The consequences of Brexit depend on the model which will be adopted for the future relationship between the EU and the UK. These models should be compared with a respect to a number of different parameters, which are not confined to substantive trade rules but include also questions of legal effect and dispute settlement. There are very substantial differences between, on the one hand, the EU

View less Membership and EEA models; and on the other the WTO/FTA models. Those differences are focused on the approach to regulatory convergence and to the legal effects of the agreements and their enforcement.