British people currently have extensive rights to live, work, and trade freely with the EU.

But at least some of these rights will definitely be lost after Brexit.

Theresa May is under pressure to opt for a softer form of Brexit to preserve as many of these rights as possible.

Here are some possible Brexit models and how they will affect the rights of UK citizens.



LONDON — With Brexit day fast approaching, many EU citizens living in the UK remain deeply uncertain about their future status in the UK.

Last year, Business Insider listed the rights EU citizens based in the UK were set to lose after Brexit under proposals then being considered by the government. These included the right to bring family members to the UK, and the right to protection from European courts.

However, much less attention has so far been given to the rights that British citizens themselves are set to lose after Brexit.

The Brussels-based non-profit group, the European Citizen Action Service, has put together a list of rights UK citizens will lose under the most discussed Brexit models, compared to their rights as EU citizens.

Here's a handy graphic of the how the different models will affect UK citizens, pulled from their latest report.

The above models — Norway, Canada, Switzerland and Turkey — are based on existing relationships the EU has with third countries, and the group accepts that "other kinds of arrangements" are possible, depending on how Brexit talks pan out.

However, Michel Barnier, the EU's chief negotiator, has warned that the UK's red lines of leaving the single market, customs union and European Court of Justice mean the future relationship will likely be very similar to the Canada option, visualised above.

So how many EU rights would a British person keep in the Canada option? And how does that compare to the Norway model? Here are Brexit models ranked by how they'd impact the rights Brits enjoy as EU citizens, the first being the least impactful.

Norway option

Calls for May to accept a Norway-style Brexit — in which Britain would remain in the single market via the European Economic Area — have gained momentum in recent weeks, having previously been ruled out by the prime minister.

In April, the parliamentary Brexit committee advised May to adopt the Norway-model as her Brexit fallback option. More recently, MP George Freeman — who used to head May's policy unit — said it's "surely time to start looking"at it. The House of Commons is set to vote on whether the government should aim for a Norway-style Brexit next month.

As well as being the least economically damaging of the Brexit models, a Norway-style Brexit would preserve the most existing rights. The only key right lost would be that of British citizens to participate in EU Parliament elections, as Britain would no longer be an EU member state. Under a Norway-style Brexit, Brits would retain the right to travel and work freely around the EU, as EEA countries follow the four freedoms of the single market. Brits would also keep all of their rights relating to social security and consumer protections.

Switzerland option

Another option for Britain is a Swiss-style Brexit. Switzerland is about as close as you can get to the European single market without being a fully-fledged member. It has agreed over 120 bilateral agreements with the EU over the years, covering a wide range of sectors.

In terms of citizens rights, the Swiss model would be the least impactful after the Norway-model, with the rights of British people to travel freely across the EU preserved. However, British people would see their right to move to an EU member state for professional purposes, either permanently or temporarily, significantly watered down. Brits would also only be given limited access to the consumer rights they currently enjoy as EU citizens.

Turkey option

Britain's Prime Minister Theresa May shakes hands with Turkish President Tayyip Erdogan after their meeting at the Presidential Palace in Ankara, Turkey, January 28, 2017. REUTERS/Umit Bektas

Next up we have Turkey. Turkey has an association agreement with the EU based on cooperation in some areas, including a partial customs union which industry leaders have urged May to replicate. However, Turkey's relationship with the EU is a distant one, which is why Brits would retain none of their rights as EU citizens in full under this sort of model. This includes their right to enter EU countries with the ease with which they do now, meaning longer queues at airports, train stations and ports for Brits wanting to reach the continent.

Canada option

A Canada-style deal would be a far cry from the close relationship soft Brexit campaigners want to see. While it slashes some tariffs, it would not keep Britain close enough to the single market for the frictionless trade that May has set out to achieve. MPs have previously warned the prime minister that Canada's deal with the EU does not include services, while 80% of the UK's economy is based on services. Brexit Secretary David Davis has sought to calm these fears by suggesting he would help negotiate a "Canada plus plus plus" deal. Exactly what that would mean, and whether British negotiators can hope to negotiate it, remains to be seen.

What we do know, as the above graphic shows, is that a Canada-style future relationship between Britain and the EU would also be the most damaging model for the rights Brits enjoy as EU citizens.

It would mean more rights being lost altogether than in any other model ECAS analysed. Not only would Brits lose their right to travel freely across the EU as they do now, but would see all of the social security rights guaranteed by the EU completely vanish into thin air, something which would be protected at least partially in a Turkey-style Brexit.

Soft Brexit campaigners will be hoping Barnier's prediction of a Canada-style Brexit does not come true.