Britain told it would have to adhere to EU rules more strictly than Norway

The UK would have to follow European Union rules more strictly than Norway, if MPs choose the Nordic model as a route out of Brexit deadlock, sources have said.

Before next week’s crucial vote on Theresa May’s Brexit deal, MPs are being urged to consider an alternative that would keep the UK in the EU single market, through membership of the European Economic Area, the 31-country zone that covers EU member states plus Norway, Iceland and Liechtenstein.

Promoted by the Conservative former minister Nick Boles, the Norway-plus option also means joining the European Free Trade Area, which also includes Switzerland.

The plan would help the UK minimise the economic impact of Brexit, but would also mean accepting EU rules on goods, services, people and capital, as well as competition and state aid.

Senior officials say the UK would have to follow the relevant parts of the EU rulebook in full and would not be allowed to delay the adoption of laws, a cause of perennial tension between Brussels and EFTA countries. Given the size and proximity of the British economy, EU member states would regard the competition risks too great, according to one EU senior source, who added: “With the UK we cannot accept such a slippage.”

The EEA agreement consists of 6,000 EU legal acts, up from 1,875 when the treaty came into force in 1994. About 500 EU laws are yet to be adopted by the four EFTA countries, including scores of banking regulations that the EU passed after the financial crisis. (Non-EEA Switzerland participates in the single market and has been accused of similar delays).

Member states have always been observant to anything that tilts the playing field against their companies, said Lotta Nymann-Lindegren, a former EU diplomat specialised in Brexit. “There is a large grey zone, where even with minor issues you can all of a sudden create a competitive advantage, so I think the balance of rights and obligations would be a very important thing.”

Setting on the path towards a Norwegian-style status does not require any change in the Brexit 585-page withdrawal treaty or the non-binding political declaration, which leaves Briain’s options open. The EU would be ready to craft new language on EEA-EFTA membership to help the UK government, if necessary.

Yet EU officials have long been sceptical about the UK choosing the Norway option, which curbs sovereignty. “Norway is the worst of all outcomes for the UK because that is Brexit in name only,” said the senior EU source.

Norway also pays more per capita into the EU budget than the UK, raising questions about “substantially smaller” contributions promised. While the EEA does not cover agriculture or fisheries, existing EU red lines are unchanged, meaning if the UK wants tariff-free access for goods it will face demands that existing rights for EU fishing fleets are maintained.

Joining the EEA also means accepting the free movement of people, the reddest of May’s red lines. Norway-plus advocates have seized on the “emergency brake“ in the EEA agreement, which allows a country to take unilateral measures in the event of “serious, economic or societal difficulty”.

Many in the EU think British MPs have misunderstood the working of the brake, which is subject to consultation with other EEA countries and could lead to fines for misuse.

“I’ve been a bit worried when I read about the marketing of this idea,” said Nymann-Lindegren, who used to participate in EU-EEA weekly meetings. While in theory the UK may be able to negotiate a new system, the current arrangement had limits, she said. “It is not designed for migration management on a regular basis, it is designed for extreme situations.”