This has left expats dependent on future decisions of the UK and France – although a leading expert on international relations told Connexion he believes they can count on France.
Remaining in the single market would have left most expat rights unchanged but now everything will depend on what Britain can offer its citizens abroad and on what Britain and France decide in reciprocal deals.
Negotiations on this could start quickly if Britain goes ahead with plans to trigger Article 50. The UK will seek to come out of European court control and the single market, Mrs May said, as staying in would involve so many constraints that it would be like not leaving at all.
She did not want “partial membership of the EU, associate membership, or anything that leaves us half-in, half-out”, which – though not explicit – may suggest reluctance to accept the idea, championed by some MEPs, that Britons could continue to opt in to a form of voluntary ‘associate citizenship’.
The UK would stop making “vast contributions” to the EU annually, but might still contribute to certain programmes. Mrs May also said the final ‘divorce’ deal would be put to both houses of Parliament for a vote – however she did not reply to a journalist who asked if Britain would remain in the EU if the deal was voted down.
Mrs May hoped some changes would be “phased in” after Brexit, avoiding a “disruptive cliff edge”; and she wanted a free trade deal between the UK and the EU to allow the “best possible access” to trade with the EU single market. However, she did not clarify what would happen if this could not be concluded along with the Article 50 deal.
Leaving the single market rules out remaining in the wider European Economic Area and means all the benefits Britons living in EU countries gain from free movement would be up for renegotiation.
However Mrs May said she wants to “guarantee the rights of EU citizens who are already living in Britain, and the rights of British nationals in other member states, as early as we can”. She added: “I have told other EU leaders we could give people the certainty they want straight away, and reach such a deal now. Many favour such an agreement – one or two do not – but it remains an important priority for Britain, and for many other member states, to resolve this challenge as soon as possible.”
Mrs May refused to guarantee that Europeans would benefit from easier entry than other foreigners after Brexit, although the UK would welcome “the brightest and the best to study and work”.
As EU countries may be expected to reciprocate, this means that while it may be hoped that rights of existing expats will be protected, moving to France in the future could become more complicated.
Expat rights campaigner Brian Cave of ecreu.com called the speech “statesman-like” but said: “I do not feel she really grasps the fear and worry that so many British citizens in the EU have.”
First steps out of the EU?
The UK’s Supreme Court was due to rule on whether Parliament must be consulted before the Prime Minister can trigger Article 50 – the formal start of the Brexit process – as Connexion went to press.
Ministers have already acknowledged the government is likely to lose when the result is announced on January 23. The court may also say the regional assemblies of Scotland, Wales and Northern Ireland must also be consulted before Article 50 is triggered.
The government is ready to rush through legislation allowing Westminster MPs to hold a vote. The Liberal Democrats oppose the trigger without a promise of a second referendum on the divorce deal but have just nine MPs and the SNP, with 56, opposes it. However a bill is still likely to pass. It is unlikely many Labour MPs will vote against it, but some may seek amendments avoiding a ‘hard’ break. Mrs May wants start the process by the end of March.
Other legal challenges are seeking to show the Article 50 trigger is not enough to take the UK out of the EEA, and seeking to clarify if the trigger is reversible later on.
The key will be the US
International relations expert Philippe Moreau Defarges of the IFRI institute in Paris said that he remains optimistic that France would treat existing Britons living in the country well.
He said: “It’s certain that Brexit would bring upheavals as regards to free movement but for Britons here I think, on the French side, everything will be done to change things as little as possible. A lot of French people, and people in the government, do not want to smash our relations with the UK – indeed some still hope the Brexit will not take place.
“Mrs May is being provocative but I think in France we will try to calm things down and take a moderate line. One reason is that France will not want to push the UK towards Trump’s USA.
“At the same time if the French in the UK feel mistreated, there will be reactions from France.”
If, however, Mrs May sticks to her promises and protects the rights of EU nationals living in the UK, “France will respond positively,” he said. “It’s in our interests. A lot of French people work in the UK and earn well and if they return to France it’ll be difficult for them – we have high unemployment.
“It’s also in Britain’s interest for many retirees to live in France because it helps reduce poverty in the UK. Many expats could not get by in the UK, which is a country with more inequalities than France. The rational thing to do – on both sides – would be to limit the damage as much as possible.”
Mr Moreau Defarges said there was uncertainty on how the UK’s exit plans will end. “The key will be the US. If Trump is a success as president, it will be very negative for Europe and will push the UK closer to him, so the gulf between the UK and EU will widen.
“In the worst-case scenario we could have a kind of ‘war’ – not a literal one – between the UK and EU, but I think good sense will prevail, not least because there will be pressure from the business sector to make sure exchanges between our countries are disrupted as little as possible.
“But Britain should have no illusions about its ‘special relationship’ with the US – it’s one in which the UK has to obey America, and that’s about it.”
