Managing Differentiated Disintegration: Insights from Comparative Federalism on Post-Brexit EU-UK Relations


This article applies insights from comparative federalism to analyse different models for managing future EU–UK relations. The argument is that the stability of the EU–UK relationship before as well as after Brexit is best understood by examining the presence of federal safeguards. Drawing on Kelemen, four types of safeguards are identified as the means for balancing centrifugal and centripetal forces. During the United Kingdom’s European Union membership, the strong glue provided by structural and judicial safeguards was undone by the weakness of partisan and socio-cultural ones. However, each post-Brexit scenario is characterised by weaker structural and judicial safeguards. The most stable outcome is an indeterminate Brexit that limits the incentive to politicise sovereignty and identity concerns by ending free movement of people and reducing the saliency of European Union rules. Such stability is nevertheless relative in that, from a comparative perspective, federal-type safeguards were stronger when the United Kingdom was still in the European Union.

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Divisions: College of Business and Social Sciences > School of Social Sciences & Humanities > Politics, History and International Relations
Additional Information: This article is distributed under the terms of the Creative Commons Attribution 4.0 License ( which permits any use, reproduction and distribution of the work without further permission provided the original work is attributed as specified on the SAGE and Open Access page (
Uncontrolled Keywords: Brexit,European Union,comparative federalism,differentiation,disintegration,federal safeguards,Political Science and International Relations,Management, Monitoring, Policy and Law
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Related URLs: https://journal ... 369148120968516 (Publisher URL)
http://www.scop ... tnerID=8YFLogxK (Scopus URL)
PURE Output Type: Article
Published Date: 2020-11-16
Published Online Date: 2020-11-16
Accepted Date: 2020-09-28
Authors: Glencross, Andrew (ORCID Profile 0000-0001-8320-9181)



Version: Published Version

License: Creative Commons Attribution

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