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What are the people implications of Brexit under a no-deal scenario compared to what is likely to happen if a deal can be reached? Download our full analysis of the implications for employees, including the impact on the right to travel and work across the EU, employment rights and social security.

In summary

  • Little change is expected to UK employment rights in the immediate to short term on Brexit whether or not a deal is reached.
  • A ‘No-deal’ scenario is likely to have an immediate impact on employee mobility and European Works Councils but not on employment rights more generally.
  • In a ‘No-deal’ scenario, EU citizens in the UK on or before Exit Day will be able to apply to remain using the new EU Settlement Scheme, but there will be no EU-wide scheme for dealing with UK nationals in the EU who will need to check what arrangements have been put in place by their host jurisdiction.
  • If a deal is reached, there will be a transition period during which all EU employment law and free movement rights will continue to apply.
  • Despite long term scope for future watering-down or dismantling of EU-derived worker rights, this is not the current UK government’s stated intention and any future trading agreement may involve some form of continuing commitment to shared employment standards.




Stephen Ratcliffe is a partner in Baker McKenzie's Employment and Benefits practice in London. He has more than 14 years of legal experience and was recognized as an "Associate to Watch" by Chambers & Partners in 2014, 2015 and 2016 before his promotion to partnership. Stephen has been described as "very precise, technically excellent, but also very practical."


Tony Haque is a senior associate with over 20 years' experience advising in all areas of UK immigration and nationality work, and related European Union law. He is a member of Baker McKenzie’s Global Labor Employment and Employee Benefits Practice Group, where he advises on related corporate, tax and labor law issues, and leads the Firm's Global Immigration & Mobility department in London. Tony is an appointed member of the Law Society's Immigration Law Committee which provides expert guidance to practitioners and seeks to influence the direction of policy. He is recognized as a leader in his field by all of the main UK legal directories including Chambers & Partners, Legal 500, Legal Experts, Global Counsel 3000 and A Who’s Who of Corporate Immigration Lawyers.