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In an updated country-by-country guide following the UK Parliament voting for the Government to request an Article 50 extension, Open Europe's Anna Nadibaidze looks at possible reasons for which the EU27 would agree to a Brexit delay.
15 March 2019
On 12 March MPs once again rejected the latest version of the Withdrawal Agreement, despite Prime Minister Theresa May obtaining further assurances on the Irish backstop protocol in Strasbourg earlier in the week.
Parliament also rejected leaving the EU without a deal in any circumstances in a non-binding vote on 13 March, and subsequently, it voted for the UK to request an extension to Article 50 on 14 March.
Reacting to this series of votes, EU officials have suggested they are reluctant to extend Article 50 without any clarity. EU chief Brexit negotiator Michel Barnier said, “Why would we extend these discussions…The discussion on Article 50 is done and dusted. We have the Withdrawal Agreement. It is there.” The European Parliament’s Brexit Co-Ordinator, Guy Verhofstadt, added, “Under no circumstances an extension in the dark! Unless there is a clear majority in the House of Commons for something precise, there is no reason at all for the European Council to agree on a prolongation.”
However, EU institutions do not have the final say on this matter. The proposal to extend needs to be agreed unanimously by all EU27 member states at the next European Council, on 21-22 March.
The general consensus remains that member states will not oppose a request for a delay. At least 18 member states have publicly said that they would not block extension. No member state has categorically ruled out a delay, although some leaders expressed concern about the prospect of prolonging Brexit uncertainty.
However, there are different opinions across the EU27 about the reasons for which an extension could be desirable or allowed, as well as about the possible length of any extension. In an updated version of our previous analysis, Open Europe looks at the statements and positions of all 27 member states to understand which conditions they may demand in exchange for agreeing a delay.
For most member states, the most important condition remains for the UK to provide clarity and guarantees for extending Article 50 will actually help Theresa May get her deal through the House of Commons. As France’s European Affairs Minister, Nathalie Loiseau, said on 7 March,
A credible extension must meet the majority of the UK Parliament.
Barnier said on 3 March that if the UK requests a delay the EU27 will “immediately ask ‘What for’?” The answer that the UK provides to that question is likely to determine the length of the extension.
The Government has confirmed it will hold a third ‘meaningful vote’ before the European Council summit. If it succeeds, the Government said it will request a short “technical” extension until 30 June, which would serve the purpose of preparing the necessary legislation. This should not be a problem for the EU27.
However, if the Withdrawal Agreement still does not pass, at the next summit the EU27 will have to come to a consensus on what kind of extension they would agree to.
Some member states, such as Austria and Germany, have stressed that there should be no extension beyond the EP elections in May, suggesting that the delay could only be a short one in any scenario. Others, such as Ireland and Portugal, have suggested that if the UK needs to reconsider its choices, they would be willing to have a longer extension of up to 21 months.
Some leaders have said they would like to see a second referendum in the UK; this implicitly means support for a longer delay to Brexit, as it is estimated a referendum will take at least six months to implement.
Finally, there are figures such as Belgian Prime Minister Charles Michel and Lithuanian President Dalia Grybauskaitė who have suggested that a No Deal Brexit could be better than continued uncertainty, if there is no valid reason for a delay. However, they are unlikely to veto an extension if the consensus among other member states is for one.
There have been reports about Eurosceptic UK MEPs asking like-minded governments in Italy, Poland, and Hungary to veto the extension request. However, it is unlikely that any of these governments would be willing to risk a No Deal scenario. In fact, as demonstrated by their statements below, these three countries are among the least likely to veto an extension.
Despite the different views held by different member states, ultimately any extension will be a common political decision taken by the EU27 heads of state. There are broadly three motivations on their side:
These motivations are not mutually exclusive and some member states hold more than one of them. Taken together, there is still the prospect of a ‘two-pronged’ offer from the EU on extension – under which the extension would be a technical, short one of up to three months if the deal is passed by a certain date, but much longer (between 9 and 21 months) if it is not.
In this table, Open Europe categorises statements made by officials and leaders from EU27 member states about the conditions to be fulfilled in order to extend Article 50. These categories are not mutually exclusive and are based on the main statements that leading politicians and officials from the member states have made in the last weeks, including after the series of parliamentary votes on 12-14 March.
Statements and analysis for each EU27 member state are outlined below.
The Austrian Chancellor, Sebastian Kurz, has been one of the leaders urging to avoid a No Deal and openly calling for an extension if the Brexit impasse is not solved.On February 28, during a meeting with Michel Barnier, Kurz said, “If more time is needed, if it’s not possible to make this regulated Brexit happen till the end of March, we will support an extension. Of course this extension can only take place if Theresa May wants it and puts forward a motion. If this extension should take place it is also necessary to ask the question ‘what is the goal for the time frame, what good does this extension do?”
After the vote on 12 March, Kurz said, “I assume that among the heads of government there is the unanimous view that it makes sense to avoid a No Deal scenario,” but warned, “The shorter the phase that we extend by the better, but the broader objective that must be kept in the foreground is to avoid a hard Brexit, so ideally I would say we are talking about weeks rather than months.” On 20 March Kurz said that he did not expect the UK to take part in European elections.
Belgium is set to be one of the member states that will be the most affected by a No Deal. Deloitte places it as the 4th country most affected and the Ifo Institute estimates the economic impact at 1.4% of Belgium’s GDP. Both government officials and business groups have been warning about the impacts for ports, the Eurostar, and jobs, especially in the Flanders region. These factors make it unlikely that Belgium could place severe constraints on an extension.
Foreign Minister Didier Reynders said, “We are not against [a delay]. Of course it will be easier to do that with a roadmap, knowing what we are doing in fact. Because if it is just to prolong the result … it’s more difficult. Like some weeks ago, we are waiting for some decisions in London. It will be that, the first step.” However, Prime Minister Charles Michel previously said that if the UK leaves without a deal on 29 March, this would at least provide some clarity. He also said on February 12 that if he needed to choose between a No Deal Brexit scenario and a “bad deal,” he would prefer No Deal as “it would mean clarity and responsibility.” After the vote on 12 March he commented, “We don’t need more time, we need more decisions.”
Ekaterina Zaharieva, Bulgaria’s Foreign Affairs Minister, previously said, “We are open to an extension of Article 50 but this extension should be with a clear and firm aim — an orderly Brexit to be achieved.” On 14 March, after the vote in the Commons, Prime Minister Boyko Borissov said that Bulgaria “has always striven to have Brexit with a deal or a treaty.”
Croatian Prime Minister Andrej Plenković said in February that Croatia “regrets the decision” of the UK to leave, adding, “We think it is not good, it is indeed bad both for Britain and for the EU, but we are working with other members to ensure that it is conducted in an orderly fashion.”
After the UK’s second ‘meaningful vote’, Plenković said Croatia was open to an extension, adding that he would prefer for the delay to be a shorter one, until 1 July at the latest.
The UK and Cyprus have a strong historical relationship, specifically characterised by two UK sovereign bases located in Cyprus which would be severely affected by a No Deal. However, these relations are unlikely to have much bearing on extending Article 50.
At a meeting with Theresa May on 5 March, President Nicos Anastasiades suggested that “neither Brexit nor the European Parliament elections should be considered a reason for delay” in the ongoing Cyprus settlement talks.
In the past Czech Prime Minister Andrej Babiš expressed support for a second referendum. He said in November 2018, “It would be better maybe to make another referendum and maybe the people in the meantime could change their view.” He also voiced concern about the rights of Czech citizens working and living in the UK, and said, “We have to work to ensure that this threat [of a No Deal Brexit] does not become a reality for our people working in Great Britain.”
Just before the second ‘meaningful vote’, Babiš urged Theresa May to hold a another public vote, telling her, “that the best solution would be for the UK to remain in the European Union.” He wrote, “[May] refused, but I still don’t think it was impossible.”
The Ministry of Foreign Affairs’ website states that the Danish government still aims for the 29 of March as the UK’s exit date but also emphasises that it wants an orderly exit with continued close ties between the EU and UK. It also states that Denmark, though traditionally a strong ally of the UK, aligns itself with EU27 and Michel Barnier, suggesting that it is unlikely to voice specific concerns about extending. Previously Foreign Minister Anders Samuelsen warned that “Brexit could have significant consequences for the Danish economy.” After the second ‘meaningful vote’, Danish Prime Minister Rasmussen wrote he was “saddened,” adding, “Despite clear EU assurances on the backstop, we now face a chaotic No Deal Brexit.”
Estonian President Kersti Kaljulaid took a hard line on the Irish backstop, but also voiced concern about No Deal, saying in February, “We are all concerned … A No Deal Brexit – if it will happen – will be a huge problem. It would be terribly difficult administratively.”
In reaction to the vote on 12 March, the Estonian government stated, “We are prepared to consider extending the deadline set forth in Article 50 of the EU Treaty,” if this helps avoiding a No Deal.
Finnish Prime Minister Juha Sipilä told Politico in early January that Finland would accept a delay to Article 50 if there is a “reason for extra time.” However he criticised the fact that “Brexit has taken too much time from our decision-making process,” referring to issues like growth, security, and migration, adding, “I hope that this issue will be off our table as soon as possible.”
France’s position seems to be stricter than the rest of the EU27, although the French government has not ruled out an extension altogether. French President Emmanuel Macron said in a press conference with Chancellor Merkel at the end of February, “We would support an extension request only if it was justified by a new choice of the British…But we would in no way accept an extension without a clear objective.” However, he later warned that the extension should not be used to “renegotiate an agreement that we have negotiated for many months.”
A No Deal would have grave consequences for the French economy, with only a third of French businesses estimated to be ready for such a scenario. However, there remains a probability of France pressing with demands with regards to fishing and access to UK waters, or other specific conditions, in exchange for a delay.
In January Macron raised the possibility of the extension “stepping over the European elections in order to find something else,” while French officials have suggested that a longer extension would be preferable to a shorter one. European Affairs Minister Nathalie Loiseau also said the UK holding EU elections “is not a problem for the European Union, but it might be weird for the UK during a process of withdrawal from the EU to organise a European election.” During a visit to London on 7 March, Loiseau said, “Why would be there be an extension without a reason? We have been in discussions for quite a long time now. There needs to be something specific to justify an extension,” adding, “A short extension: why not, if there is a good and credible reason.”
Chancellor Angela Merkel has been warning about the impacts of No Deal and reiterating that Germany “wanted to do everything to avoid a No Deal.” On a possible extension, Merkel said in February, “If the UK needs a bit more time, we won’t say no. But we want an orderly withdrawal of the UK from the EU.”
European Affairs Minister Michael Roth said in February, “An extension would only make sense if we have new substantial ideas on the table. Otherwise there’s no point…The deadlines are very clear: if there is a substantial extension, for example past the 1 July, then of course there will also have to be [European Parliament] elections in Great Britain, but I don’t want to speculate about this.”
Roth added on 13 March, “It’s not clear to me how what hasn’t been solved in two years could be sorted out in a few weeks…There would have to be a constructive and forward-looking suggestion — perhaps also one that’s capable of getting a majority — on the table from the British side, which explains how they see all of this. And I don’t see that at the moment.”
Announcing protection of citizens’ rights in a potential No Deal, Greek Foreign Minister George Katrougalos emphasised that an “orderly” exit “without major disruptions” would be the best scenario. Greece is also concerned about the economic impacts of a No Deal, but is unlikely to be seeking to impose further conditions.
Alternate Minister of Foreign Affairs, Sia Anagnostopoulou, warned on 6 March, “The only sure thing is that in order to limit the negative effects of Brexit, the withdrawal must be carried out in an orderly manner, based on the EU-UK Withdrawal Agreement.”
Sources in the Greek government have indicated that “there is no way to block a commonly accepted decision” on a longer extension.
Historically Hungary has been an ally of the UK within the EU, and Prime Minister Orbán has called the EU “not to punish the UK” for its decision to leave. It has also voiced concerns about No Deal, with Foreign Minister Péter Szijjártó calling it a “disaster” and saying, “We have to avoid a situation without a deal by all efforts.” He also said in June 2018, “Hungary regards the maintaining of security cooperation with Great Britain as extremely important.”
As Ireland is set to be the EU27 member state affected the most by No Deal, not only in economic terms (23.5% of Ireland’s GDP comes from trade with the UK), but also in terms of the border with Northern Ireland. The priority of the Irish government remains to avoid a hard border, and for this reason the Irish Taoiseach also suggested Ireland would be open to a longer extension.
In January, Foreign Minister Simon Coveney said, “If it is the case that in some point in the future the British Government seeks an extension of Article 50, that will have to have EU approval, but that is not something we would stand in the way of.” Coveney also said there would be a “generous response” to an Article 50 extension,” adding, “With the practicalities around European elections, the establishment of a new European Commission … there is a natural extension date until the end of June perhaps but that is a matter for the British Prime Minister and British parliament.”
Following the parliamentary vote on 13 March, Coveney raised the possibility of a longer extension of up to 21 months, which would open up “the debate in a much broader way to the overall approach that the United Kingdom takes to Brexit. That may facilitate a fundamental rethink, it may not, we just don’t know. If you have a long extension of, say 21 months to the end of 2020 – whatever the period would be – then Britain has a legal entitlement to have representation in the European Parliament.”
Prime Minister Leo Varadkar said at the end of February, “I’d certainly rather see an extension than seeing the UK leave without a deal. A long extension creates a complication in relation to the European elections, but that’s a small complication relative to the impact on our economy.”
On 14 March Varadkar welcomed the Commons’ decision to delay, as it reduces the likelihood of a No Deal scenario on 29 March. He added, “There seem to be two emerging options: ratification of the Withdrawal Agreement followed by a short extension into the summer, or a much longer extension that would give the UK time and space to decide what they want to do, including considering options that had been taken off the table like participation in the customs union and single market. I think we need to be open to any request they make, listen attentively and be generous in our response.”
Italian Prime Minister Giuseppe Conte said the UK’s withdrawal should be done in an orderly manner in a phone call with Theresa May, emphasising that a No Deal scenario should be avoided.
The Italian Foreign Minister, Enzo Moavero Milanesi, warned in February about the impact of No Deal for both sides’ citizens. He said, “We hope there will be no brutal severing of the relationship between Britain and the EU, given that many Italian citizens live on the other side of the channel and there are many Britons living in Italy,” adding that Italy has “strong economic interests” in and “a positive trade balance” with the UK.
Following the vote in Parliament on 13 March, he said, “If there were a request for a delay by the United Kingdom… we should say yes. No postponement would mean immediately going into a No Deal scenario, which, unfortunately, is on the table.”
Foreign Affairs Minister Edgars Rinkēvičs said in January, “Considering the incredibly complicated situation, we have to consider ways to avoid making the situation even more complicated. If there is an opportunity to resolve problems or reach an agreement, I see no reasons why talks could not be extended.”
Latvia’s ambassador to the UK, Baiba Braže, recently said she “does not recognise” reports that the EU27 will demand strict “legal and financial conditions” in exchange for an extension.
Lithuanian President Dalia Grybauskaitė has suggested No Deal would be better than a chaotic delay, saying in January, “The more we will be trying to extend any kind of uncertainty, the worse it will be for both sides. And in that case, it’s better to finish this chaos sooner even with no deal, or with any kind of deal.” However, other statements by Lithuanian officials are not necessarily consistent with this.
Foreign Minister Jean Asselborn said on January 18, “Only the initiative to hold a second referendum could be an indication to extend Article 50. Maybe it is a bit daring to say so. But it seems obvious that something strong needs to be behind the idea to tinker with Article 50.” He also told Politico, “If the UK were to decide to hold a second referendum and request an extension of Article 50 to carry out this process, we would respond favourably,” but only “provided that such a solution would be limited in time, and justified by a clear perspective and a realistic assurance that a rules-based process will be sought.” Prime Minister Xavier Bettel reportedly said that the UK could nominate MEPs “for a very short period,” suggesting that the stumbling block of European elections could be overcome. Bettel also requested clarity, writing, “We need a very clear and comprehensive reason for a delay extending Article 50.”
However, after the second ‘meaningful vote’, Finance Minister Pierre Gramegna said that it was “unthinkable” for the UK to delay its withdrawal beyond EU elections.
Prime Minister Joseph Muscat supports an extension of the Brexit deadline in case the UK requests it and said the EU should “definitely give [Theresa May] more time,” while ruling out the prospect of renegotiating the Withdrawal Agreement. He said, “It’s not an issue of whether we lose a couple of millions [of euros] here or there … I don’t think we can fudge on principles.”
Previously, Muscat has voiced strong support for a second referendum, saying at the Salzburg Summit in September 2018, “There is a unanimous – or almost unanimous, I would say – point of view around the table that we would like the almost impossible to happen, that the UK has another referendum.”
As the Dutch economy and specifically the Netherlands’ ports face important risks in case of No Deal, the Dutch government is unlikely to impose strict conditions for an extension.
However, Mark Rutte, the Dutch prime minister, has said the UK would have to explain “what [the extension] is for,” adding, “the EU could not… just spend another couple of months going round in circles.” Following the second ‘meaningful vote’, Rutte wrote, “Should the UK hand in a reasoned request for an extension, I expect a credible and convincing justification. The EU27 will consider the request and decide by unanimity. The smooth functioning of the EU institutions needs to be ensured,” suggesting that a longer extension will require the UK to participate in the European elections.
Dutch Foreign Minister Stef Blok said on 14 March that The Hague would view a request for extension with “benevolence,” adding, “Of course our question will be what will this extension be used for…of course each and every EU member state has to be convinced.”
Polish Foreign Minister Jacek Czaputowicz said in February that Poland would support delaying Brexit “if it helps work out a better position,” adding, “What is very important for us is that there should not be a No Deal Brexit…This would not be advantageous for the European Union, for Great Britain or for Poland.” He said on 13 March, “We are watching what is happening in the UK – the votes, there are certain expectations about how they will end. Maybe we will need to… extend this period a bit, maybe a little more time is needed for reflection…From our point of view a No Deal Brexit is the worst solution.”
A Polish-born Conservative MP has previously lobbied the Polish government to veto an Article 50 extension. However, there is little evidence Poland is taking this seriously – the suggestion has been shot down by government sources. In addition, the Centre for European Reform’s Charles Grant has reported that the Polish Government is happy to agree to an Article 50 extension – they would “prefer” a short one, but could “live with” one which went beyond the European Parliament elections. According to Grant, Warsaw believes that Brussels “exaggerates the complication of the UK needing to choose MEPs.”
In January, Portuguese Foreign Minister Augusto Santos Silvas said on Portuguese radio, “Only if UK asks for a delay to present alternatives to their ‘red lines’ and presents clear alternatives to the backstop, we are then going to listen and give our position.”
On 13 March, the Portuguese Foreign Ministry has stated its support for a longer extension, stating, “Portugal is fully available to lend its support to an extension, sufficiently significant so that we may have the conditions and time to negotiate an agreement with the British,” adding, “It does not make sense to have an extension of a few weeks, because the problem here is a political problem and not purely technical.”
However, even if it is a shorter extension, Portugal is unlikely to veto it. Gven the concerns about the impact of No Deal for citizens’ rights and for the tourism industry, Portugal would not present strict conditions for the extension.
Romania currently holds the rotating presidency of the Council of the EU, and although this role is largely symbolic and limited, it will have a role in forging a consensus among member states. Romania’s minister for European affairs, George Ciamba, told Reuters on February 27 that Romania, as the current holder of the EU’s rotating presidency, was still making plans for a disorderly Brexit but was more optimistic after Theresa May paved the way for a delay beyond the planned Brexit date of 29 March. He also said that if there was political will, the obstacle of European Parliament elections could be overcome.
Slovenian President Borut Pahor told Sky News on 2 March, “I think Slovenia and a lot of other countries would say yes [to an extension]. I think that nobody wants to see a hard Brexit in a chaotic way.” However, he demanded clarity and consensus from the UK Parliament, saying, “It is not clear at the moment if United Kingdom has a clear position on some sort of compromise solution and if it fits the requirements of the majority in the House [of Commons].” He also warned about Brexit being an issue for European parliament elections, “If Brexit would become an issue of political campaign among the 27 (member states), I think this could even make more difficult the whole framework of negotiations between London and Brussels.”
In January, Slovak Foreign Minister Miroslav Lajcak said the EU shouldn’t just “extend the agony” of Brexit, but “If there is a good reason [for an extension], then yes.”
Throughout Brexit negotiations, Slovakia as well as other Central and Eastern European (CEE) countries have prioritised citizens’ rights and have warned of the impact of No Deal for their citizens living in the UK. The European Bank for Reconstruction and Development (EBRD) estimates that CEE as a whole could have a 4-5% smaller GDP by 2021 in a No Deal scenario.
In the previous stage of negotiations, Spain has been threatening to block progress by demanding concessions on the post-Brexit status of Gibraltar; there is a small possibility they could revive such demands again in exchange for an extension. However, following the vote to delay on 14 March, a spokesperson for the Spanish government said they considered the case of Gibraltar “closed,” suggesting that this issue would not be an obstacle. Spain also has concerns about the impacts of a No Deal scenario, particularly for citizens’ rights and the tourism industry.
Prime Minister Pedro Sánchez said in February there needed to be conditions to extend Article 50, as “prolonging the uncertainty by postponing deadlines is not a reasonable or desirable alternative.” He added, “I want to make clear before this possible position of the British government, that although Spain is not going to oppose the concession of an eventual extension, it must have a certain perspective of resolution.”
The new Swedish EU Affairs Minister, Hans Dahlgren, said in January that a delay would be acceptable if there was “significant change” or a valid reason.
Sweden’s Brexit spokesperson Jan Olsson also said, “We [on the Swedish side] generally assess that the prerequisites [for an extension] exist if it becomes a clear process.”