Examining existing convergences between EU-UK and EU-Switzerland negotiations, with a focus on the role of the European Court of Justice, customs arrangements and the free movement of persons.

20 April 2018


Micheline Calmy-Rey, President, Switzerland (2007 and 2011); Minister Foreign Affairs, Switzerland (2003–11)
Professor Michael Ambühl, State Secretary and Head, Directorate of Political Affairs Federal Department ETH Zurich (2005-13); Professor, ETHZ Zurich
Rudolf Dietrich, Director General, Swiss Customs Office (1994-2015)
Chair: Professor Richard Whitman, Associate Fellow, Europe Programme, Chatham House


Since 1992, following Switzerland’s decision not to join the European Economic Area (EEA), Swiss-EU relations have been developing through bilateral agreements adopted by both parties.

There are now around 140 such bilateral agreements and mechanisms and this has created a specific and fragmented legal framework rather than negotiating under a robust legislative structure.

It is this ‘living agreement’, between the EU and Switzerland, which the ‘Leave’ campaign in the 2016 Brexit referendum often cited as a viable and desirable option for the UK, as opposed to an ‘off the shelf’ framework for any future relationship.

Our panellists were involved in negotiating Switzerland’s relationship with the EU following the 1992 referendum, and discuss the lessons they learned that may guide the UK government during the second stage of Brexit negotiations.

How can the UK best balance retaining national sovereignty and gaining access the EU domestic market? And even if the UK did wish to pursue a ‘Swiss model’, would such a model now be impossible to emulate particularly as the EU has made it clear that it will no longer negotiate with countries without a legislative framework?