already proved too much for UK voters? this article
In the absence of such work, it is hard to say if, and why, disintegration from a starting point of high interdependence, as is the case for the United Kingdom, is more stable than the constraints of EU membership. To address this gap as it pertains to post-Brexit outcomes, the article draws on scholarship that examines the difficulties of finding political accommodation between different levels of government that share common rules and institutional structures, that is, comparative federalism

Summary

Introduction

The UK government’s decision to accept the mandate of the 2016 Brexit referendum and withdraw from the European Union (EU) left unanswered the question of how exactly to disassociate from the single market. In the absence of such work, it is hard to say if, and why, disintegration from a starting point of high interdependence, as is the case for the United Kingdom, is more stable than the constraints of EU membership To address this gap as it pertains to post-Brexit outcomes, the article draws on scholarship that examines the difficulties of finding political accommodation between different levels of government that share common rules and institutional structures, that is, comparative federalism. The United Kingdom, like all EU member states – but especially large countries with significant voting weight in the Council – was afforded strong structural safeguards to protect its interests, which it took ample advantage of Another important safeguard in federal-like systems comes in the form of judicial mechanisms to ensure that different parties observe common obligations, while preventing power grabs from the centre.

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