Brexit, Devolution and Constitution, Economy and Trade, Long Reads

A Canada v Norway second vote: a way out of impasse?

Given last week’s march and the fact that crunch time is looming, it is a good time to write about potential exits from the Brexit impasse.

Specifically, I would like to discuss the merits of a second referendum which offers a simple choice between ‘Canada’ and ‘Norway’ style Brexits and does not include the option of ‘Remain’. Such a vote might be a good, though not ideal, way out of the current deadlock. I cannot claim that this is an original idea of mine. I first saw it on Twitter, yet I am afraid that I have forgotten who it was that proposed it! I think this is one of those ideas which is floating around policy circles however; perhaps it cannot be attributed to one person.

Before discussing this in more depth, it is important to define what I mean by Canadian and Norwegian style Brexits. The Canadian model entails a more distant relationship with the EU; such a model would not involve membership of the customs union and single market or freedom of movement, but does entail the conclusion of a free trade agreement. This option therefore differs from a disorderly ‘no deal’. The Norwegian model entails a closer relationship with the EU; such a model would involve membership of the single market and freedom of movement. Though Norway are not members of the customs union, thus allowing them to pursue an independent trade policy, their membership of EEA/EFTA means that their customs policy is fairly integrated with the EU. Regarding applicability to Britain, these arrangements would have to be bespoke; I therefore talk about these models quite loosely.

Here are some reflections on the merits of such a vote:

1) A major advantage of such a solution is that it would respect the result of the first referendum. The main reason why this should be done is to maintain confidence in the political system. Though it is often said that elections do not deliver once and for all results, changes to the executive are always implemented following an election; this change is then effective until the law stipulates that another election is due.

It can be argued that the June 2016 referendum was far more significant than an ordinary election. Not only did both sides agree that the result would be binding, but the campaign was more high-profile and turnout higher than an ordinary election; a series of demographics who do not normally vote also participated. Given this added significance, it would be very strange if, just as elections occasion changes in the executive, the referendum did not lead to exit from the EU. If this did not happen, one would worry that confidence in our political system would be immensely damaged, providing the far-right with unprecedented stimulus.

2) Remainers are nonetheless correct to assert that the form of Brexit was not on the ballot paper. Given this and the current impasse, it seems to me that a second vote on the shape of Brexit would be a sensible idea. The two options advocated above would nonetheless have to be agreed with European public authorities, so as to ensure that they were viable. Aside from general objections to including ‘Remain’ on the ballot paper, a two-way vote would also be appealingly simple; if ‘Remain’ were to be included on a multi-option STV ballot, there would be further questions about the democratic legitimacy of remaining.

3) In terms of the viability of the two options, the main issue would continue to be the Irish border; an agreement on this issue would have to be achieved prior to a second vote. Though the Norwegian model is not a panacea for the issue of the Irish border – Norway is not a member of the customs union – my understanding is that such a model would make resolution of the Irish border question easier; the immigration and customs policies of Norway and EU are fairly integrated. If a Canada style Brexit were pursued, the border question would continue to be problematic. This matter would have to be solved before a second vote; there is little point including options which cannot subsequently be implemented.

4) The major disadvantage of the Norway option would be subsequent inability to influence EU regulation. Norway is a member of the single market, yet has no votes in the Council of Ministers/seats in the European Parliament etc. This is not ideal for a small country such as Norway, yet would be significantly more problematic for a bigger country such as the UK. So as to address this issue, a Norwegian style option might have to include proposals for a permanent forum for UK-EU dialogue, allowing the UK to express opinions about the direction of EU regulation. This raises more questions of cake and eating.

5) Much might be made of differing implications of the two options for immigration. The Canada option would allow the UK to set an autonomous immigration policy. The Norway option would have to include freedom of movement, given the indivisibility of the freedoms of the single market. The EEA definition of freedom of movement, used by Norway, is more restrictive than the EU definition however; it permits freedom of movement of workers, rather than movement of all citizens. The 2016 referendum nonetheless did not pertain directly to immigration; more flexibility on this issue is therefore permissible.

What next?

As will have been gathered, this solution is far from ideal; both the Canada and Norway options are associated with problems. Compromises can also satisfy few, particularly in the polarized climate of today. The country nonetheless remains in a dangerous impasse, with no ideal options, and this solution might be the best of a series of bad options. As they might say in Brussels, on verra bien!

Dr Thomas Prosser is Reader in European Social Policy at Cardiff Business School.

This post represents the views of the author and neither those of the Welsh Brexit blog nor Cardiff University.


  • Hilton Marlton

    On a day that Aaron Banks is being investigated for fraudulent activity, relating to the referendum on 23rd June 2016, it would seem more appropriate for Dr Prosser to be making a proper academic argument for a free and fair democratic referendum on our continued membership of the EU and not coming up with schemes that would see us all poorer and intellectually isolated.

  • Desrt4

    In Norway, the type of government is a Unitary parliamentary constitutional monarchy. In Norway, the legislative power is vested in a Great Assembly. The head of the government is Harald V. The governmental structure of a country determines the manner in which laws are written, approved, and interpreted. Government type determines the manner in which elections are held as well as the country’s system of policing its citizens.

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