Anna Nadibaidze is a Research and Communications Associate at Open Europe. This article first appeared on the Open Europe blog.
Following Parliament’s vote to seek a Brexit delay is approved by Parliament, the proposal then needs to be agreed unanimously by all EU27 member states at the next European Council.
There is a general consensus that if the UK proposes a delay, member states will not oppose it. At least 18 member states have publicly said that they would welcome, or at least not block, an 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 the possible length of any extension. Open Europe has looked at the statements and positions of all 27 member states to assess which conditions they may demand in exchange for agreeing an extension.
While it has been argued on the Brexiteer side that a 21-month extension could be desirable in order to facilitate a ‘managed’ No Deal Brexit in 2021, it is very unlikely the EU27 will agree such terms for a delay. The vast majority of member states have committed to avoiding a No Deal scenario.
Theresa May suggested in a speech on 8th March that in order to agree an extension of Article 50 member states could ask further conditions, such as “no end to free movement [of people], no taking back control…or a second Brexit referendum.” However, it seems likely that these assertions were aimed at a domestic political audience. For most member states, the most important condition remains for the UK to provide clarity and guarantees that extending Article 50 will actually help Theresa May get her deal through the House of Commons. As Nathalie Loiseau, France’s European Affairs Minister, said, “A credible extension must meet the majority of the UK Parliament.”
Michel Barnier said 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. For instance, if the extension is “technical” and serves the purpose of passing the necessary domestic legislation, it is most likely to be a short extension of weeks or months.
Some member states, such as Austria and Germany, have stressed that there should be no extension beyond the European Parliament (EP) elections in May, suggesting that the delay could only be a short one in any scenario. However, others, such as Luxembourg and Ireland, have suggested that if the UK provides a valid reason for extension, the obstacle of elections could be overcome.
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. Meanwhile, it has been reported that member states such as France would also prefer a longer delay in order to avoid the UK asking for repeated extensions.
Finally, there are figures such as Charles Michel, the Belgian Prime Minister, and Dalia Grybauskaitė, the Lithuanian President, 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.
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 and months.
The bigger picture: EU27 motivations
Despite the different views held by different member states, any extension will be a common EU decision. There are broadly three motivations on the EU27 side:
- Avoiding the chaos of a No Deal exit at the end of March, while also avoiding any practical difficulties relating to the European Parliament elections. This lends itself to a short extension, which would have to have a clear purpose and would last no later than the end of June.
- A few member states also hold out limited hope that the political weather in the UK might change, towards either a much softer Brexit or a second referendum. This lends itself to a longer extension, beyond the European elections.
- Maximising pressure on UK MPs to vote for the deal. This lends itself to the threat of a longer extension, perhaps in the hope that MPs will reject this offer and back the deal instead.
These motivations are not mutually exclusive and some member states hold more than one of them. Taken together, there may yet be 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.
Statements and analysis for each EU27 member state are outlined below.
Will support an extension, but not beyond European elections and only with clear goal
Sebastian Kurz, the Austrian Chancellor, 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. In January, Kurz said, “We should have the courage to defer the date of Brexit” if the UK Parliament cannot reach agreement on the Brexit deal, adding that the condition would be “only until European elections in May.”
On February 28, during a meeting with 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?”
Not against a delay, but Belgian Prime Minister has warned against a “bad deal”
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 per cent 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.
Didier Reynders, the Foreign Minister, 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, Charles Michel, the Belgian Prime Minister, previously said that if the UK leaves without a deal on 29th March, this would at least provide some clarity. He also said on 12th February 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.”
Open to an extension, but with a clear goal
Ekaterina Zaharieva, Bulgaria’s Foreign Affairs Minister, 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.”
Regrets Brexit, but aims for it to be done in an orderly way
Andrej Plenkovic, the Croatian Prime Minister, 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.”
No explicit position, but unlikely to impose conditions
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 5th 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.
Would not oppose an extension, especially if it is to hold a second referendum
In the past Andrej Babiš, the Czech Prime Minister, 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.”
Aims for an orderly Brexit
The Ministry of Foreign Affairs’ website states that the Danish government still aims for 29th 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 Barnier, suggesting that it is unlikely to voice specific concerns about extending. Previously, Anders Samuelsen, the Foreign Minister, warned that “Brexit could have significant consequences for the Danish economy.”
Concerned about No Deal
Kersti Kaljulaid, Estonia’s president, 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.”
Would be open to a short extension, if there is a valid reason
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.”
Demands a clear reason for an extension, and would prefer a longer delay
France’s position seems to be stricter than the rest of the EU27, although the French government has not ruled out an extension altogether. 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.”
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. Nathalie Loiseau, the European Affairs Minister, 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.” On a visit to London on 7th 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.”
Open to a short extension, if the UK has a plan
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.”
However, Michael Roth, the European Affairs Minister, also 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 1st 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.”
Seeks an orderly Brexit
Announcing protection of citizens’ rights in a potential No Deal, George Katrougalos, the Foreign Minister, 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.
Sia Anagnostopoulou, the Alternate Minister of Foreign Affairs, warned on 6th 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.”
Not opposed to either a short or a long extension, if it helps reach a deal
As Ireland is set to be the EU27 member state affected the most by No Deal, not only in economic terms (23.5 per cent 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, Simon Coveney, the Foreign Minister, 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.”
Leo Varadkar struck a slightly different note in February, saying that an extension is not “inevitable. It’s certainly possible. If there is going to be an extension, it needs to be with a purpose, it needs to be with a view to securing and ratifying an agreement. I don’t think anyone would like to see this stalemate or impasse or period of purgatory continue for months and months and months.” However, Varadkar also saidat 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.”
Emphasises importance of orderly exit
Giuseppe Conte, the Italian Prime Minister, said in a phone call with Theresa May that the UK’s withdrawal should be done in an orderly manner, emphasising that a No Deal scenario should be avoided.
Enzo Moavero Milanesi, the IForeign Minister, warned in February especially 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. He also discussed “A possible extension of Britain’s withdrawal from the EU beyond March, which remains a possibility under Article 50 of the Treaty on European Union and which requires the European Council’s unanimous accord.”
Wants to avoid No Deal at all costs
Historically, Hungary has been an ally of the UK within the EU, and Viktor Orbán has called on the EU “not to punish the UK” for its decision to leave. The country has also voiced concerns about No Deal, with Péter Szijjártó, the Foreign Minister, 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.”
Does not rule out extension if it helps reaching an agreement
Edgars Rinkēvičs, the Latvian Foreign Affairs Minister, 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.”
Reluctant to prolong uncertainty
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.
Does not rule out an extension, specifically if another public vote is held
Foreign Minister Jean Asselborn said on 18th January, “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.”
Xavier Bettel, the Prime Minister, reportedly said that the UK could nominate MEPs “for a very short period,” suggesting that the stumbling block of European elections could be overcome.
Does not rule out extension, supports a second referendum
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.”
Demands clarity on the reason why the extension would be needed
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.” He told the BBC, “It’s up to the UK. If the UK ask for delay, the EU will ask what do you want with it? We don’t want to go round in circles for the next couple of months. What will be achieved by it?”
Will not risk a No Deal by opposing extension
Jacek Czaputowicz, the Polish Foreign Minister, said 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.”
Prime Minister Mateusz Morawiecki has also previously criticised the EU for being harsh towards May, which might suggest his country would be sympathetic. He said, “Strong statements and harsh words of some politicians in Brussels do not help, but hinder our common goal in achieving the most desirable outcome for all.”
A Polish-born Conservative MP has repeatedly 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.”
Demands alternatives from the UK
In January, Augusto Santos Silvas, the Portuguese Foreign Minister, 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.”
However, given the concerns about the impact of No Deal for citizens’ rights and for the tourism industry, Portugal is unlikely to present strict conditions for the extension.
As current EU Council president, would not oppose will of EU27 to extend
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. George Ciamba, Romania’s minister for European affairs, told Reuters on 27th February 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 29th March. He also said that if there was political will, the obstacle of European Parliament elections could be overcome.
Open to an extension, but demands a compromise from the UK
President Borut Pahor told Sky News on 2nd 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.”
Demands a clear reason for extending
In January, Miroslav Lajcak, the Slovak Foreign Minister 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 per cent smaller GDP by 2021 in a No Deal scenario.
Will not oppose extension, but could demand conditions
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 possibility they could revive such demands again in exchange for an extension. On the other hand, Spain also has concerns about the impacts of a No Deal scenario, particularly for citizens’ rights and the tourism industry.
Prime Minister Pedro Sanchez 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.”
Supports an extension if there is clarity about the process
Jan Olsson, Sweden’s Brexit spokesperson, said, “We [on the Swedish side] generally assess that the prerequisites [for an extension] exist if it becomes a clear process.”