T HE SWISS are getting ready once again for a referendum that could muck up their relations with the European Union. On May 19th they will have a chance to block an EU law that is meant to protect the continent against terrorism by forcing the Swiss, along with everyone else in Europe’s Schengen free-movement zone, to tighten rules on gun use and ownership. Swiss men, most of whom do an annual stint as army reservists, may keep a weapon under their bed at home when they are not on duty. The EU ’s instruction to curb this privilege, among other things by banning people from possessing semi-automatic weapons, has enraged Swiss on the prickly right, even though their federal parliament has diluted the EU ’s edict, for instance by exempting members of shooting clubs from such strictures.

In any case, the nationalist Swiss People’s Party, the country’s largest, still jibs at the Schengen zone’s freedom of movement and rails against the European Convention on Human Rights. It argues, for instance, that migrants who commit crimes should be expelled forthwith and that asylum-seekers should be denied legal aid in pursuit of residence; the right lost referendums on those issues three years ago. But if the Swiss repeatedly use referendums in an effort to block such European laws from affecting them and propose nationwide initiatives to amend their own constitution with the same aims, they could be forced out of the convention or even out of the Schengen zone, membership of which is vital for business.

Brexiteers often cite Norway and Switzerland as shiny models for Britain to emulate once the shackles of the European Union have been shaken off. Yet the two countries, though superficially akin, differ sharply in legislation and popular attitudes to Europe. True, both are enviably prosperous and stable democracies, and both laud pragmatism in politics. Yet the Norwegians have much smoother relations with the EU , whereas the Swiss—influenced by a large minority—tend to be twitchy and awkward, even if recent referendums have generally gone against the anti- EU nationalists. Bigwigs in the Brussels bureaucracy dread the prospect that the post-Brexit British will cleave to a Swiss rather than a Norwegian model.

On the face of things, the similarities should outweigh the differences. Both countries, along with remote Iceland and tiny Liechtenstein, belong to the European Free Trade Association ( EFTA ), which grants access to the single market. Both belong to the Schengen zone: in 2005, 55% of the Swiss voted in favour of joining it. Both keep out of the customs union and have steadfastly refused to join the actual EU , mainly to preserve their own cherished sense of independence and sovereignty. Norwegians said no (by 52.2% to 47.8%) in 1994 and have not been asked again. In 1992 the Swiss rejected a bid to join the European Economic Area, which the other three EFTA members have joined, by 50.3% to 49.7%; in 2001 the Swiss voted overwhelmingly against reopening negotiations to join it. In both countries, minorities of only around a fifth still want to join the EU wholesale; a similar proportion (though it is bigger in Switzerland) want to withdraw from the web of EU arrangements they now have; and easily the largest group—well over half—in each country is satisfied with the way things are. There is not the slightest chance of either country fully joining the EU soon.

Yet the Norwegians seem much happier with their deal. True, there have been complaints about the EU forcing Norway, as part of the single market, to open up its postal services and electricity companies, among other things. And Norway’s Progress Party, like the Swiss People’s Party, balks at unlimited immigration within the EU ’s Schengen area.

But the Swiss are regarded in Brussels as a lot more awkward, for two main reasons. First, their relations with the EU are governed by a tangle of more than 100 bilateral agreements. So the EU longs to build a so-called “institutional architecture” to put the Swiss under the roof of Europe’s laws.

This is where the second hiccup, in the view of Brussels, occurs. For whenever the EU wants to bring the Swiss into line with a new law, the threat of a blocking referendum pops up. The Swiss need only 50,000 signatures (within a timeframe) to put one to the people. This unpredictability constantly creates tension. Last November the Swiss People’s Party put forward a “Swiss Law First” initiative to assert the superiority of Swiss law over European. Though it was decisively defeated (on the same day as an initiative to ban the dehorning of cows and goats was more narrowly fended off), such events make relations between Switzerland and the EU endlessly twitchy.