Norway and the UK are close to reaching a deal to protect the status of Norwegians living in Britain and British nationals living in the Nordic country post-Brexit. The deal should mirror what was agreed between the UK and the European Union on citizens’ rights last December.

The announcement was made by Norwegian Prime Minister Erna Solberg and British Prime Minister Theresa May at the 70th Nordic Council meeting in Oslo this week.

British citizens living in Norway and Norwegians in the UK will also see their rights protected in case of no-deal Brexit, the two Prime Ministers said.

The UK is expected to leave the European Union on 29 March 2019. Norway is not a member of the European Union, but is part of the single market as a non-EU member of the European Economic Area (EEA). EU rules apply in the EEA on free movement of persons, goods, services and capital. As the UK prepares to leave the EU, Theresa May announced the intention to also leave the single market and to end free movement of people. Citizens from EEA countries living in the UK and British residents in the EEA are will therefore see their status changing due to Brexit.

“Prime Minister May and I agreed that Norway and UK will put in place a comprehensive citizens rights’ agreement,” said Erna Solberg. She also promised that, after March 2019, British citizens in Norway “will have the same opportunities as they had before”. British Prime Minister Theresa May made the same commitment to Norwegians living in Britain.

“We hope of course to be able to come to a satisfactory conclusion of the current negotiations in relation to this matter. In the event of no deal, we would look to be able to have an agreement for EEA and EFTA countries, but whatever happens, we confirm that people from with EEA EFTA countries, Norwegian citizens and those others who […] have made their life choice to be in the UK will be able to stay in the UK. We want them to stay, they are part of our community, they are part of our country and we welcome the contribution that they make,” said Theresa May.

In December 2018, the EU and the UK reached an agreement to protect the post-Brexit rights of citizens who moved across the respective territories. In March 2018, the deal was translated in a draft legal text forming part of the withdrawal agreement of the UK from the EU. The agreement is yet to be confirmed as negotiations in other areas have not been finalised.

As part of the deal, the UK is designing a “settled status” scheme to recognise, with some changes, the rights of EU nationals in the country. The government plans to extend the scheme to citizens of the European Free Trade Association (EFTA) countries (Iceland, Liechtenstein, Norway and Switzerland).

“The deal, which covers residency, healthcare, pensions, mutual recognition of professional qualifications and other benefits could be extended to the 18,000 Norwegian nationals, 2,000 Icelandic nationals and 40 Liechtenstein nationals living in the UK, and the 15,000 UK nationals in Norway, 800 in Iceland and 60 in Liechtenstein,” according to a statement issued in February.

Switzerland is not a member of the EU, nor of the EEA, but is part of EFTA and has a comprehensive agreement with the European Union that includes free movement of persons.

A note by the Swiss Embassy in the UK specifies that, while the British and Swiss authorities are discussing similar arrangements on citizens’ rights, “the different legal basis for movement between the EU and Switzerland – which is based on the EU-Swiss Free Movement of Persons Agreement (FMOPA) – means that there is a lot of technical detail to work through in order to take into account the differences in substance between the two legal frameworks (intra-EU and Swiss-EU related)”.

Working through the implications of these differences has been a key focus of UK-Switzerland talks, says the note.

Claudia Delpero © all rights reserved.
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