The United Kingdom's exit from the European Union (Brexit) and the Federal Council's 'Mind the gap' strategy

© European Commission

The United Kingdom (UK) left the European Union (EU) on 31 January 2020. The UK’s withdrawal marked the beginning of a prolongable transition period until 31 December 2020 during which the bilateral agreements between Switzerland and the EU continued to apply to the UK. The Switzerland-EU bilateral agreements ceased to apply to the United Kingdom at the end of the Brexit transition period. These agreements now are succeeded by a series of follow-up agreements that Switzerland negotiated with the UK as part of its Mind the Gap strategy (including Mind the Gap+). Most of the existing rights and obligations between the two countries will continue to apply.

All in all, the Federal Council negotiated seven agreements with the UK government:

  • The Agreement on Scheduled Air Services ensures that existing air transport rules will continue to apply in full and allows air carriers to retain their current traffic rights. The agreement will come into force on 1 January 2021.
  • The Agreement on the International Carriage of Passengers and Goods by Road allows carriers to continue transporting goods without requiring an authorisation and ensures the continued transportation of people and goods between the two countries. The agreement will come into force on 1 January 2021.
  • The Agreement on Direct Insurance other than Life Insurance (signed on 25 January 2019) allows Swiss insurance companies active in direct insurance, to operate and establish branches in the UK (and conversely for British insurance companies). The agreement will come into force on 1 January 2021.
  • The Trade Agreement transfers several relevant agreements with the EU into the Swiss-UK relationship, including the Free Trade Agreement (1972), the Procurement Agreement (1999), the Mutual Recognition Agreement (1999), the Agriculture Agreement (1999), and the Anti-Fraud Agreement (2004). The Trade Agreement will come into force on 1 January 2021. Some of the replicated provisions will not apply from 1 January, as they depend on an equivalent arrangement between the UK and the EU.
  • The Citizens' Rights Agreement safeguards the rights of Swiss nationals resident in the UK under the Agreement on the Free Movement of Persons (AFMP), i.e. rights of residence, social security entitlements and the recognition of professional qualifications. Reciprocal terms apply to British citizens in Switzerland. The agreement will provisionally apply from 1 January 2021. In relation to social security, a decision of the Swiss-EU Joint Committee for the AFMP will supplement the agreement and extend the protection of rights to citizens of EU member states.
  • The Services Mobility Agreement governs the short-term cross-border supply of services by natural persons. The agreement is initially limited to two years and will provisionally apply from 1 January 2021.
  • The Police Co-Operation Agreement strengthens and enhances Switzerland's cooperation with British law enforcement agencies, particularly in crime and terrorism prevention. This will improve the internal security of both countries and further develop relations with the UK (Mind the gap Plus). The agreement is due to take effect in the second half of 2021.


  • 01.01.2021 New Swiss–UK agreements apply 
  • 31.12.2020 Expected end of the transition period
  • 31.01.2020 UK withdrawal from the EU
  • 31.10.2019 Signing of a provisional agreement on the coordination of social security schemes
  • 10.07.2019 Signing of a provisional agreement on mutual access to the labour market and a me morandum of understanding on police cooperation
  • 25.2.2019 Signing of the citizens’ rights agreement
  • 11.2.2019 Signing of the trade agreement
  • 25.1.2019 Signing of the insurance agreement and the overland transport agreement
  • 17.12.2018 Signing of the air transport agreement
  • 29.03.2017 Initiation by the UK of the withdrawal process from the EU under Article 50 of the Treaty on European Union (date originally set for withdrawal: 29.03.2019)
  • 19.10.2016 Adoption of ‘Mind the gap’ strategy by the Federal Council
  • 23.06.2016 UK’s referendum on withdrawal from the EU (leave: 51.9%)