Kirsty Hughes
In-Depth Analysis
The result of the UK’s referendum on EU membership will have significant implications for the country’s relationship with the rest of Europe and its own constitutional future, writes Kirsty Hughes. She argues that, whatever the outcome of the vote, the impact on the UK is likely to be substantial, long-term and broadly negative.
Polling Station – Council House, Birmingham, Elliott Brown, CC-BY-NC-ND-2.0
At one level, the big question for the UK’s future relationship with the European Union is a simple one: will the UK’s citizens vote to remain in or to leave the EU in the upcoming referendum? Yet whichever way the vote goes, there will be potentially critical knock-on political impacts both for the UK’s own political future and for its role and influence in the EU.
It is quite possible that England will vote differently to all three other constituent parts of the UK – Scotland, Wales and Northern Ireland. And whether England drags the other parts of the UK out of the EU in a ‘Brexit’ against their will, or whether in contrast a reluctant England is kept in by the other three, political debates will erupt as a result.
Current polls are only a rough guide, with the campaign yet to take off, but they do suggest the vote in England wavering between ‘stay’ or ‘go’, while voters in Scotland and Northern Ireland look strongly in favour of remaining in the EU and those in Wales also in favour, if less strongly so (see NatCen’s summary of recent polls).
This suggests three main likely scenarios for the outcome of the referendum – a referendum that could be held as early as next June. In the first, the UK stays in, with all four constituent parts voting to remain. In the second scenario, the UK also votes to remain but with England outvoted in its desire to leave by Scotland, Wales and Northern Ireland. The opposite occurs in the third scenario, with the English desire to leave trumping pro-EU votes in the three other parts of the UK.
While the possibility of Brexit leading to a second independence referendum in Scotland and so triggering the break-up of the UK has already been floated as one quite likely outcome of a ‘leave’ vote, this is only one of a number of likely impacts from the referendum – from a surge in English nationalism or an ever weaker and more marginalised UK staying in the EU, to a reluctant Scotland pulled out of the UK but without sufficient switch in opinion to go for a second independence referendum. The politics will not end with the EU referendum result.
Scenario One: A Clear Vote for the UK to Stay in the EU – But as a Low-Influence, Semi-Detached Member
In this scenario, all four parts of the UK vote to remain in the European Union in a clear and non-divisive result. And while the Tory Eurosceptics are unlikely to give up their cause, this will surely deal with the issue of EU membership for a long time. There will be great relief in all EU member states and in Brussels, and especially in Ireland, where the impact of Brexit would be most strongly felt of all the other member states.
Those in Scotland who hope a vote for Brexit to trigger a second independence referendum will be disappointed. But there are upsides for those supporting Scottish independence: it is much easier to envisage an independent Scotland if both Scotland and the rest of the UK are in the EU – borders, free movement, trade and even currency issues would be much harder if England was outside the EU and Scotland inside.
There is one clear negative knock-on impact of the referendum in this scenario. The deal Cameron will have negotiated, combined with the referendum result, would reinforce the UK’s current semi-detached, low-influence role in the EU. Where in the past, the UK has been a strategic and high-influence player in Europe, this role has been thrown away in the last several years (principally by Cameron but to some extent starting with Gordon Brown).
The referendum vote will not be on Cameron’s reforms but he would surely claim a majority ‘remain’ vote demonstrates support for the deal he brought home. And those reforms, such as the symbolic, but otherwise meaningless, demand for an opt-out from the goal of ‘ever closer union’, would reinforce the UK’s current role as a semi-detached member state focused only on trade and the Single Market, not a member state that is interested in the whole gamut of the EU’s policy and critical challenges – from relations with Ukraine and Russia, to the refugee crisis, terrorism, and social and employment issues.
There is nothing to indicate that after the referendum Cameron, or any other Conservative Prime Minister will attempt to rebuild the influence and clout at the EU’s top tables that they have deliberately lost over the last five years. A future Labour government or progressive coalition could rebuild that influence, but any government that took a more positive, strategic and active role in the EU may find itself challenged by those who claim the referendum ‘remain’ vote was a vote for a disengaged, opted-out Britain in Europe.
Scenario Two: The UK Votes to ‘Remain’ Despite an English Vote to ‘Leave’: Challenges Ahead for Scotland
Current polls suggest that Scotland and Northern Ireland will vote strongly to stay in the EU, with Wales positive but less strongly in favour. NatCen, in its most recent analysis, put Scotland on 64 per cent, Northern Ireland on 75 per cent and Wales on 55 per cent. If support is at these levels or higher on referendum day, the votes from these three parts of the UK would counteract an English ‘leave’ vote up to levels of 51-52 per cent of voters in England voting for Brexit.
Ironies will abound at this point. UKIP and other Eurosceptics may suddenly find themselves strong converts to a dissolution of the UK, and even unlikely proponents of an independent Scotland. Given England is the heartland of Tory Eurosceptics, and such a result will surely fuel their cause into the long term. The referendum will not, in any way, have calmed the permanent tensions over the EU in the Conservative Party. And new constitutional debates about the UK, driven by English nationalism, will spring up.
A clear vote in England against the EU (say at a level of 52 per cent voting to leave) could mean any UK government in the years after the referendum would find it hard to play a highly active, strategic role in Europe, and would face much criticism from English sceptics, including in the media, if they did. This will cause little trouble to the current Tory government but any future Labour government may find itself hamstrung. The UK as a whole will be visibly divided on Europe – both across its four constituent parts, and with the ‘remain’ vote only just having won the day.
There would also be implications for Scotland and any future push for independence after such a vote. Brussels and the EU’s 27 other member states would, for sure, be very grateful for the pro-European sentiments of Scotland, Wales and Northern Ireland keeping the UK in the EU. But there would then be a clear and ever present risk that, as and when Scotland holds a second independence referendum, this could trigger new demands in England for a second Brexit referendum.
Without Scotland in the UK, a second EU referendum could easily translate into Brexit not long after. In this scenario, the scaremongering from Brussels about how long an independent Scotland would have to wait to join the EU would surely be heard again. Brussels and others would have a new reason to hope and wish that Scotland stays as part of the UK.
Scenario Three: Brexit Goes Ahead and England Out-Votes Scotland, Wales and Northern Ireland – UK in Crisis
If England votes to leave the EU at a level of 53 per cent or more, then that would be very likely to outweigh the combined ‘remain’ votes of Scotland, Wales and Northern Ireland. This is clearly the most politically explosive scenario – one that would have major ramifications for the UK, for the EU as a whole and for particular member states, especially Ireland.
One major knock-on effect would be if Brexit triggers a second independence referendum in Scotland. In that case, Scotland could expect to hear much more positive mood music from Brussels and other member states about its case for independence and for becoming a full EU member state.
While Spain’s concerns over encouraging Catalan independence would remain, the EU as a whole does not want to see member states leave – and so being a pole of attraction for an independent Scotland would, at that moment, be seen in a much more positive light. Scotland remaining in the EU would also be seen by some as opening up a greater chance that at some point in the future England might reconsider its position and think about re-joining.
The big question for the SNP and Nicola Sturgeon will be whether and how much support for Scottish independence increases in the face of a Brexit vote. Sturgeon has made the point that she wants to see clear and sustained support for independence before holding another vote – but if opinion shifts towards independence but not to the degree she would like to see (for instance, if support goes up to 54-55 per cent not 60 per cent) she will be under considerable pressure to hold a second independence referendum.
The timing of a second independence referendum will be tricky. The UK Prime Minister (whoever it is at that point, Cameron surely having had to resign if the Brexit vote succeeds) may say Scotland should wait until the UK has negotiated its exit deal with Brussels. The SNP would need to be ready with a strong alternative strategy based on holding a rapid independence referendum ahead of Brexit talks.
Then, if Scotland votes ‘yes’ to independence, three parallel sets of talks could be held at the same time – and overlapping issues dealt with across them. The three sets of talks would involve: the rest of the UK (rUK – ie excluding Scotland) and the EU on Brexit; rUK and Scotland on dissolving the UK; and Scotland and the EU on Scotland becoming a new member state.
All of this would be highly complex. UK-EU talks on the UK’s exit from the Union would be highly likely to take several years (assuming the European Council agreed to extend the deadline set in the Lisbon Treaty of two years for such talks). But Scotland, having voted for independence, may be very reluctant to wait several years for its own new constitutional set up as an independent state to begin.
It is also possible, in the face of a UK-wide Brexit vote, that opinion does not shift much in favour of Scottish independence. If there is little shift in the opinion polls, Sturgeon would be likely to hold back on demands for a new independence referendum. Scotland – along with Wales and Northern Ireland – would be taken out of the EU against its wishes. The political atmosphere in the UK at that point would surely be toxic with divisions and recrimination across the country.
Relations with Ireland would also become very difficult with huge challenges in keeping the Common Travel Area open, if the UK stops free movement with other EU member states as a result of Brexit.
Having voted for Brexit, the UK would then start tricky and time-consuming negotiations with Brussels on leaving the EU. And at home, there would be major debates about what sort of relationship the UK should have with the EU. The Scottish government would surely demand, but not necessarily get (given its relative lack of voice and influence in the UK’s EU policies today), a strong voice in those negotiations.
One interesting possibility would arise at this point. Scotland (whether with or without Wales and Northern Ireland) could demand that a number of EU issues are devolved to the Scottish government and that it is empowered to develop closer relations with the EU than the UK government negotiates for the rest of the UK. Thus, for example, Scotland might want to negotiate a differential relationship on education, research or agriculture.
Whether this is possible, and whether Brussels would welcome it, is an open question. But in the face of Brexit, and in the case where support for independence does not increase strongly at that point, it is a possibility well worth exploring. The EU has a track record of creative solutions involving treating different parts of the same member state differently (think Cyprus, Denmark and Greenland, or the former East Germany reunifying with West Germany).
The UK’s EU Relationship and its Constitutional Future After the Vote
In the end, a vote for the UK to stay in the EU will, of course, create many fewer waves – in the UK, EU and around the world – than a vote to leave. But whichever way the vote goes, the referendum is likely to impact both on the UK’s future influence in, and strategy towards, the EU, and on its own internal politics.
If all parts of the UK vote to stay in the EU, this would reinforce the UK’s current semi-detached, low-influence role in Brussels, and make it difficult for a future, more pro-European government to change that.
If voters in Scotland, Wales and Northern Ireland keep the UK in the EU, despite an English vote to leave, this will create a major debate amongst English nationalists and will surely not lead to the Eurosceptic cause dying down. And any future Scottish vote for independence would be highly likely to trigger a demand in England for a second EU referendum.
If England votes to leave in such numbers that there is Brexit, against the wishes of Scotland, Wales and Northern Ireland, this could trigger a second independence referendum in Scotland. And Scotland may at that point find Brussels much more positive about its chance of rapidly becoming an independent member state of the EU. But if Scottish opinion polls do not shift enough towards independence, the Scottish government may instead have to look for ways to keep Scotland more integrated than England with the EU, but from the outside. Relations between England and Scotland will certainly sour dramatically at that point.
David Cameron called the EU referendum to deal with his own internal Conservative Party tensions over Europe. But whether he gets a ‘remain’ or a ‘leave’ vote, it is clear that the referendum will impact, mostly negatively, on the UK’s politics and its engagement with the EU for many years ahead.
This article was originally published on openDemocracy.
Kirsty Hughes
Friends of Europe
Dr Kirsty Hughes is Senior Fellow at Friends of Europe, Brussels and a writer and commentator on European and international politics and policy. She has worked for organisations including Chatham House, the Centre for European Policy Studies, Oxfam GB and the European Commission.
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