The Windsor Framework Heralds a Breakthrough in EU-UK Relations

On February 27, European Commission president Ursula von der Leyen visited London to finalize an agreement with the United Kingdom that could signal a new era in the bilateral relationship. Dubbed the Windsor Framework in a nod to the British royal residence, the agreement primarily addresses lingering issues in the 2019 Northern Ireland protocol by reducing trade barriers. Though not the only difficult chapter in the separation, the trading border in Northern Ireland remains the most sensitive given its implications for peace on the island of Ireland. While several procedural and political hurdles lie ahead for both parties, the agreement is a positive first step toward mending years of acrimony following Brexit.

Q1: What is the Windsor Framework?

A1: The agreement aims to smooth the flow of goods between Northern Ireland and Great Britain while retaining Northern Ireland’s dual market access with the EU single market. This addresses shortcomings in the Northern Ireland protocol, which established a hard border in the Irish Sea to allow for Northern Ireland to remain in the Single Market—all in an effort to avoid a hard customs border being reestablished between Northern Ireland and the Republic of Ireland.

The two sides agreed to simplify border controls and reduce customs checks required by the protocol through the introduction of “green” lanes and trusted traders for goods from Great Britain intended to stay in Northern Ireland. Meanwhile, goods destined for the Republic of Ireland will still be subject to the standard customs checks required for goods entering the EU single market. UK authorities will make trade data available to EU officials in real time to enable this arrangement. This framework will also guarantee better medicine supply in the long term, which had been an issue since the EU-UK Withdrawal Agreement came into force. Brussels also made minor concessions on more specific trade rules applying in Northern Ireland, such as certain value-added taxes and alcohol duties.

Most notably, the agreement includes a mechanism whereby members of the Northern Ireland Assembly in Stormont (Belfast) can object to new EU rules on goods, customs, and agriculture if 30 or more members from two or more parties sign a petition. This “Stormont brake” can only be used for “significantly different” rules and once triggered, a UK veto on the rule means it cannot apply in Northern Ireland. In a major concession from Brussels, the Court of Justice of the European Union (CJEU) will not have oversight over the brake—though it remains the final arbiter of existing single-market rules in Northern Ireland. Importantly, the brake can only be triggered if a power-sharing agreement is in place in Stormont.

Q2: Why was a deal necessary for the people of Northern Ireland?

A2: The Brexit vote jeopardized the fragile equilibrium that has been established in Northern Ireland since the 1998 Good Friday (Belfast) Agreement (GFA) by potentially reintroducing a hard border on the island of Ireland. Indeed, the European Union played a crucial role in the signature of the GFA and has helped maintain an unsteady peace since. The removal of a hard border on the island of Ireland, made possible by EU membership, allowed for the free flow of people and goods, which defanged some of the violent nationalism that had fueled the Troubles. The power-sharing governance structure in Stormont also established a balance between Irish republicans and British unionists, safeguarding Northern Ireland’s connection to Europe, the Republic of Ireland, and Great Britain.

To prevent the reemergence of a hard border, the EU-UK Withdrawal Agreement established a dual market in Northern Ireland with access to both the British and the EU single market. However, it introduced inspections and customs checks at Northern Ireland’s ports instead of at the Irish borders, creating a de facto barrier between the province and the rest of the United Kingdom—weakening the protection of unionists’ interests laid out in the GFA. This separation from Great Britain also proved untenable to the Democratic Unionist Party (DUP), the largest unionist party in Stormont. It left the power-sharing executive in May 2022 vowing not to return until its concerns over the protocol were addressed. This has left the people of Northern Ireland without a representative body for close to a year, following years of instability in Stormont. The Windsor Framework aims to address these concerns and improve conditions for Northern Ireland consumers and businesses.

Q3: What led London and Brussels to reach an agreement after years of negotiations?

A3: Political and economic pressures in the United Kingdom, combined with a deteriorating situation in Northern Ireland and continued U.S. diplomatic engagement, enabled the Windsor Framework’s signature.

Successive conservative governments have failed to deliver on lofty promises of what the British economy would look like after Brexit and what concessions could be extracted from Brussels. The Global Britain strategy has failed to gain momentum, as London struggled to reach new global trade agreements or pick off individual EU member states that instead united behind a common negotiating position. The UK economy has contracted since 2019 and the United Kingdom showed the slowest economic recovery from Covid-19 out of all G7 countries. This economic reality is reflected in recent opinion polling: 45 percent of Britons now believe Brexit is going worse than expected, 84 percent think it is important to maintain a close relationship with the European Union, and improving trade arrangements for goods and services is seen as the top priority for Britain’s relationship with the bloc.

Prime Minister Rishi Sunak seems to understand these pressures; following the tumultuous tenure of Boris Johnson and Liz Truss—the latter short-lived—he has positioned himself as a competent technocrat and adopted a more pragmatic approach to the relationship with Brussels.

The war in Ukraine has also eased tensions by forging pan-European unity, as London and Brussels have coordinated on economic sanctions and weapons deliveries to Kyiv. Pressure from the United States likely also had an effect. After the announcement, U.S. president Joe Biden called the framework “an essential step to ensuring that the hard-earned peace and progress of the Belfast/Good Friday Agreement is preserved and strengthened.”

Q4: How will the deal affect EU-UK relations?

A4: The agreement marks a turning point in the bilateral relationship after years of acrimony. Prime Minister Sunak described the deal as “a decisive breakthrough” and President von der Leyen called it a “new chapter,” stating the European Union and the United Kingdom would “stand shoulder to shoulder now into the future.”

Brussels had been disinclined to make concessions to consecutive UK governments led by Brexit hardliners who aimed to remove all EU rules and oversight without bearing the consequences of being cut off from the single market. By adopting a less confrontational approach and a pragmatic attitude to negotiations, Sunak established stronger foundations for the relationship now and in the future, making room for Brussels’ red lines on single market integrity while unlocking dividends for Northern Ireland. This thaw in the relationship offers additional windfalls: upon approval of the framework, the United Kingdom will rejoin the Horizon Europe research program—a boon to UK researchers—and talks on a financial services memorandum, crucial for the City of London, will restart.

London’s newfound flexibility toward the European Union bodes well for closer cooperation in several policy areas, including scientific research and additional sanctions against Russia. From Brussels’ perspective, the deal represents an opportunity to stabilize relations with a key ally and trading partner amid the war in Ukraine, the energy transition, and other looming geopolitical challenges. This will also be a welcome development in Washington, which needs a united transatlantic community now more than ever.

Q5: What happens next?

A5: The first hurdle will be a political one in Westminster. A vote on the agreement will likely pass in the British parliament, as Sunak’s Tory backers and the Labour Party have already voiced their support for a potential deal. However, relying on opposition votes would be politically toxic for Sunak as he tries to unite his party behind a softer Brexit. Businesses and the people of Northern Ireland will likely welcome the deal, as will other UK citizens who have awaited a clean resolution of the breakup. But Brexit hardliners in the DUP and the Conservative Party will be displeased that Sunak maintained a role for the CJEU in Northern Ireland and dropped Boris Johnson’s controversial bill to unilaterally tear up the protocol. Johnson has already hinted that he would struggle to back the deal, sparking fears that a rebellion in the Conservative Party could revive ideological divisions that have paralyzed previous Tory governments.

The deal thus presents some risk to Sunak as he prepares for a vote in the House of Commons, which he said would happen at an “appropriate time.” Officials have noted that the agreement is unlikely to come into force for several months since Sunak needs time to sell the deal to Brexit hardliners within his coalition. Following meetings with officials in Northern Ireland, he stated that he would not press the DUP for “an instant answer.”

The next challenge will arise in Stormont. Most parties outside the DUP have expressed positive opinions on the framework and hopes that the DUP will support it and abandon its boycott of the power-sharing executive and assembly. However, the latter is grappling with contradictory political incentives: republican party Sinn Féin has now become the largest political party in the assembly—putting pressure on the DUP to rejoin the executive—while 41 percent of unionist voters think the DUP should not rejoin until the protocol is entirely scrapped. The political deadlock has prevented a functional devolved government for the people of Northern Ireland at the same time as the country is experiencing dire economic conditions.

In his first major test as prime minister, Sunak thus needs to rally his volatile Conservative Party coalition to secure a quite favorable deal and a path toward a more constructive bilateral relationship.

Otto Hastrup Svendsen is a research associate in the Europe, Russia, and Eurasia Program at the Center for Strategic and International Studies (CSIS) in Washington, D.C. Donatienne Ruy is the director of the Abshire-Inamori Leadership Academy and fellow with the CSIS Europe, Russia, and Eurasia Program.

Otto Svendsen
Research Associate, Europe, Russia, and Eurasia Program
Donatienne Ruy
Director, Executive Education and Abshire-Inamori Leadership Academy, and Fellow, Europe, Russia, and Eurasia Program