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Switzerland Plusthe deal that could restore free movement within months

The Switzerland Plus Deal

Andy Burnham's proposed Switzerland Plus model offers the UK a pragmatic, achievable path to restoring free movement and single market access — without requiring full EU membership.

What is the Switzerland Plus model?

Switzerland is not an EU member. It has never been one. Yet it has deep, frictionless access to the EU single market through a series of bilateral agreements, and its citizens enjoy mutual free movement with all EU27 countries.

The “Switzerland Plus” concept — championed by Andy Burnham — takes this model and goes further. The “Plus” elements would extend Switzerland’s bilateral framework to include:

  1. Mutual free movement of persons — British and EU citizens can live and work in each other’s territories without visa requirements
  2. Single market access for goods — UK goods can be exported to the EU without customs declarations, rules of origin paperwork, or equivalent standards checks
  3. Services access — UK professional services firms gain the right to operate across the EU under mutual recognition of qualifications
  4. Participation in EU programmes — Horizon Europe (research), Erasmus+ (education), and other EU collaborative programmes

Andy Burnham’s role

Andy Burnham, who became UK Prime Minister in July 2026 following Labour’s second successive election victory, has consistently argued that the UK’s relationship with the EU needs to be rebuilt from pragmatic economic and social grounds rather than revisiting the divisive remain/leave binary.

In September 2026, Burnham did not rule out including a Switzerland Plus proposal in Labour’s next manifesto, noting that “the question is not whether we want closer European ties — the evidence shows we do — but what the most achievable and beneficial form of that relationship looks like.”

This political moment is significant. For the first time since the 2016 referendum, a sitting UK Prime Minister is actively discussing the framework for restored free movement.

Why Switzerland Plus over full rejoining?

Full EU membership would require:

  • Rejoining the EU customs union (surrendering independent trade policy)
  • Accepting the jurisdiction of the European Court of Justice in all areas
  • Full budget contributions (the UK’s net contribution was ~£10bn/year)
  • A multi-year accession process (minimum 5 years)
  • A second referendum, which polling shows is not yet a clear majority position

Switzerland Plus avoids all of these constraints while delivering the two things British people and businesses actually want most: free movement and reduced trade barriers.

Norway, Iceland, and Liechtenstein have operated the EEA model successfully for 30 years. Switzerland’s bilateral model has operated since 1999. The UK does not need to invent something new — it can adopt a proven framework.

What would it take?

The EU has demonstrated willingness to negotiate with the UK on a new basis. The Trade and Cooperation Agreement was a floor, not a ceiling.

A Switzerland Plus deal would require:

  1. Political will from the UK government — Burnham’s government appears to be moving in this direction
  2. EU negotiating mandate — The European Commission would need a mandate from EU27 governments; given the UK’s size and economic weight, this is achievable
  3. Agreement on free movement — This is the central issue; the EU will require genuine mutual free movement, not one-sided access
  4. Governance arrangements — A joint committee structure and dispute resolution mechanism (similar to Switzerland’s model but without ECJ supremacy)

The EU has a strong incentive to agree. The UK is the EU’s second-largest trading partner. Reduced friction is in EU27 interest too.

What happens if we wait?

Each year of the current relationship compounds the economic divergence and the staffing shortages in public services. British young people continue to have fewer rights than their European counterparts. UK businesses continue to operate under a dual regulatory burden.

The Switzerland Plus deal is not the end goal — it is a pragmatic first step. A deal could be negotiated and ratified within this parliament. Free movement could be restored within years, not decades.

The question is whether we seize this political moment.


Sources: UK Prime Minister’s speeches, European Commission TCA review, Swiss Federal Council bilateral agreements, UK in a Changing Europe

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