Norms, institutions, and the limits of post-Brexit bilateralism: A case study on UK-German relations

Since Brexit, the United Kingdom has sought to recalibrate its relations with European Union member states through intensified bilateralism. While Brexit advocates portrayed this as an expression of regained sovereignty, the EU profoundly shapes post-Brexit bilateralism through the Withdrawal Agreement and Trade and Cooperation Agreement on the one side, and the terms of membership on the other. This paper addresses the question if and in what way EU norms and institutional procedures also shape the UK’s bilateral relations with member states. Grounded in regime theory, this research conceptualises post-Brexit bilateralism as a form of nested regimes within a broader European regime complex with the EU at its centre and multiple points of overlap that allow for both legal and normative influence. The analytical focus is on the extent to which the UK’s bilateral regimes are shaped by EU procedural norms – particularly consensus-seeking and the so-called coordination reflex – and how these interact with the UK’s post-Brexit emphasis on sovereignty and autonomy. This is empirically explored in a case study on UK-German relations, which emphasises the practical relevance of the theorised normative factors. To put their effect in context with the EU’s legal influence on bilateral relations, the analysis zooms in on three policy areas in which the EU’s treaty-based competencies vary: i) trade (high), ii) research and higher education (medium), and iii) security and defence (low). Data is drawn from elite interviews with senior policymakers, diplomats, and experts in both the UK and Germany alongside official documents and public statements from both governments since the Brexit vote in 2016.