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

Andrew Glencross

Research output: Contribution to journalArticlepeer-review


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.

Original languageEnglish
Article number0
JournalBritish Journal of Politics and International Relations
Issue number0
Early online date16 Nov 2020
Publication statusE-pub ahead of print - 16 Nov 2020

Bibliographical note

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 (


  • Brexit
  • European Union
  • comparative federalism
  • differentiation
  • disintegration
  • federal safeguards


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