Current plans by the UK government and the EU provide a range of temporary mitigation measures to help ease the disruption that a no deal might cause. However, the temporary measures are scheduled to fall away at different times – creating a range of deadlines for your business to consider as part of its no deal planning over the months and years after the UK’s exit from the EU.
Use the timeline to understand some of the temporary measures which are of most importance to your business.
These timelines are based on no deal taking place on 31 October 2019. Some of the short-term measures may also be extended by the UK or the EU, which would allow more time for business to prepare, and many will be unnecessary if a deal is eventually struck.
- The UK’s temporary permissions for European haulage operators undertaking limited cabotage in the UK is scheduled to end
- The ECJ is scheduled to make a decision on whether standard contractual clauses are sufficient to protect data flows, creating the potential for EU to UK flows to become illegal.
- A review of the transitional simplified procedures that are designed to make customs processes easier will begin – paving the way for these simplifications to potentially end
- The grace period for UK companies importing chemicals to submit initial registrations of their substances comes to an end
- The deadline for UK citizens in Germany to apply for the right to permanent residency takes place
- EU citizens newly arrived in the UK will need to start applying for European Temporary Leave to Remain.
- Temporary measures by both the UK and the EU to preserve aviation connectivity are scheduled to come to an end.
- The deadline for UK citizens in France to apply for the right to permanent residency takes place
- The EU’s grace period for majority airline ownership and control requirements comes to an end.
- The EU’s temporary measures to allow UK hauliers to use their current hauliers license and ECMT permits is due to expire
- The period of time the UK has committed to remain aligned to EU sanitary and phytosanitary regulations comes to an end.
- The UK’s temporary no deal tariff schedules that remove the majority of tariffs on imports is scheduled to come to an end and be replaced
- EU permission for continued basic air connectivity between the UK and the EU is due to expire.
- The transitional period for EU qualified lawyers and auditors working in the UK to convert their qualifications is scheduled to end
- The ability for EU citizens resident in the UK to be able to continue to use the NHS as they do today is expected to expire
- The grace period for EU citizens to apply for Settled Status is scheduled to come to an end, and to be replaced by a new immigration system.
- The UK’s transition period for changing labelling on food comes to an end.
- The deadline for UK citizens in Spain and the Netherlands to apply for the right to permanent residency takes place.
- The UK will no longer automatically recognise automotive type approvals for EU vehicles
- The grace period provided by the UK for all data required to fully register chemicals will come to an end.
- The UK will need to re-open a number of rollover deals, such as South Korea and Switzerland, unless already replaced.
How the UK-EU relationship may change over time
Even if no deal does occur and no future deal is struck, there should be improvements to the UK’s relationship with the EU over time in some areas.
Unscheduled changes in the relationship between the UK and the EU are likely to occur and will also need to be managed. Some of these will increase divergence between the UK and the EU, as the two develop different regulations and move away from each other. This will increase non-tariff barriers between the UK and the EU. Others will improve and deepen the relationship between the UK and the EU. Here are some examples:
- The UK will re-join the WTO’s Government Procurement Agreement after one calendar month, restoring its access to international procurement contracts very rapidly after no deal – though at a less privileged level than it currently has when accessing procurement opportunities in the EU.
- The UK should eventually be able to strike a data adequacy agreement with the EU, allowing the flow of data between the UK and the EU to resume relatively unhindered. The quickest the EU has concluded a data adequacy agreement is 18 months
- It is anticipated that the UK will be able to resume its relationship with the EU’s research and innovation programme as a third-country participant when the new programme launches in 2021.
No deal is not an event, merely the start of a process – and ultimately will continue to create uncertainty beyond October 2019. Good contingency planning will help to ensure your business reduces the impact of that uncertainty in the coming months.
No deal preparations hub