Evolving Unions: Brexit, Scotland, and the British Constitution

The United Kingdom is having an identity crisis. A fast-approaching March 29 Brexit deadline has thrown Prime Minister Theresa May’s government and Parliament into a state of prolonged chaos as Members of Parliament (MPs) from across the ideological spectrum cannot agree on any single direction. On January 15, the House of Commons rejected May’s proposed deal by 230 votes, the largest margin for a government in history. Beneath the surface of procedural jargon and party politics, major existential questions about the future of the UK in Europe continue to cause gridlock and uncertainty. Leaders of the oppositional political parties, mainly the Scottish National Party (SNP) and Labour have suggested a second referendum to reverse course and remain in the EU, though Labour is also internally divided over Brexit. In the daily political circus, an often forgotten issue is the territorial nature of the modern British system beyond the center of power in London and the consequences that Brexit holds for internal divisions within the plurinational union. This article comprises discussion of political contexts in Scotland which contribute to an ongoing Brexit divide, a brief examination of SNP discourses, and a consideration of Brexit’s impact on the territorial British constitution.

Scotland’s independent religious and educational institutions, in addition to a general lack of confidence in Conservative leadership, have shaped a distinctly Scottish political culture and complicated union with the rest of the UK. Scottish institutional representation in British politics was an incremental process throughout the 19th and 20th centuries, with the creation of a largely symbolic Scottish Office in 1885 in response to criticisms that Scotland was neglected by Parliament and civil service. Administrative devolution left a legacy of limited Scottish political autonomy as well as a national identity shaped by such autonomy and nationalism. Politically, devolution of some legislative powers from Westminster arose out of discontent with conservative government policies during the Thatcher era, reaching a turning point in 1997 when Tony Blair’s government held a referendum on the formation of a Scottish Parliament with tax-varying powers. The Scottish Parliament’s purpose was described by McHarg and Mitchell as “a defensive institution, designed to protect Scotland from Westminster Governments that sought to pursue policies opposed by [the] majority opinion in Scotland.” The Brexit outcome and subsequent implementation tests the absolute limits of this balance between devolved Scottish government and Westminster, as the majority opinion in Scotland has been overruled by the rest of the UK in both a political and constitutional sense.

Contrary to the traditional understanding of the British state, the UK is not a unitary state but rather an asymmetrical union of four nations: England, Scotland, Wales, and Northern Ireland. These unions developed over centuries with the English and subsequently British state absorbing Scottish, Welsh, and Northern Irish cultural identities without wholly replacing them. In the 2016 referendum, only England and Wales voted in majorities to Leave the European Union. Leave defeated Remain by a slim 52-48 margin overall whereas 62% of Scottish voters cast their vote to Remain in the EU. Scotland and Northern Ireland both voted in majorities to remain in the EU but have also expressed a desire to remain in the UK; now they cannot have both. The institutional unions between Westminster, Scotland, and Northern Ireland developed differently and gradually due to complex histories, however British internal politics adapted to plurinational unions with relative stability. According to James Mitchell of the University of Edinburgh, the changing relationship between Westminster and the UK’s component nations characterizes the UK “as a state of evolving unions […] Institutions may frame politics but people make choices as to how the institutions operate.” At the heart of Brexit lies this conflict among institutions and identities, processes of union and separation, and, above all, the constitutional adaptability and volatility of the British state.

As a regionalist political party within the parliamentary system, the original purpose of the SNP was to rally political support for Scottish independence. Ultimately, a 2014 referendum settled Scotland’s status as an independent country, resulting in a 55% “No” vote. Since 2014, the SNP’s vision seeks to advance the cultural notion of Scotland as distinct from the London-centric political establishment. As a center-left party, the nationalism encompassed by SNP rhetoric aligns with the EU and opposes the conservative and insular vision of the UK’s role in the European system. In a study of public opinion from the 1979 and 1997 referendums, Seth Jolly found links between pro-EU sentiment across Scotland and greater public support of devolution and independence. European integration is, therefore, a strategic benefit for an independent Scotland’s viability, not only as an institutional arrangement for trade but as an idea, as the EU provides an alternative to Westminster rule and traditional notions of English hegemony. This strategic relationship between Scotland and the EU is still a focal point for the SNP in the current Brexit debate.

The most principal actor in the formation of Scottish political discourse is First Minister Nicola Sturgeon, Theresa May’s counterpart as the leader of the Scottish Parliament and figurehead of the SNP across Scotland. Sturgeon has recently utilized her public platform to make clear that Scottish interests are not taken seriously by other UK political parties, therefore a renewed consideration of Scottish independence (in addition to a second Brexit referendum) should stay on the table post-Brexit. In a foreign visit to the United States in February, Sturgeon gave a speech on Brexit at Georgetown University’s Institute for Women, Peace and Security:

Scotland has a very proud European tradition. We see ourselves as a European country and people in Scotland by and large, perhaps in contrast with people elsewhere in the UK, don’t really see membership of the European Union as a threat to our own national sovereignty. […] But, amid the confusion and uncertainty of Brexit, one thing I think is clearer than ever. Scotland’s national interests are not being served by a Westminster system which too often treats Scotland as an afterthought, or too often sees our interests as not being material. In my view, they can only properly be served by becoming an independent country. But an independent country that then seeks to play its part in an interconnected world.

Framing Scotland as pro-Europe, culturally distinct from the rest of the UK, and inadequately represented in Westminster is consistent with the scholarly notion of the UK’s asymmetric union as well as the SNP’s political strategy, while the combination of these forces logically leads Sturgeon to steer discourse towards the direction of independence.

Since 2016, Twitter has become an especially relevant medium for the creation and dissemination of political discourse relating to Brexit, whether in the form of official statements, news, commentary, or jokes. MPs often post clips from their speeches in Parliament on social media in order to amplify their message among local constituencies in the Scottish political realm; however, Twitter can also extend beyond Scotland’s borders to shape the national debate. Vocal dissent amongst elected SNP MPs has brought attention to Brexit’s constitutional implications and Scottish grievances over perceived disempowerment due to the proposed Brexit deal going against the democratic will of Scotland’s Remain majority. Joanna Cherry, SNP MP for Edinburgh South West, bluntly described the power dynamic between Theresa May’s government and Scotland in a post on December 10, “Brexit has shown how unequal the Union of the UK is. The PM and her government have no respect for Scotland. Her #Brexit deal has failed and her government is failing. She must put the deal to the people. #PeoplesVote.” On January 21, Ian Blackford, SNP MP for Ross, Skye and Lochaber posted a clip from the House of Commons debate in which he framed Brexit as a precarious and existential situation: “We will not be dragged out of Europe by a Tory Government we did not vote for. We might not be able to save the UK but we can save Scotland. We have an escape route from the chaos of Brexit – an Independent Scotland.” Beyond just political difference on Brexit, the emphasis on the UK government’s authority to override Scotland’s Remain vote exposes the inherent power imbalances in the British system.

The official SNP Twitter account used similar language in a post on January 27: “We don't accept Scotland being dragged out of the EU against its will by a reckless, incompetent Tory UK government. Once the Brexit fog clears, the people of Scotland should have the right to look at a brighter future with independence.” The reality of a second independence referendum is unlikely, especially due to public fatigue with political instability and a complicated process for Scotland to hypothetically re-enter the EU as an independent country. However, the revival of SNP rhetoric about independence signifies not only strong political discontent with Theresa May’s government but a deeper frustration with the asymmetrical territorial distribution of power in the British constitution.

The largely unwritten UK constitution allows a wide range of flexibility to redefine the political fabric of the state, as legislation and convention can be rewritten, repealed, and reconsidered over time based on the governing political party’s interests. Unlike the United States Constitution, there is no single document that defines a unifying constitutional vision or clearly outlines the relationship between the central government and component nations. In the case of Brexit, the lack of a legal roadmap means that the UK is a “real-time experiment” in constitutional change. Scholarly understandings of the British constitution have changed significantly over time, as Vernon Bogdanor asserted in 1979 that the UK was “profoundly unitary” due to the supremacy and sovereignty of Westminster, in following decades a new understanding has emerged framing the UK as no longer unitary but perhaps still organized around the supremacy of the UK Parliament. Since 1999, devolution has allowed greater ambiguity in the constitutional arrangement between the UK Parliament and devolved legislatures. However, Brexit puts into question the nature of the territorial British constitution with semi-devolved powers.

A case that recently came before the UK Supreme Court shows competing constitutional visions in action. In R (Miller) v Secretary of State for Exiting the European Union, or otherwise known as the Miller case, the High Court determined that the UK Government may not unilaterally trigger the Article 50 procedure to formally exit the EU without Parliament’s approval in the form of legislation. The UK Government appealed the case to the Supreme Court which allowed the Scottish government to also claim their approval was necessary to trigger Article 50, due to “a fundamental alteration of the UK’s, and particularly Scotland’s, constitutional arrangements.” The Scottish government’s legal argument hinged upon the Sewel Convention, a principle “that the UK Parliament will not normally legislate on devolved areas without the consent of the Scottish Parliament.” The Court deemed the Sewel Convention not legally enforceable as a norm rather than a law, thus the European Union (Notification of Withdrawal) Act passed through Parliament in March 2017 without the approval of devolved governments. McHarg and Mitchell concluded, “Brexit will affect devolved decision-making and questions of constitutional voice, in terms of how much influence they are able to exert over the form that Brexit takes, or indeed whether it happens at all.” In practice, Scotland’s constitutional influence on Brexit has been significantly limited by the UK Parliament, setting the stage for an even greater degree of SNP rhetoric about disaffection, independence, and self-determination.

It is impossible to know exactly how Brexit will affect UK politics in the long-term. The British constitution is dynamic and adaptable, though the EU referendum has exposed significant fault lines in the union between Westminster and Scotland. If the next generations of Scottish voters continue to feel perpetually unrepresented by British politics and expelled from the EU against their will as SNP rhetoric suggests, the current union arrangement may be unable to resist popular mistrust indefinitely. Similar forces of anti-establishment politics that made Leave appealing to the disaffected UK electorate in 2016 could eventually influence another referendum on a Scottish exit from the UK. Though Scottish independence seems politically improbable and absurd, the idea of Brexit itself also would have been unimaginable only a few years ago. Constant change in British politics is part of its institutional design, and as time runs out on the March 29 Brexit deadline, spectators of Parliament will find that absurd and unlikely things can happen quite often.

The Puzzle of Scottish Independence and EU Membership

The possibility of an independent Scotland and its consequent European Union (EU) membership holds a plethora of issues and ambiguities left to be clarified. The issue at hand is that the Treaty of the European Union does not address how, or if, a region of a current member could obtain membership, if that region becomes independent. The impending ‘Brexit’further complicates this matter. This grey area of potential membership is increasing the demand for clarification regarding membership acquisition in light of the ‘Brexit’ and the growing instability of the European Union.  The potential secession of Scotland from the United Kingdom (UK) and entrance into EU membership poses a multitude of issues: defining the type of relationship an independent Scotland would have with the EU, what the process would be to become a member and how the process would manifest, and how the ‘Brexit’ affects Scotland’s want for membership.

There are contentious debates surrounding the Scottish need for departure from the UK and its subsequent reapplication to the EU. Some experts assert that an independent Scotland would only need to ratify a number of treaties to be a full EU member, while others state that Scotland would become a “third country” (a non-EU member) and thus would be immediately expelled from the EU.

Each theory has its discrepancies, and no one method has been defined as the clear course with which an independent Scotland should proceed. Furthermore, Scotland’s role in the EU will also be reintroduced within the context of the ‘Brexit.’ The outcome of the 2014 Scottish independence referendum was largely affected by the Europhile sentiments of the region and its desire to retain its EU role; thus, the ‘Brexit’ could trigger another referendum on independence that could result in Scotland preferring the EU to the UK. The EU-Scotland relationship needs to be defined, with a process for enacting that relationship decided upon, in order to present a clear future including EU membership to the Scottish people. By defining and asserting a clear path for Scotland, the EU can preemptively avoid any future issues such as drawn out negotiations or shocks to the EU economy.

Scotland’s want for independence is politically and economically based. The country, which has been ruled by the UK parliament since 1707, came under UK rule during a time of economic need, when insufficient supplies and catastrophic illness crippled the country. However, Scotland has matured in the modern age and is no longer in need of an economic system rooted in regional co-dependence. One of the primary arguments for secession is that Scots would gain political sovereignty (a wish that was only partially met by the creation of the Scottish Parliament in 1998. This furthered sovereignty would also have economic benefits, with increased economic freedom from UK obligations. However, both Scotland’s current political and economic standings are dependent on its membership in the EU. Scotland wishes to be politically independent in order to represent itself both to the world and to the EU specifically. With individual membership, Scotland would gain its own vote in EU matters; currently, the United Kingdom has a vote in EU matter, which represents the whole of the UK. In becoming an individual member, Scotland would be able to vote along the lines of its own interests and not merely be represented by the UK. Furthermore, economic independence would retain Scotland’s current dealings, while opening the economy per the wishes of the Scottish people. Thus, the question at hand is whether or not an independent Scotland could be a EU member in order to gain politically and economically.

The grey area surrounding an independent Scotland’s EU membership originates in the Treaty of the European Union (TEU). When the treaty was written, it had not been anticipated that a region of a Member State would attempt to secede, and thus the treaty has not identified the process concerning regions that have seceded from Member States. This means that, while there is a process in place for a member state to leave the EU, there is not one that specifically addresses a region such as Scotland. Thus, there is no predetermined legal process for Scotland that addresses what it would mean to secede from an EU member state. One viewpoint is that Scotland, by seceding from the United Kingdom, is exiting the EU. This is the opinion of former presidents of the European Commission, Prodi and Barroso, who described Scotland’s secession as an immediate withdrawal from the EU. This, however, is not economically or legally feasible because Scotland is economically intertwined with the EU, and Scots are currently EU citizens. An overnight expulsion of Scotland from the EU would devastate its economy as it is reliant on EU free trade — three of Scotland’s top five export partners are EU members. Member States are also entangled with the Scottish market, as they too gain from Scottish imports such as petroleum and chemical products. An expulsion of Scotland would manifest in the form of duties on its exports and imports, as well as the potential creation of export quotas for goods going into the EU. These restrictions would stress Scotland’s economy and potentially create barriers for EU countries seeking Scottish goods. Furthermore, Scots are EU citizens and to strip them of their citizenship overnight would be a harsh act that would leave many abroad without the freedom to cross borders, or at schools they can no longer afford. In addition to these entanglements, an immediate expulsion of Scotland would disregard the EU principle of sincere cooperation, diminishing Scotland’s right to the democratic process and the principle of continuity of effect. At any length, it appears that if an independent Scotland were to be considered a third country (non-member state) to the EU, it would be necessary to invoke Article 50 of the Treaty. Even if the EU considers the British exit to be Scotland’s exit from the EU, the exit itself would have to be negotiated over a two-year period to finalize all aspects of former EU dealings. However, a radically different view of Scotland has also been proposed.

The Scottish government, prior to the election, stated that an independent Scotland would be able to “take its place as a full Member State within the European Union”. This wording assumes Scotland’s current role in the EU as partial membership; it acknowledges Scotland’s role in the EU while recognizing that it soon will not be a member state. The government has elaborated on this matter by stating that, following a vote for independence, Scotland would enter negotiations with both the UK and the EU to ensure a smooth transition into independent EU membership. This method of negotiation is corroborated by a number of experts that define Scotland as a non-member actor in the EU. However, this relation to the EU, and the process as previously defined by the Scottish government, is dependent on the UK’s role as a member state.

The situation in Scotland was made more complex by the ‘Brexit’ vote. Many people have incorrectly assumed that the ‘Brexit’ would simply incite another Scottish referendum because of Scotland’s Europhile tendencies; however, Scotland’s plan, as stated in a government white paper, Scotland’s Future, is dependent on the UK as a member state. In the proposal for an independent Scotland, potential EU membership is defined as full membership, but with certain opt outs such as abstaining from certain EU norms that the UK currently abstains from. Specifically, Scotland will not pursue an entrance to the Eurozone or the Schengen Area, opting instead to continue using the pound and to keep its current Common Travel Area with the UK, The Republic of Ireland, Channel Islands, and Isle of Man. These two opt outs are radically affect by the ‘Brexit.’ Scotland now faces more questions concerning its potential EU membership including whether or not Scotland can mimic the Republic of Ireland’s opt out of the Schengen Area, and keep an open border with the UK, regardless of the Schengen’s external border resolution. The other, and more complicated, issue of currency will also need to be resolved. While Scotland has stated that it intends on continuing its use of the pound, it is questionable that as non-member the UK would allow its currency to be used by a separate country that willingly removed itself from UK jurisdiction. This topic has no precedent and would need to be determined by the UK Parliament. In addition to these technical conflicts, Brussels has ruled out the possibility of Scotland remaining in the EU while Britain leaves. The European Commission came to this conclusion in late June, with the intention of relaying that an independent Scotland would need to reapply for membership regardless of the timing of independence, since it will be a post-Brexit vote. However, this declaration too has loopholes and leaves Scotland’s future with more questions. It has been speculated that Scotland could follow in Greenland’s footsteps from 1982 when Greenland itself broke away from the EU, but its residents (Danish residents) and Denmark itself remained in the EU. In this situation, Scotland (which has voted to remain in the EU and predominantly voted against the Brexit) could use this precedent loophole to retain EU benefits that it has desperately been pursuing.

Scotland’s future is facing many contradictions in terms of its participation in the EU. Scholars and politicians cannot agree on the terms of a Scottish claim to EU membership or the process by which an independent Scotland could attain membership. The Brexit has further complicated the matter by forcefully beginning Scotland’s unwanted exit from the EU and the single market in particular. Indeed there is no clear path for Scotland at this time. The only clear aspect of this grey area is that Scotland wants EU membership and has proved so time and time again. It is a key player in, and depends on, the EU single market, and is prepared to fully add to the system by commissioning a full vote. Should Scotland have the opportunity to be a full EU member, it would do so whole-heartedly.

A Tale of Two Memberships: Scotland and Northern Ireland’s Possible Paths to EU Membership as Independent States

The Brexit referendum on 23 June 2016 brought 30 million voters (with a 71.8% voter turnout) to the polls to decide whether the United Kingdom (UK) would stay in the European Union (EU). The “Leave” campaign narrowly won with 52% of the vote; however, when split by countries in the UK, Wales and England voted to leave while Northern Ireland and Scotland voted to remain by much larger margins. Additionally, demographics with a higher income, more education, and younger age generally voted to remain. Although the referendum was not legally binding, the new Conservative UK Prime Minister, Theresa May, stated that she has committed herself to the will of the people and will guide the UK leaving the EU. However, Prime Minister May also said that she will not invoke Article 50 of the Lisbon Treaty, which gives the country two years to negotiate its exit with EU members, before the end of 2016. Thus, the UK would remain a full member of the EU until Article 50 is invoked and the UK begins negotiations to leave. Once negotiations are fully over, the UK will officially no longer be a part of the EU; however, until that time, the UK is a full-fledged member. When the UK leaves the EU, it will need to negotiate a new trade deal because it will no longer be a part of the EU single market. Thus, there is a possibility that the EU would instate trade tariffs because the UK would not be part of the single market.

Since Scotland and Northern Ireland both voted overwhelmingly to remain, one or both of the countries may leave the UK in order to stay in the EU. However, there are two paths for the different countries. Scotland only has one option if it wants to remain in the EU: secede from the UK and join the EU as a separate country. Northern Ireland has two options: it can unite with the rest of Ireland in the EU and become part of the EU by joining an EU member state, or it could leave the UK and try to become a member of the EU member. The best option for Northern Ireland to remain in the EU is unification. Otherwise, Ireland would go through the same accession process as Scotland, which will have a long, difficult road to EU membership, if it gets in at all.

Accession Process

As the UK now has to negotiate its exit from the EU, there are talks of Scotland and Northern Ireland leaving the UK to join the EU. If Northern Ireland were to join independently, it would join Scotland in the EU accession process.

The EU has strict criteria for membership: a country must have stable institutions that represent and ensure democracy, human rights and minority protection, and rule of law, a functioning market economy capable of dealing with competition in the EU market, and the ability to effectively implement membership obligations and to adhere “to the aims of political, economic and monetary union”. The first step to membership is an application for candidacy. Negotiations can only begin with a unanimous decision in the EU Council.

Accession involves 35 chapters relating to policy areas such as environment, rule of law, human rights, energy, and transportation. These chapters are non-negotiable, but candidates can determine how and when to adopt and implement them. Meanwhile, the EU receives guarantees on completion and effectiveness from the candidate country and from the Commission, which monitors implementation and benchmark requirements. Outside the 35 chapters, candidate countries also negotiate financial and transitional arrangements. The negotiations occur between representatives and ministers of the EU and the candidate country at what is called an intergovernmental conference. For each chapter, in a process called screening, the candidate country must meet the opening benchmarks before the chapter can be opened. Then, for each chapter, the candidate country must submit a position for negotiation while the EU adopts a common position and sets closing benchmarks for the chapter, which must be met before closing negotiations for that chapter. Some chapters have interim benchmarks that must be met. Thus, the length of negotiations may vary depending how prepared the country is to join the EU.

In closing negotiations, all negotiations for individual chapters must be finished. Details of membership, arrangements and deadlines, financial arrangements, and potential safeguard clauses are all in the Accession Treaty. The treaty has three steps to becoming a binding agreement: it must have the support of the EU Council, EU Commission, and European Parliament; the candidate and all EU member states sign it; the candidate country ratifies it according to their constitution. Once ratified, the candidate becomes an acceding country and will become a full member on the date agreed in the Treaty.

Scotland

In the event that Scotland secedes from the UK, the EU headquarters in Brussels stated that Scotland has to exit the EU with the UK and cannot remain on its own. Additionally, if Scotland were to secede before the UK leaves the EU, it would be leaving an EU country and thus be leaving the EU. Therefore, Scotland will have to go through the accession process as an independent country.

The accession process poses a number of problems for Scotland, mainly the length of the negotiations and its financial burdens and obligations. Due to the lengthy negotiations, Scotland would be on its own, neither in the UK nor the EU, for some time, which would hinder trade and investment. Additionally, Scotland’s projected country deficit is three times that of the UK, and Scotland would have a higher deficit than the UK does now. The EU limits the amount of debt and deficit its member states can have, and since the economic crisis and the Eurozone crisis, it will likely oversee these requirements more closely and ensure that its members adhere to them. Thus, Scotland might have to reduce their deficit in order to become a member of the EU. Additionally, as reported in 2015,, Scotland has 6.2% unemployment, compared to the UK’s 5.1%, and GDP growth of 1.9%, compared to the UK’s 2.3%. In addition to these potential economic problems, EU membership would be vastly more expensive for Scotland than it was under the UK because Scotland would lose the UK membership contribution opt-outs that Margaret Thatcher negotiated during her time as Prime Minister.

Another potential problem for Scotland’s EU membership is the potential problems regarding its referendum to leave the UK. The EU values democracy, rule of law, and human rights; however,many Scots were ineligible to vote in the referendum. Anyone who is a citizen of a Commonwealth country, the EU, or the UK living in Scotland was able to vote; however, Scots residing outside of Scotland were unable to register to vote. This could call into question whether the process was truly democratic, as some Scottish citizens could not vote in the referendum. This issue must be addressed during negotiations, and Scotland would have to comply with EU democratic ideals, as many Scots were unable to vote in a decision. Thus, looking at all of the problems with Scotland’s independent path to EU membership, it would take years, if not over a decade, to negotiate membership.

Northern Ireland

Given the difficulties that Scotland will face if they try to become an EU member on its own, Northern Ireland’s best path to EU membership is through unification with the rest of Ireland. Using the case of German unification after the fall of the Berlin Wall as a precedent for EU accession, if Northern Ireland becomes part of Ireland, it will enter the EU as part of a member state.

When East Germany and West Germany united, East Germany gained from joining the EU because it “could rely on the tried and tested rules and institutions, the West German social market economy and immediate access to large amounts of financial resources”. Unification inspired high expectations, and East Germany gained advanced, sophisticated institutions and administrators. Unification eliminated most of the legal barriers regarding sovereignty, which usually delay establishment of institutions and full EU membership. However, there was a cultural difference between the two Germanys, and institutions were established on top of East Germany’s previous institutions.

There is still a divide between the two sides of Germany in terms of economic prosperity. After ten years of membership, labor productivity was still 60% of that of West Germany. There has been moderate improvement since unification, though. In 1991, East German income per capita compared to West Germany was 40%, and in 2016, East German income per capita compared to West Germany reached two thirds. Due to Soviet occupation for over forty years, East Germany has a higher level of social distrust than its Western counterpart, which plays a role in its development and integration in the EU. Overall, the economic gap between Germany and East Germany has significantly decreased despite remaining differences.

Although the German unification was successful, it highlights potential problems for Northern Ireland to light. Aside from cultural, religious, and historic tensions between Ireland and Northern Ireland, Northern Ireland might not be as developed because it would not go through the negotiation process or receive EU funding for meeting set benchmarks. However, Northern Ireland has been a part of the EU as long as the UK has, so it has the infrastructure required. Additionally, Northern Ireland was not under Soviet rule and has been developing alongside the rest of the UK and Ireland. Given the minor economic differences between the two countries, Irish unification would be the best option for Northern Ireland to remain in the EU.

Conclusion

Although Brexit will likely have a negative economic effect on the United Kingdom, the country is large and developed enough to thrive regardless of its EU membership status. However, if Scotland opts for independence, it will struggle while if Northern Ireland unites with the rest of Ireland, it will continue on its path in the EU. In particular, Scotland trades more with the rest of the UK than any other country, dwarfing its exports to non-UK countries by comparison. Looking at other economic indicators like deficit and debt, Scotland’s independence would likely increase borrowing and decrease economic stability and security. As Scotland relies heavily on its robust banking sector, the decrease in stability would lead to less investment and fewer banks in the country. As a result, Scotland would regret leaving the UK because the UK would remain stable and prosperous, as it could get products that usually come from Scotland elsewhere. In addition to economic instability, the likely lengthy amount of time it would take to join the EU, if at all, should dissuade Scotland from independence. With neither the UK nor the EU, Scotland would be a small country of just over 5 million with an unstable economy and decreased trade, investment, and movement of human capital. These consequences should, if Northern Ireland were to pursue independence, persuade Northern Irelanders to unite with the rest of Ireland and join the EU upon unification. Northern Ireland has a simpler path out of the UK and into the EU than Scotland, so it would likely not have a major effect on the economy other than changing currency.