LONDON — There is a black hole at the center of the Brexit negotiations — hard-liners can kick and scream, but it’s sucking everyone into its gravitational pull. Its name is transition, and its shape is Norway.

The U.K. rejoining the European Economic Area from outside the European Union — the so-called Norway model — is European Commission chief negotiator Michel Barnier’s favorite option for a post-Brexit transitional arrangement.

It would allow for a smooth exit with minimum disruption for British business — by maintaining access to the single market — and give negotiators precious time to work out the details of a future trading arrangement. In Brussels, it is now seen as the only serious proposal that the European Commission is likely to make when it comes to a transitional deal. Five EU diplomats told POLITCO it would be a reasonable solution to the Brexit transition conundrum.

Two senior U.K. government figures, speaking on condition of anonymity, acknowledged the EU’s stance on this and in recent weeks a succession of British cabinet ministers have come out in favor of a transition period of up to three years after Brexit.

While none are yet explicitly talking about the EEA model, even Brexiteers like Trade Secretary Liam Fox and Environment Secretary Michael Gove now sing from the same hymn sheet as Brexit doves like Chancellor Philip Hammond, Business Secretary Greg Clark and Home Secretary Amber Rudd — all emphasizing the importance of avoiding a “cliff edge” Brexit for British business.

On the EU side, there is a clear position that no agreement on a transition — EEA or otherwise — can be settled until separation issues, like the Brexit bill, are settled.

The opposition Labour Party too, appears to be gravitating toward that position. Its leader Jeremy Corbyn had said that leaving the EU also means leaving the single market (which would preclude EEA membership). But Labour's shadow Brexit secretary, Keir Starmer, told the Guardian on August 1 that the party would try to force a vote on keeping the country in the single market.

Inexorably, under pressure from British business, political opponents and sheer realpolitik, they are all being pushed toward an EEA transition.

EFTA door is open

In the alphabet soup of variations on the fringes of the European Union, the EEA is the organization with the largest membership. It includes all EU member countries plus Norway, Iceland and Liechtenstein. Those three states are also members (along with Switzerland) of the European Free Trade Association (EFTA), a regional free-trade area that operates alongside the EU. To rejoin the EEA from outside the EU, Britain would have to join EFTA.

The bloc’s spokesman Thorfinnur Omarsson confirmed to POLTICO that their door is open. “We are open to receiving a U.K. membership application,” he said. EFTA has not had an indication that this is what London wants yet, but if it takes that option, then the U.K’s entry into EFTA “should not be too complicated,” he added. That's so long as an application comes relatively early in the negotiation process.

While there is broad consensus in the British Cabinet that some kind of transition is required, some aspects of EFTA/EEA membership would be unappealing to Brexiteers, even temporarily. Steve Baker, a junior minister in the Brexit department who was promoted after the election, said last month that staying in the EEA post Brexit would be like "putting blood in the water" — indicating the soft Brexiteers can expect a fight.

One reason is that EFTA/EEA members are subject to freedom of movement. The British government’s public position is still that freedom of movement will end on March 29, 2019, when the U.K. leaves the EU. But seemingly contradictory statements from Hammond, who has said it will be “some time” before full migration controls can be imposed, and Rudd, who has promised businesses no “cliff edge” on migration, suggest the government is heading toward a compromise.

One such escape clause was proposed by former chair of the House of Commons foreign affairs committee Crispin Blunt immediately after the election in a Times article suggesting an EEA transition. He pointed out that it would be possible to invoke powers held by EEA members to restrict freedom of movement.

Article 112 of the EEA Agreement allows a party to the agreement to unilaterally take “safeguard measures” to limit freedom of movement in particular regions or sectors.

Stephen Kinnock, the Labour MP for Aberavon, son of former leader Neil Kinnock and partner of former Danish Prime Minister Helle Thorning-Schmidt, said that the clause meant an EEA transition met all three of his party’s manifesto pledges on Brexit: that the U.K. must leave the EU, retain the benefits of the single market and reform freedom of movement.

The only legal precedent for invoking it comes from Liechtenstein but, Kinnock said, “if that’s a deal that tiny little Liechtenstein could secure, that’s something we could secure given the diplomatic and economic clout of the U.K.”

“That’s up to Theresa May and David Davis to deliver," he added.

Kinnock is one of a group of Labour MPs seeking to ally with like-minded Conservative backbenchers to force a vote on staying in the EEA during a transition when the government’s EU Withdrawal Bill comes to the House of Commons in September.

One Labour shadow cabinet member said it was now “almost inevitable” that the transition period would be the EEA model, because there is not enough time between now and the close of negotiations, likely to be in fall 2018, to devise a bespoke transition arrangement. Hammond is reported to have made a similar case to business leaders in recent days, calling for an “off-the-shelf” transition arrangement.

However, the Labour shadow cabinet member said EEA membership was not a permanent solution. “If you have any respect for yourself as a 21st-century global power you can’t become Norway,” the shadow cabinet figure said. One major downside of EEA membership outside of the EU is that you must accept the rules of the single market without having any influence over them. By leaving the EU, Britain will lose its representation in the European Parliament and the Council of the EU, as well as it right to nominate a commissioner.

Brexit bill link

The EFTA/EEA option is no silver bullet to a smooth transition.

It does not cover customs arrangements and if trade disruption is to be avoided during a transition, a separate agreement would be needed to maintain or replicate the U.K.’s place in the EU customs union.

One U.K. government official, meanwhile, said it would not be straightforward to rejoin the EEA, via EFTA, given the reform of the two organizations' procedures, and structures required to accommodate such a large new member. However, the official did not rule out transition inside the EEA, or “something novel, but conceptually similar.”

On the EU side, there is a clear position that no agreement on a transition — EEA or otherwise — can be settled until separation issues, like the Brexit bill, are settled. Martin Selmayr, Jean-Claude Juncker’s head of Cabinet, on Thursday retweeted a Times article making this point with the words: “Very true. Good analysis.”

The Commission views the transition deal as an issue for phase two of the Brexit negotiations. These can only begin if, in the fall, the European Council is satisfied that “sufficient progress” has been made in phase one. This judgment is likely to rest on whether the U.K. has made an acceptable proposal on the so-called Brexit bill — the U.K.’s financial obligations to the EU.

Reports in the British press that U.K. officials will propose paying £10 billion a year for three years as part of a transition deal chime with expectations on the EU side.

Two EU diplomats said they expected the U.K. to link the Brexit bill to the transition in talks this fall. If the U.K. were to meet its financial obligations under the EU’s multiannual financial framework until 2020, the diplomats argued, Brussels could play fair and not make the U.K. pay again as an EEA member to get market access. The Brexit bill could, in this scenario, become the ticket for getting market access under a transitional deal. Norway will have paid €1.3 billion to the EU between 2014 and 2021, but its gross domestic product (€313 billion) is much smaller than the U.K.’s (€2.2 trillion) so the British payments would be much higher.

"We need to understand the EU's methodology in respect of the calculation of the ‘bill’" — Conservative MP David Jones

Linking the Brexit bill to EEA membership may suit the U.K., whose negotiators have made clear that it would be “politically impossible” for Theresa May to go public with a Brexit bill figure in the tens of billions of euros without having something to show for it.

Guntram Wolff, director of the Bruegel think tank in Brussels, said an early agreement on an EEA transition “would take the sting out of the very toxic Brexit bill debate. The discussion can calm down, which could also help advancing in other areas such as negotiating a future trade agreement.”

But an EEA transition would not be seen as good value for money by all, and some MPs will want the U.K. to hold out rather than accept that an EFTA/EEA transition is the only option on the table.

“The negotiations will obviously require give and take on both sides. We need to understand the EU's methodology in respect of the calculation of the ‘bill,’" said Conservative MP David Jones, a former Brexit minister who was fired after the election and staunch Brexiteer. “We want a free-trade agreement that gives the best possible access to the single market."

"Further than that, there will clearly have to be negotiation and I would guess that we are some considerable way off seeing what the final position will be,” Jones said.