Introduction
This paper lays out the priorities the European Movement in Scotland believes should be adopted by the UK government at the UK/EU summit scheduled for 20th November 2026, in Brussels.
The European Movement in Scotland (EMiS) is Scotland’s oldest and largest organisation campaigning for political and economic integration in Europe and for Scotland rejoining the European Union, whether as a member nation of the UK or as an independent sovereign state. EMiS takes no position on the Scottish constitutional question
Membership of EMiS is open to people of all political persuasions and those who have no party-political affiliation. Membership is open to all who believe in the values and benefits of economic partnerships between European states that promote peace, prosperity, human and civil rights, security, democracy and the rule of law.
To learn more about EMiS and on how to join visit the website at: euromovescotland.org.uk
Position Paper on the November 2026 EU-UK Summit
Summary
- The Prime Minister is right to have initiated an open debate on the future of UK-EU relations.
- The current UK–EU reset is welcome but too limited and too slow to offset the economic, social and constitutional damage caused by Brexit. Sectoral agreements can reduce friction, but they leave the UK as a rule-taker and cannot reproduce the benefits or influence of membership.
- The UK should pursue dynamic alignment and immediate practical agreements on sanitary and phytosanitary standards, emissions trading, electricity, chemicals, qualifications and mobility, while making return to the Single Market and Customs Union—and ultimately EU membership—the strategic direction of travel within the shortest possible timeframe.
- Scotland has a distinctive stake. It voted 62 per cent to remain and is more exposed than the UK in agrifood, fisheries, energy, higher education, tourism, hospitality and social care. The Scottish Government and Parliament must therefore be involved directly in setting objectives, shaping negotiations and implementing agreements.
- Youth mobility and the welcome return to Erasmus+ are early priorities. Scotland also needs flexible migration routes for sectors facing acute labour shortages, including agriculture, hospitality and care.
- Closer UK–EU cooperation on security, defence, AI and economic resilience is essential, but should rest on shared interests and trust rather than be used as leverage in trade negotiations.
- Parliamentary and devolved scrutiny must begin while EU rules are being shaped, not after UK implementing legislation is tabled. Dedicated European affairs scrutiny structures in Holyrood and Westminster, and properly resourced representation in Brussels are required.
1. Purpose and context
Scotland’s position on EU membership is distinctive. In 2016, 62 per cent of Scottish voters chose to remain in the EU. European links are integral to sectors including food and drink, fisheries, energy, tourism, higher education and culture. Brexit has also altered Scotland’s constitutional debate: many voters recall the 2014 assurance that remaining in the UK would secure Scotland’s EU membership, while subsequent UK legislation—particularly the Internal Market Act—has damaged trust between Westminster and Holyrood.
The wider geopolitical context strengthens the case for closer European cooperation. A less predictable United States, pressure on the rules-based trading system and the need for greater European security capacity all make a durable UK–EU partnership more important. The reset should therefore rebuild trust, restore the UK’s reputation as a reliable partner and establish a pathway towards substantially deeper integration.
2. The limits of the current reset
Agreements on a common sanitary and phytosanitary area, emissions trading and electricity are useful and should be concluded quickly. They would reduce costs, prevent further divergence and deliver particular benefits to Scottish agrifood and renewable energy. However, their aggregate economic effect is modest compared with the loss associated with Brexit. They mitigate the damage but are not a substitute for broad market integration.
The UK should stop framing negotiations through fixed “red lines”. The EU is unlikely to permit cherry-picking or a proliferation of disconnected bilateral arrangements. Any meaningful increase in market access will be calibrated to acceptance and enforcement of EU rules. The UK should therefore approach negotiations with realistic expectations, emphasise common interests and recognise that the Trade and Cooperation Agreement already largely meets EU needs; the UK is therefore largely a demandeur (an applicant).
A series of sectoral deals would consume political and administrative capacity while producing a fragmented regulatory landscape. The strategic objective should instead be return to the Single Market and Customs Union, followed by an application for EU membership. Dynamic alignment and the European Partnership framework can help arrest divergence and prepare the ground, but outside membership the UK will have limited influence over the rules it follows.
3. Dynamic alignment and influence
Dynamic alignment means keeping domestic rules in step with changes in EU law. It can be unilateral, as enabled in some areas by the Product Regulation and Metrology Act, or embedded in an agreement that also provides market access. The latter offers greater economic benefit but normally entails governance, enforcement, financial contributions and a continuing obligation to update rules.
The experience of the EEA and Switzerland shows both the opportunities and the limits. Non-EU countries can participate in expert groups, preparatory work and “decision-shaping”, but they do not vote on EU legislation. The UK should nevertheless seek formal access to relevant working groups, second staff to EU institutions and agencies, and invest in early intelligence and sustained engagement with the Commission, Member States and European Parliament.
Alignment should be prioritised where divergence imposes the greatest costs, including agrifood, chemicals, product regulation, carbon pricing and highly integrated manufacturing; the UK should secure participation in the EU’s Industrial Development Act (of which ‘Made in Europe’ is a key tool).
Formal alignment with EU REACH would reduce duplication in chemicals regulation. Mutual recognition should cover professional qualifications and, where possible, entry requirements for further and higher education. In each case, access to markets, systems and agencies will justify a fair UK contribution to implementation costs; value should be judged against the benefits secured, not against a presumption that cooperation should be cost-free.
4. Scottish economic and social priorities
Food, farming and fisheries
A comprehensive SPS agreement is especially important to Scotland because agrifood represents a larger share of output and employment than across the UK as a whole. Reducing certification, border checks and regulatory duplication would support producers and exporters. On fisheries, negotiations should prioritise the long-term conservation of shared stocks and stable, evidence-based access arrangements rather than short-term political symbolism.
Energy and climate
Scotland’s renewable resources and associated expertise give it a major interest in participation in the EU internal electricity market, efficient interconnection and a linked emissions trading system. Any agreement should improve cross-border trading while ensuring that communities hosting infrastructure share in the benefits and are protected from disproportionate costs. Alignment on carbon pricing would also reduce uncertainty and avoid exposure to the EU Carbon Border Adjustment Mechanism.
Mobility, education and labour supply
A reciprocal youth mobility scheme should be an early deliverable. Alongside the return to Erasmus+, it would expand opportunities for young people and their communities, and strengthen Scotland’s universities, colleges, schools as well as that of vocational training, youth work and sports organisations. Mobility arrangements should be simple and affordable, and should extend beyond touring artists to students, researchers and workers.
Brexit has intensified labour shortages in Scottish agriculture, hospitality and social care. The UK should restore greater labour mobility with the EU and give the Scottish Government meaningful scope to shape routes responding to demonstrable Scottish needs. Mutual recognition of qualifications would support recruitment and reduce barriers for Scottish citizens seeking to study or work in Europe.
5. Trade beyond Europe
Post-Brexit trade agreements should not obstruct deeper alignment with the EU. Most UK agreements simply roll over earlier EU arrangements, while the projected gains from the Australia agreement, CPTPP membership and a potential US agreement are small compared with the economic cost attributed to Brexit.
Where conflicts arise between possible cooperation with the EU and other trade relations, the Government should prioritise arrangements with the EU, the UK’s largest and nearest market.
Recent discussions on ‘Made in Europe’, a key component of the Industrial Accelerator Act (IAA) tabled by the European Commission in March 2006, illustrate how vulnerable the UK now is to the vicissitudes of international trade, notably, but not only those concerning the automotive sector.
UK inclusion in the IAA would constrain Chinese direct investments in the UK and involve tariffs on Chinese EVs, likely impairing UK-China relations; however, the UK cannot afford to be locked out of EU supply chains. ‘Muddling through’ under the guise of pragmatism risks increasing the price of isolation from the EU while still exposing the UK to Chinese retaliation.
For Scotland, assessments of closer EU alignment as against trade beyond Europe must include distributional effects. Agricultural concessions in distant trade agreements can impose concentrated costs on Scottish producers, while closer EU alignment offers direct advantages to food and drink exporters, universities, tourism and energy. Trade policy should therefore be assessed not only in terms of aggregate UK GDP, but also through its sectoral and territorial impacts.
6. Security and defence
The UK and EU should build the broadest practical security partnership possible, covering regular political dialogue, intelligence sharing, defence cooperation, participation in relevant missions and closer defence-industrial collaboration. The UK should seek structured links with the European Defence Agency, appropriate participation in PESCO projects, access to EU defence initiatives and involvement in Security Action for Europe.
The UK has been at the forefront of international discussions about AI safety, following the inaugural AI Safety Summit at Bletchley Park. The UK and the EU take very different approaches to AI regulation, and yet UK businesses are subject to EU rules for products and services offered there. At the same time, there are growing concerns, not least among whistleblowers from within the sector, about the capacity for AI developments to outpace regulatory frameworks, pointing to the requirement for internationally agreed guardrails. There is a clear opportunity for UK-EU collaboration to contribute to the development of protocols that ensure AI safety while maximising the economic and scientific opportunities that AI can offer.
These strengths should not be treated as bargaining chips for unrelated concessions. Cooperation will be most effective if the UK acts in good faith, respects the competences of EU institutions and uses bilateral and multilateral relationships to complement—not circumvent—the formal UK–EU framework.
7. Devolution, governance and scrutiny
A credible European policy requires a domestic reset. Scottish ministers and officials should be involved from the outset in defining UK objectives in areas of devolved responsibility or distinctive Scottish interest. Their expertise should be represented in negotiating teams and technical groups, particularly for SPS rules, fisheries, energy, education, justice and mobility. Changes affecting devolved powers should proceed through consent and the Sewel Convention, not unilateral centralisation.
The Scottish Government’s Brussels office and wider European networks should be retained and strengthened. An expanded intergovernmental mechanism, potentially drawing on the British–Irish Council, could improve coordination among the UK Government, devolved administrations, Ireland and Northern Ireland. Scottish ministers should have appropriate powers to implement agreed alignment in devolved fields, subject to mechanisms ensuring compliance with the UK’s international obligations.
Scrutiny must also become earlier and more systematic. The UK Parliament should re-establish overarching European affairs scrutiny, working with sectoral committees, devolved legislatures and stakeholders. Effective influence requires monitoring EU initiatives before they are adopted, engaging with the Commission, Member States and European Parliament, and assessing the territorial implications of proposed alignment. Agreements of substance should be legally binding and subject to transparent parliamentary approval and review.
8. Recommendations
- Conclude ambitious SPS, electricity and emissions-trading agreements quickly, with Scottish sectoral interests reflected in the mandates.
- Adopt dynamic alignment in priority areas—including agrifood, chemicals, product regulation and carbon pricing—while negotiating the greatest possible market access and participation in decision-shaping.
- Make youth mobility and wider recognition of qualifications central to the reset.
- Create flexible migration arrangements responsive to Scottish labour shortages in agriculture, hospitality, social care and other key sectors.
- State that return to the Single Market and Customs Union, followed by EU membership, is the strategic objective.
- Establish a comprehensive UK–EU security and defence partnership based on trust and shared European interests and establish cooperation in AI regulation.
- Give the Scottish Government and Parliament a formal, continuing role in negotiation, implementation and scrutiny where Scottish or devolved interests are engaged.
- Restore dedicated European scrutiny at Westminster, strengthen Scottish and UK representation in Brussels, and resource early engagement with EU institutions and Member States.
- Conduct frank, evidence-based public and business engagement on the effects of Brexit, the choices involved in alignment and the benefits and obligations of closer integration.
Researched and written by Fiona Wishlade, Emeritus Professor of European Policy Research, with contributions from other members of the European Movement in Scotland.
October 2026
The European Movement in Scotland is committed to promoting the essential European value of free speech. Consequently, we regularly publish articles by leading academics, journalists and others discussing issues germane to Scotland’s place in Europe. Such articles do not necessarily reflect the views of the European Movement in Scotland.