Pristine streets, beautiful alpine landscape, delicious chocolate and national banks with a greater value than the country itself!
Switzerland also sits outside the EU and the EEA but maintains a unique relationship with these economic groups whereby they enjoy extensive access to aspects of the European Single Market without being EU members. Interestingly, although Switzerland participates in free movement, it administers that movement through a permit system that differs from the arrangements that previously applied in the UK.
What is the Swiss immigration relationship with the EU, and could it also be applied to the UK?
Prior to leaving the EU, the UK had its own unique relationship with the EU, whereby it had the right of veto on any new amendments and had already used this veto to stay removed from the Euro and Schengen zone. One non-negotiable between the UK and the EU was the freedom of movement between territories for EU nationals and certain non-EU family members.
For the UK, this meant that EU nationals had a right to visit and temporarily remain in the UK for three months, and then beyond this time they could remain in the UK if they were ‘qualified’, which generally meant they were either economically active or self-sufficient. Since leaving the EU, EU nationals can visit the UK once obtaining an ETA permission, but to remain longer, they require a UK immigration visa.
Switzerland participates in the Agreement on the Free Movement of Persons (AFMP) with the EU and EEA, which means that similar to the UK’s former EEA Free Movement Regulations, an EU or EEA national can travel to Switzerland for a period of three months to visit, work or study with no visa.
However, unlike EU member states, in Switzerland, an EU national can remain in Switzerland beyond 3 months on either a short-term “L Permit” where a person has short-term employment of up to 12 months, or a longer term “B Permit” if they have a longer contract up to 5 years. The B Permit also includes people who are self-employed, students with comprehensive health insurance and sufficient means to support themselves and those who are self-sufficient from other forms of income or savings.
Neither the B or L Permits have specific minimum salary requirements, but the employers do need to show that the salary on offer to support the permit is consistent with local market rates. Permits would be refused to those who the Swiss authorities consider on a salary that is too low.
Therefore, like the UK, Switzerland allows EU members to visit for a short period of time, but then Switzerland has quite light-touch residence permits linked to employment or self-sufficiency.
There is substantial evidence that Brexit has reduced trade and investment relative to what might otherwise have occurred. The UK economy is around 80% services, and the key difference between membership of the EU and the EU-UK Trade and Cooperation Agreement is that the UK now experiences far more friction with trade, service access, labour mobility and regulatory integration than it did as an EU member state.
The EU Single Market is built on four inseparable freedoms: goods, services, capital, and people. Many businesses argue that the UK would benefit from better access to the first three but the UK cannot give itself freely again to the free movement of people. This is a non-negotiable for the EU and it remains politically difficult for UK leaders to advocate a return to free movement, so is the Swiss model of immigration a concession that the UK can make to achieve better access to the single market?
Or rather, what could be the effect of an increase in ‘economically active and self-sufficient’ EU immigration to the UK?
By the end of 2025, the UK experienced negative net migration with the EU of 42,000 people, meaning 42,000 more EU nationals left the UK than entered. Some voters would welcome this development, viewing it as a key objective of Brexit. Many Leave voters felt that the lack of enforcement of UK government originated rules on how EU nationals become qualified to remain longer in the UK meant that the EU was essentially in control of a large part of UK immigration. The EU didn’t want to negotiate any lessening of the freedom of movement for EU nationals with the UK in post-Brexit negotiations since it was one of the four fundamental freedoms.
However, after Brexit it became quickly apparent that EU nationals occupied many hard-to-fill roles across sectors such as logistics, hospitality, agriculture and social care. While there was a surge in migration to qualify for UK residence before the eligibility cut-off date, it became clear that there were labour gaps that would have been filled by temporary migration from the EU.
To accommodate these market gaps, the UK government expanded immigration routes in sectors facing labour shortages, particularly health and social care, which then resulted in an increase in migration from India, Nigeria and Pakistan principally.
Since Brexit, public debate about immigration has increasingly focused on issues of integration and social cohesion. This coincided with a significant shift in migration patterns, with migration from outside Europe increasing as migration from the EU declined. For many Leave voters, concerns centred less on particular nationalities and more on whether the UK government retained sufficient control over immigration policy. Their arguments concerned more the fact that it appeared the UK couldn’t restrict immigration, and immigration was often presented as a root cause of wider issues such as pressure on housing, public services and employment opportunities.
Could a relaxation of the immigration rules for EU nationals who can demonstrate economic activity in return for temporary visas be a way to plug gaps in the labour market, to encourage EU investment and trade, whilst also addressing concerns among some voters about the pace and scale of immigration-driven social change, or is the answer with the UK government’s current strategy to fill all labour market gaps by upskilling UK nationals – a strategy that is over a year in the making and yet to be introduced.
Answers on a postcard—although, post-Brexit, that postcard may now face a few more administrative hurdles on its journey.