The UK and EU held their first post-Brexit summit in May 2025. Its outcome was a long list of areas – ranging from emissions trading to the mobility of young people – on which the two sides intend to cooperate more closely. But formal negotiations will be neither quick nor easy. Most of the hard work is yet to come, writes Jannike Wachowiak.
Not much will happen before the summer break. Since the summit, the two sides have done the legal work to extend the fisheries and energy chapters under the Trade and Cooperation Agreement (TCA), but the start of formal negotiations in other areas will likely have to wait until the autumn.
First, the EU machinery kicks into gear: The European Commission must propose negotiating mandates to EU Member States, which must be approved unanimously. The first negotiating mandate – on an EU–UK youth experience scheme – has already been adopted but not yet published. Further mandates are expected for the UK’s participation in the EU’s €150-billion defence investment SAFE programme, the linking of emissions trading schemes (ETS), the creation of a common area for agri-food trade and the UK’s participation in the EU internal electricity market.
As Member States have been closely involved in discussions leading up to the summit, most of these should be fairly straightforward. But mandates could still ruffle feathers in the UK if, for example, it turns out that the proposal to let EU students pay ‘home’ fees at UK universities, which the European Commission put forward last year, has been included in the final mandate.
Of course, not everything listed in the common understanding will require a mandate. This probably applies to some of the weaker commitments on touring artists (the two sides promised to ‘continue their efforts to support travel and cultural exchange’) and the mutual recognition of professional qualifications (they agreed to set up a ’dedicated dialogue’).
The hard work is yet to come
And then, turning the mandates into legally binding agreements will require finnicky technical work. The EU and UK have only agreed a rough outline of what they want to achieve – for instance closer cooperation on agri-food and emissions trading based on dynamic alignment with EU rules. But interpretations of this may differ. The EU will ask for alignment across the board, while the UK prefers a more nuanced approach, including various exemptions. The two sides will also need to settle difficult questions around the UK’s financial contributions and its ability to shape EU decision-making when EU rules change in the future.
UK and EU negotiators may also be pulling in opposite directions when it comes to the conditions of the much-vaunted youth experience scheme. And on the commitment to explore participation in Erasmus+, the UK government’s explanatory notes leave no doubt that it will drive a hard bargain: ‘the UK will only associate to Erasmus+ on significantly improved financial terms’.
Whilst the EU and UK have promised to ‘proceed swiftly’ in all areas, they might treat some as more time sensitive than others. The linking of ETS schemes would ideally be done and dusted before the EU’s Carbon Border Adjustment Mechanism (CBAM) enters into force in 2026. Otherwise, levies would apply to carbon-heavy UK exports to the EU. Whether this is possible remains to be seen, particularly as it would not be unheard of that problems with negotiations in one area undermine progress in others.
All this being said, the summit marks a new phase in UK–EU relations. It is the first time the two sides have agreed to build on the existing trade agreement. This would not have been possible without a newfound pragmatism on the UK side. In a break with the past, the government has shown that it is willing to trade off sovereignty in limited areas for improved market access.
Make Brexit boring again
Keir Starmer has defended the provisional deal against the inevitable cries of betrayal and surrender. Not only did he acknowledge the economic pain inflicted by Brexit, but he also emphasised the tangible benefits British citizens will gain from resetting relations, from lower food prices to shorter airport queues. The challenge he faces is that any benefits will only materialise months (if not years) down the line.
In the meantime, the prime minister is unlikely to beat the drum for closer relations with the EU. With lots of other pressing challenges at home and Labour preoccupied by the challenge posed by Nigel Farage’s Reform Party, the most likely scenario is one where Starmer tries to ‘make Brexit boring again’ by keeping talks with the EU out of the limelight.
But this approach is not without its challenges either. The Liberal Democrats and the Green Party welcomed the summit but have already called on Starmer to be more ambitious. And these voices might grow louder over time, particularly if economic growth continues to prove elusive and the international environment grows more volatile.
On the global stage, Keir Starmer has performed his balancing act between the UK’s relationships with the US and the EU rather well. But if President Trump were to, for example, launch a full-blown trade war against the EU or renege on his deal with the UK, many in the UK might call on Starmer to take a clearer stance.
Labour’s strategy appears to be focused on minimising any potential losses to Reform. But it also faces challenges from the left. The May 2026 local elections, in which remainer-heavy borough councils all over London will be up for grabs, will be an interesting test case.
Red lines remain on both sides
The trouble is that even if Labour wanted to go much further in its relations with the EU, there would be no obvious path for doing so, unless the party decided to drop one or more of its well-rehearsed red lines of no customs union, no single market or no freedom of movement. This is because the Brits aren’t the only one with red lines. And even after all these years, the EU remains wary of creating a partnership with the UK that could unsettle the rights and obligations agreed with other third countries.
Some like to argue that the UK could be moving towards a relationship à la Switzerland, with selective participation in the single market. The Swiss model, however, comes at a cost. The country not only pays into the EU budget, but it accepts freedom of movement. The updated agreement with Switzerland still needs to be ratified, and it is unlikely that the EU would grant favourable terms to the UK that would then unravel what was agreed with Switzerland.
Some might argue that the EU has already agreed to the principle of selective access to its market by committing to new agreements on agri-food trade and electricity. Whilst this is true, the EU sees these as in its interest, and in both cases, UK alignment with EU rules will help ease trade from Great Britain to Northern Ireland (which the EU also sees as beneficial). Other areas of UK interest, for example an agreement on conformity assessments, are not seen as in the EU’s economic interest.
For now, the two sides will be focussed on the start of negotiations this autumn. There will be limited bandwidth and willingness to add to the list of items that was agreed on 19 May 2025. That means the common understanding sets the agenda for UK–EU trade relations, at least until the next summit and possibly beyond. Unless, of course, events change the calculus on both sides.
The views and opinions in this article do not necessarily reflect those of the Heinrich-Böll-Stiftung European Union.
This article first appeared here: eu.boell.org