Britain will maintain continuity with EU rules during the post-Brexit transition period, three cabinet ministers have said in an open letter to businesses.

The chancellor, Philip Hammond, Brexit secretary David Davis and business secretary Greg Clark said access to EU markets would continue on current terms from March 2019 for “around two years”.

The approach was criticised by the Conservative backbencher Jacob Rees-Mogg who said it would lead to “Brexit in name only”.



Clark responded by saying the UK is “absolutely, unambiguously” leaving the EU.

In a show of unity following cabinet rifts over Brexit, the ministers said firms should not worry that they will have to operate outside the “existing structure of EU rules and regulations” during what they term an “implementation period”.

EU laws will remain “common to both parties” during the transition that will start after formal withdrawal in March 2019, so firms only have to adapt to one set of rule changes at the end of the implementation period.

The letter comes as Theresa May reportedly cancelled a scheduled speech that was due to outline her vision of the Brexit “end state”, fuelling fears the rifts in her cabinet are irreconcilable.

In an interview with the Daily Telegraph, Rees-Mogg warned the prime minister: “If the Conservative party doesn’t deliver the Brexit that the British people voted for, the Conservatives will not win the next election. The leader is important, but the party is more important. Brexit is more important than anyone other than the Queen.

“If everything is delayed for two years and then there’s high alignment, you will find that by 2022 no one will have noticed any difference from having left.”



His concerns were dismissed by Clark, who said on BBC Radio 4’s Today programme that an implementation period was needed in order for trade to continue, and that nobody wanted a “cliff edge”.

Clark said the UK was “absolutely, unambiguously” leaving the EU.

But he added: “Businesses all across the country have been very clear – large businesses, but small business as well – that we need to take the time to adjust to the new regime.”

In response, Keir Starmer, the shadow Brexit secretary, said: “The truth is that Tory infighting is now the single biggest threat to a Brexit deal that works for Britain.”

In the letter (pdf), the senior ministers said maintaining continuity of rules will require the EU and UK to “act in good faith” and reflect “the spirit of our future partnership”.

Quick guide What are Brexit options now? Four scenarios Show Hide Staying in the single market and customs union The UK could sign up to all the EU’s rules and regulations, staying in the single market – which provides free movement of goods, services and people – and the customs union, in which EU members agree tariffs on external states. Freedom of movement would continue and the UK would keep paying into the Brussels pot. We would continue to have unfettered access to EU trade, but the pledge to “take back control” of laws, borders and money would not have been fulfilled. This is an unlikely outcome and one that may be possible only by reversing the Brexit decision, after a second referendum or election. The Norway model Britain could follow Norway, which is in the single market, is subject to freedom of movement rules and pays a fee to Brussels – but is outside the customs union. That combination would tie Britain to EU regulations but allow it to sign trade deals of its own. A “Norway-minus” deal is more likely. That would see the UK leave the single market and customs union and end free movement of people. But Britain would align its rules and regulations with Brussels, hoping this would allow a greater degree of market access. The UK would still be subject to EU rules. The Canada deal A comprehensive trade deal like the one handed to Canada would help British traders, as it would lower or eliminate tariffs. But there would be little on offer for the UK services industry. It is a bad outcome for financial services. Such a deal would leave Britain free to diverge from EU rules and regulations but that in turn would lead to border checks and the rise of other “non-tariff barriers” to trade. It would leave Britain free to forge new trade deals with other nations. Many in Brussels see this as a likely outcome, based on Theresa May’s direction so far. No deal Britain leaves with no trade deal, meaning that all trade is governed by World Trade Organization rules. Tariffs would be high, queues at the border long and the Irish border issue severe. In the short term, British aircraft might be unable to fly to some European destinations. The UK would quickly need to establish bilateral agreements to deal with the consequences, but the country would be free to take whatever future direction it wishes. It may need to deregulate to attract international business – a very different future and a lot of disruption.

The ministers said the plan was to “mimic the breadth of our current arrangements, from goods to agriculture to financial services, meaning that every business, small or large, will be able to go on trading with the EU as it does today until it’s time to make any changes necessary for the future partnership”.

The UK will also work with the EU to ensure Britain is covered by more than 750 international agreements, including trade deals, signed between Brussels and countries outside the union.

EU citizens will also be free to “live and work” in the UK during the implementation period of “around two years” and have “no new barriers to taking up employment”, except having to register with the authorities.

“This will not place any new burdens on businesses during the implementation period,” they added.