IfG INSIGHT | MAY 2020

A four-nation exit strategy
How the UK and devolved governments
should approach coronavirus
Akash Paun, Jess Sargeant and Alex Nice

Summary
The coronavirus crisis has required a co-ordinated response between the UK anddevolved governments.
The devolved governments of Scotland, Wales and Northern Ireland are responsible forkey public services affected by the pandemic, including the NHS, education and public
transport, and for implementing the lockdown within their territories. For these matters, acommon approach cannot be imposed by UK ministers, and instead can only be achieved
through agreement.
In the early stages of the pandemic, there has been close co-ordination between the four
administrations. There have been some differences in policy and guidance, but on the big
issues, including the lockdown, the governments have been on the same page.
As the UK enters its sixth week of lockdown, the four governments are beginning to think
about the ‘exit strategy’ from the unprecedented restrictions on personal freedom andother temporary policies imposed to fight coronavirus. Since key powers used in the
pandemic response are devolved, this could potentially lead to divergence between thefour nations, with, for example, restrictions changed sooner in some places than in others.
A co-ordinated exit strategy would be preferable. But co-ordination is not the same ashomogeneity, and a UK strategy is not the same as a UK government strategy.

1

A FOUR-NATION EXIT STRATEGYIntroduction: a four-nation exit strategy
The UK exit strategy will be a combination of:•decisions taken in Westminster that apply across the whole of the UK•

decisions taken collectively between the four governments•

decisions taken separately in the four national capitals.

Although some difference between what happens in the four nations could create
logistical problems and public divisions, there are some legitimate reasons why this
could take place. Several other countries, such as Spain and Italy, have implemented
geographically variable lockdown rules in line with variation in the public health threat.
In the UK, the law requires ministers in each of the nations to lift lockdown restrictions
if they are “no longer necessary”. So if the pandemic is brought under control sooner in
one part of the UK than in others, then this could lead to ministers easing the lockdown
in that territory sooner than elsewhere.
Ministers in the four governments might also reach legitimately different judgments
about the acceptable trade-offs between health, economic and wider social factors,
leading some to favour an earlier easing of restrictions.
Particular considerations apply in Northern Ireland, where economic and healthproblems could arise if significant policy differences emerge on each side of the Irish
border. In this eventuality, there might be a case to align on some matters more closelywith Dublin than London.
What would be undesirable is if different decisions are taken in different parts of thecountry in an ad hoc way, for purely political rather than evidence-driven reasons, orwithout clear communication about what is happening and why.
Already, there have been some problems in communicating with the public about
whether certain policies and announcements apply UK-wide or only in England. Thishas caused confusion, for instance about free school meals, business rates relief
and coronavirus testing targets. Significantly different rules applying in the different
UK nations could also be regarded as unfair, leading to a loss of public consent, andundermining compliance.
Devolved administrations also do not have all the necessary levers to allow for markedly
different approaches. In particular, Westminster control over big economic schemes tosupport business, as well as ports and borders, limits the scope for divergence.
Any variation between the nations should be based on a shared evidence base, open
communication and collaboration between the governments, and transparency about how
decisions are being taken to enable the accountability of ministers in all governments.
The four governments will need to make plain in public and parliamentary debates
which rules will apply where, and why any differences in approach are being taken.
2

A FOUR-NATION EXIT STRATEGYCoronavirus has required a four-government response
The coronavirus pandemic is a global crisis that has hit all parts of the UK and
has required a nationwide response. This has involved not just the government at
Westminster but also the devolved administrations in Edinburgh, Cardiff and Belfast,
who hold many of the policy levers that have been pulled in the fight against thedisease (see Annex: Table of coronavirus measures).
The UK government is responsible for many big economic and fiscal functions that
operate across the UK. Therefore, the key measures introduced by Westminster
to support the incomes of those affected by the shutdown operate on a UK-widebasis. These include the Coronavirus Job Retention Scheme, which provides 80%
of employees’ salaries up to £2,500 a month, the Self-Employment Income Support
Scheme, and enhanced sick-pay and welfare entitlements. Some support for businesses
has also been provided by the UK government across the country, including thedeferral of VAT payments, the purchase of the short-term debt of large enterprises, andgovernment-backed loans for small businesses.
But the devolved governments are responsible for several key public services affectedby the pandemic, including the NHS, social care, education, and public transport, as well
as for important functions such as ensuring food supply and supporting local economic
development. In Scotland and Northern Ireland, policing and justice are devolved too.
Most significantly, the regulations that imposed a ‘lockdown’ of the country to slow
the spread of the Covid-19 virus were made under public health legislation. As healthis a devolved matter, the UK government, in legal terms, only imposed the lockdown
in England. In Scotland, Wales and Northern Ireland, the lockdown was imposed byseparate, but very similar, regulations introduced by the devolved administrations.1

The four governments have worked closely together in the first phaseof the crisis
The fact that health is a devolved matter, and a large part of the legislative framework
to manage the pandemic has been implemented on a devolved basis, creates thepotential for different responses to the crisis in the four nations. It also means thata common approach cannot be enforced by UK ministers, but can only be achieved
through co-ordination and agreement.
During this crisis, co-ordination between the UK and devolved governments is being
facilitated in a number of ways. The leaders of the devolved administrations attend
COBR (‘Cobra’) meetings, and meet the prime minister (and in recent times, his deputy)on an ad-hoc basis. The devolved administrations are also represented on the cabinet
committees created by the UK government to respond to the crisis.2
There is close co-ordination between the chief scientific advisers (CSAs) and thechief medical officers (CMOs) of the four administrations. The latter group meet aminimum of three times a week and are supported by clinical groups who meet
regularly on a four-nation basis.3
3

A FOUR-NATION EXIT STRATEGYAll three devolved administrations participate in the Scientific Advisory Group for
Emergencies (SAGE) structure;4 Scottish and Welsh governments have their own advisorygroups, but their primary purpose is to apply modelling developed by SAGE to theirown contexts – and both chairs are members or attendees of the UK-wide group. As aresult, the scientific advice given to ministers in each part of the UK is consistent.5 Thisappears to have worked reasonably well, although it has been reported that the Scottish
government is unhappy about the status of the Scottish CSA at these meetings.6
The four governments have been in broad agreement on the strategy for responding
to the coronavirus in the first phase of the crisis. In early March, a joint ‘action plan’
was produced, a rare example of a government document with all four administrations’logos on the cover.7 There has been a similarly unusual level of co-ordination between
the health services of the UK, while the UK government has also sought to lead afour-nation approach to procuring personal protective equipment (PPE) and increasing
testing capacity.*
Whitehall departments such as the Department for the Environment, Food andRural Affairs (Defra) have worked closely with devolved counterparts on issues
such as ensuring food supply and supporting the agriculture sector. The intenseintergovernmental working that took place during the no-deal Brexit preparations in2019 (as part of Operation Yellowhammer) has reportedly proven useful, as it led to thestrengthening of relationships and channels of communication between officials in the
different capitals, including in key areas such as civil contingency planning.
The Coronavirus Act 2020, which conferred powers on all four UK governments to tackle
the pandemic, was similarly the product of close intergovernmental collaboration.
Officials from across the UK worked together to ensure that the bill was drafted to meetthe needs of each administration, and the bill was swiftly given consent (under the
Sewel Convention)** by all three devolved legislatures.
The closure of pubs and restaurants and, shortly after, the decision to impose
lockdown were also tightly choreographed between the four governments, with initial
announcements by the prime minister followed by similar statements by the devolved
leaders. In some cases, co-ordination has been looser, but the outcome has been thesame. For instance, all four governments separately announced the closure of schools
within their territory on the same day, a few hours apart.

*

**

4

Although the devolved administrations are also allowed to procure their own equipment. See for example:
Scottish Government, ‘Coronavirus (COVID-19) update: Health Secretary’s statement 21 April 2020’, Scottish
Government, 21 April 2020, retrieved 29 April 2020, www.gov.scot/publications/coronavirus-covid-19-updatehealth-secretarys-update-tuesday-21-april-2020
The Sewel Convention is the commitment by the UK parliament not to legislate in devolved areas without
the consent of the devolved legislature or legislatures in question, see www.instituteforgovernment.org.uk/
explainers/sewel-convention

A FOUR-NATION EXIT STRATEGYSome small differences in the four governments’ approaches have emerged
However, there have been modest instances of divergence.
In some cases, this has arisen as jointly agreed strategies have been interpreted andtranslated into detailed guidance by each administration. For example, in Scotland
the construction industry was advised to stop all but essential work, while in Englandand Wales work of a similar nature was allowed to continue if workers could practisesocial distancing.8
In other cases, divergence can be attributed to local political and economic factors. For
instance, the Scottish government announced financial support for Scottish sea fisheries
just days after the lockdown began, a full month before the UK government created asimilar scheme for England, reflecting the sector’s greater importance in Scotland.9
Schemes to support small business also vary in some respects. England, Scotland andWales have all granted year-long business rates holidays, but the Welsh government
has limited entitlement to the holiday to properties under the value of £500,000. It has
used this money to fund grants for small and microbusinesses instead.10
Some examples of policy divergence have been short-lived, and quickly followed bydecisions to bring one part of the UK in line with others. For instance, in the early phaseof the crisis, the governments in Scotland and Northern Ireland halted all new jury trials“until further notice”, whereas the UK government initially continued to allow short jury
trials. This gap was closed a few days later, when the lord chief justice announced that
there would be no new jury trials in England and Wales either (England and Wales are a
joint legal jurisdiction).11
Similarly, when lockdown was imposed, off-licences in Northern Ireland were initiallyrequired to close, but were classed as essential businesses in other parts of the UK. Days
later, the Northern Ireland executive amended its guidance to allow them to re-open.12
More recently, on 28 April, Scotland advised people to wear face masks in public inlimited circumstances as a precautionary measure.13 However, in response to theannouncement, the UK health secretary, Matt Hancock, said that the UK government’s
position had not changed and that there was “weak science” on the use of facemasks.14
Two days later, the prime minister said that face covering could be “useful” as lockdown
measures are eased, “both for epidemiological reasons but also for giving people
confidence that they can go back to work”.15 This example shows how assessments ofthe same scientific evidence can lead to different political judgments.
As the UK steps up plans for its exit strategy, more difficult political decisions, andpotentially greater opportunity for divergence, may lie ahead.

5

A FOUR-NATION EXIT STRATEGYThe UK government and media have been vague about where policies apply
One aspect of co-ordination that has not always gone smoothly has been thecommunication about the parts of the country to which certain policy decisions apply.
The problem stems from the tendency of the UK government, and London-based media,
to be unhelpfully vague about whether particular announcements relate to England, thewhole UK or (in some cases) England and Wales.
This problem arose in March when the Treasury provided funding for business rates
relief, but it was not initially made clear that this applied in England only, and that
additional resources would be given to the Welsh government to create its own scheme.
This reportedly caused confusion in Wales.16
Similarly, in early April, the UK government announced that free school meals for
disadvantaged children would continue to be provided, via a voucher scheme, during
the Easter holidays. But neither the government guidance on how to access the voucher
scheme,17 nor national media coverage of the policy,18 made mention of the fact that
this applied in England only. Hardly surprisingly, this was reported to have caused
confusion among parents in Wales, where London-based newspapers are widely read.19
One final important example relates to the UK health secretary’s stated aspirationthat 100,000 Covid-19 tests should be carried out per day by the end of April. When
first announced, this was expressed as a UK-wide target, with the intention being that
Public Health England would lead a co-ordinated strategy involving the devolved
administrations.20 However, there were then mixed messages from Whitehall and
Edinburgh about whether this pledge was in fact for England only.21
The Scottish and Welsh governments subsequently announced their own plans for
scaling up testing, but the Scottish first minister, Nicola Sturgeon, pointedly distanced
her government from the 100,000 figure, stating that “it’s not for me to set out the basis
behind the UK government’s target, or how it plans to get there”.22 On 1 May, the healthsecretary announced that the target had been achieved, and by this point it was clearthat the 100,000 figure was for the whole UK, although it was also reported that the UK
and Scottish governments were running parallel, and slightly different, testing regimes.23
These examples illustrate that even when the UK and devolved governments arebroadly on the same page, there is potential for confusion. This may become an evengreater risk, if greater differences between the four governments emerge.

6

A FOUR-NATION EXIT STRATEGYThe four governments could take different approaches
to their exit strategies
The simultaneous imposition of the lockdown, and other measures, by the four
governments may have created an expectation that these interventions in people’s lives
will likewise be brought to an end at the same time across the country. But as the crisis
eases, and the UK moves back towards normal politics – as well as normal life – there is
no guarantee that the four governments will continue to march in lockstep. This raises
the possibility that the ‘exit strategy’ from lockdown may unfold in different ways or on
different timelines, in the four UK nations.*
In theory, the UK government could seek to impose a common approach to the exit
strategy across the entire UK by passing an Act of Parliament that imposed new
obligations or constraints on the devolved administrations. However, to do so without
their consent would be regarded in Edinburgh, Cardiff and Belfast as an assault on the
devolution settlements.
Even if this were politically palatable, it is hard to imagine why it would be necessary,
given the willingness of the devolved governments to work with Westminster. Far betterto keep the devolved governments closely involved in UK-wide decision making, while
accepting the possibility of some variation in how different parts of the country return
to normality.
There may be legitimate reasons for different parts of the country to move at different
speeds – especially if there is clear evidence that the public health risk from thecoronavirus has fallen substantially in some places, while continuing to pose a greater
threat elsewhere.
A geographically differentiated strategy in the UK would not be without international
precedent. Several other countries, including South Korea and Australia, have responded
to the pandemic in such a way:24•

The government of South Korea applied containment strategies with continued
contact-tracing in areas with low infection. In infection hot-spots, such as Daegu andCheongdo, response measures were more focused on mitigation strategies to slow
the spread, rather than tracing all contacts.25•

Different states in Australia have imposed and lifted restrictions – which in somecases have included effectively closing state borders – at different times, reflecting
different levels of infection across the country.26•

Regional governments in Germany have applied different rules in some areas, suchas mask-wearing, depending on the local level of infection.27 Decisions on school
openings have also varied.

*

The UK government could also decide to vary the exit strategy on a regional basis within England. For a discussion,see: Tetlow G, Owen J, Pope T and others, Lifting Lockdown: How to approach a coronavirus exit strategy.

7

A FOUR-NATION EXIT STRATEGY•

Italy imposed its lockdown in stages, starting with certain municipalities in thenorthern region of Lombardy in February. It extended the quarantine measuresacross the country in early March. The Italian government has subsequently sought
to keep restrictions uniform across the country, but the Veneto region has eased
certain measures before the rest of the country.28•

Spain is lifting restrictions first on smaller islands. The government plans to take aphased approach to deconfinement on the mainland, depending on local conditions.29

Ministers in the different capitals might reach different decisions – forlegitimate reasons
In the end, ministers in each of the four governments will separately make – and be heldto account for – many of the key decisions relating to the exit strategy within their own
territories. The leaders of all the devolved administrations have floated the possibility ofdiverging from the rest of the UK, should the evidence support this.
As Nicola Sturgeon put it on 17 April: divergence in Scotland could be justified “if theevidence and the science tells us that because we are all at different stages of theinfection curve we might need to do things slightly differently”.30 Northern Ireland’s
first minister, Arlene Foster, said that we could see “different parts of the United
Kingdom move in different times to other parts” if the criteria for lifting lockdown
were met.31 Welsh first minister, Mark Drakeford, has been more cautious, suggestingthat his government’s strategy could differ “at the margins” while emphasising that“a UK way of doing things remains a strength.”32 On 4 May, he went further, declaringthat “a four nations approach works best for Wales” and that the four governments
should “begin to lift lockdown through a set of common measures implemented to acommon timetable”.33
Ministers in each of the four administrations are legally required to review the need forthe lockdown restrictions within their territories at least every 21 days. This provision is
written into the four governments’ respective regulations that introduced the lockdown.
If this review leads any of the four administrations to the conclusion that any of therestrictions are “no longer necessary” to fight the spread of coronavirus, then they
are compelled to terminate the rules in question.34 This means that if clear territorialdifferences emerge in the threat level posed by Covid-19, then this could lead toministers easing the lockdown in that territory sooner than elsewhere.
It is also possible that ministers in the four governments will reach legitimately different
judgments about the acceptable trade-offs between health, economic and wider social
factors, leading some to favour an earlier easing of restrictions. Additionally, industries
with particular significance in one nation or another – agriculture in Wales or fisheries in
Scotland, for instance – might successfully lobby the devolved administrations to offer
additional financial support, or an earlier loosening of some restrictions.

8

A FOUR-NATION EXIT STRATEGYSpecific considerations apply in Northern Ireland, where shared geography and a highlevel of cross-border movement create a need for close co-ordination with the Irish
government as well as the other governments of the UK. Public health experts havemade the case for an all-island strategy, including a common approach to community
testing and controls at ports and airports to contain the virus.35
There has already been significant north–south co-operation to provide for elementsof a joined-up response that recognises the idea of Ireland as a single epidemiologicalunit. For instance, the chief medical officers of the two governments have a weekly
teleconference and the respective health departments signed a Memorandum ofUnderstanding on how to “promote cooperation and collaboration in response to the
COVID-19 pandemic”.36 There have also been discussions on travel restrictions acrossthe two parts of Ireland, and an attempt at joint procurement of PPE.
The Irish government has already announced a phased approach to easing restrictions
and reopening the economy, with a provisional timeline for each phase to commence.37
If the UK decides on a substantially different exit strategy, for instance in allowing
schools and workplaces to reopen at different times, then Northern Ireland might facea dilemma about which path to follow. This, inevitably, has the potential to open up
divisions within the Northern Ireland executive, with the nationalist Sinn Féin leaning
instinctively towards an all-Ireland approach, and the Democratic Unionist Party (DUP)
looking to Westminster.
Co-ordination between the four nations on the UK exit strategy is a sensible aspiration.
But co-ordination is not the same as homogeneity, and the UK exit strategy is not thesame as the UK government exit strategy.
The overall strategy will be a combination of decisions taken in Westminster that do
apply across the whole country (for instance those relating to support for businessand employees), decisions taken collaboratively between the four governments, anddecisions taken separately in the four national capitals. Whether devolved ministers
choose to align their exit strategies with Westminster or not, they will be held toaccount for these decisions by their respective legislatures, and voters.

9

A FOUR-NATION EXIT STRATEGYThe UK and devolved governments are now developing their own frameworks
for exit strategy decisions
On 16 April, the UK government set out “five tests” that it will use to assess the rightmoment to adjust lockdown measures.*,38 As with other announcements made during
the crisis, it was not initially clear whether these tests were intended to apply across the
UK or in England, or whether they had been agreed with devolved counterparts.
In subsequent government documents, the tests have been spelt out as follows:
1. The NHS has sufficient capacity to provide critical care and specialist treatmentright across the UK.
2. A sustained and consistent fall in daily deaths from coronavirus.
3. Reliable data to show the rate of infection is decreasing to manageablelevels across the board.
4. Operational challenges including testing and PPE are in hand with supply
able to meet future demand.
5. Confident that any adjustments to the current measures will not risk asecond peak of infections that overwhelms the NHS.39
The tests make reference to the whole of the UK, and have been presented by ministers
and officials alongside UK-wide data. However, it does not appear that they have been
agreed with the devolved governments, who, as discussed, are responsible for lifting
the social distancing restrictions and managing the NHS within their own territories.
The Scottish40 and Welsh41 governments have also both published substantial
documents setting out how they will take their own decisions about releasing lockdown
restrictions. In terms of substance, the plans are largely consistent with the five tests.
Both refer to considerations like healthcare capacity, evidence of a decreased infection
rate, and supply of PPE and testing equipment as key measures in assessing whether
lockdown can be eased.
There is some variation in the emphasis of key messages. The Scottish government
talks about the impact on the care system as well as the NHS and is more explicit
in discussing the possibility that restrictions may have to be re-imposed if there isevidence that transmission is not under control. The Welsh government paper highlights
international experience as a key factor that will guide its thinking.
It is noteworthy that the Scottish and Welsh administrations decided to publish theirown documents, rather than producing a common framework with the UK government,
as this contrasts directly with the joint plans published at an earlier phase in the crisis.

*10

For our assessment of the viability of the UK government’s five-tests approach, and other aspects of its approach
to its exit strategy see Lifting Lockdown: How to approach a coronavirus exit strategy.

A FOUR-NATION EXIT STRATEGYOverall, however, there is nothing to suggest that major divergences in strategy lie
ahead. The Scottish government commits to continue to take part in “the UK four
nations expert advisory groups and collective decision-making process”42 and theWelsh government states its preference “that all four nations retain a common approach
to lifting the restrictions”.43
One reason why the Scottish and Welsh governments published these documents was
to demonstrate a commitment to greater openness than Whitehall, and a willingness
to engage in public debate about these important matters. Until the UK government
provides further detail on its planned approach, it is hard to assess whether theserecent developments might presage the start of a period of greater divergence
between the UK nations. The Northern Ireland executive is yet to set out its approachto leaving lockdown.
In any case, at this stage all any government has done is outline how it intends toapproach decision making in this difficult area – the real test of the four-nation
approach will come when those decisions are actually made. On 30 April, in Boris
Johnson’s first press conference after returning from his own recuperation from
Covid-19, he committed to publishing a “comprehensive plan [to] get the economy
moving” the following week, and to build “maximum political consensus as we produce
it across all parties and across the U.K”.44 Whether the prime minister is able to achieve
this ambition will be a determinant in whether the four-nation strategy will hold.

Divergence in the exit strategy could create confusion and non-compliance –especially if poorly communicatedWhile there are certain reasons why a geographically differentiated exit strategy could
make sense, there are potential downsides too.
First of all, there is a potential for confusion among the public and business about whichrules apply where. As discussed above, UK ministers and departments have not always
been clear about the territorial scope of different policy announcements, which has
caused confusion and some tensions with the devolved governments. Getting this rightin the next phase will be crucial.
So if there is to be any differentiation in the exit strategy, UK ministers and departments
will need to be precise in their public communications, stating explicitly whether decisions
apply only to England, to the whole UK, or to some particular subset of the UK nations.
If ministers at Westminster wish to set a strategy or target for the whole UK that
relates to devolved functions, then they should first reach agreement on this with theirdevolved counterparts. Conversely, if the devolved governments decide to opt out of
UK-wide approaches, then it will be for them to explain to their citizens in what ways,
and for what reasons, they have chosen to diverge.

11

A FOUR-NATION EXIT STRATEGYEven when communications are clear, variable restrictions on business and citizens
could generate a sense of unfairness, potentially undermining compliance. This will beespecially likely if there is any suggestion of divergence on the big decisions – such as
when to lift the requirement that people stay at home unless they have a reasonableexcuse, or when to allow different types of business to reopen.
The challenge may be particularly great if differences arise between England andWales, since a large number of workers, businesses and public services operate acrossthe Anglo–Welsh border. But regulatory differences across the Anglo–Scottish borderwould also be contentious, and would raise questions about enforceability, and whether
border checks might be required.45 A poorly co-ordinated UK-wide exit strategy may
also make it more difficult to contain the infection in border areas.
As the Institute for Government recently concluded, “public consent for thegovernment’s actions during the first phase of the lockdown has been remarkably high.
But that may not continue, if people perceive that they are being treated unfairly, forexample if there is major differentiation between groups or if the differentiation is
not grounded in solid evidence.” 46 This factor may serve as a major constraint on therealistic potential for divergent exit strategies between the UK nations.

Devolved administrations do not have the powers – or the capacity – to allow
for significantly different approaches
Devolved and reserved elements of the coronavirus response interact with each otherin complex ways. This might make it tricky to unwind the different schemes on differing
timescales. In particular, as we note above, the UK government is funding support for
big business across the UK, including through VAT relief and the furloughed workers
scheme. These interventions are predicated on businesses being in lockdown, so if oneof the devolved nations were to allow a swifter return to business as usual, this mightraise complications about whether the UK funding streams should then be turned off inthat part of the country.
Conversely, if the UK government were to favour a faster resumption of ordinary
economic activity, and accordingly decided to switch off business support mechanisms
such as the furlough scheme, this would likely make it unviable for the devolved nations
to maintain a longer lockdown, since many businesses in those territories would swiftly
run into serious financial difficulties that the devolved governments would lack thefiscal powers to redress.
Neither do the devolved governments have powers over borders and ports thatwould enable them to operate a markedly different scheme for controlling arrivals
from overseas, for instance in the event that the UK government decided to reopen
the country to international travellers sooner than one or other of the devolved
governments wished to do. This constrains the devolved administrations’ ability todiverge in their approach to disease control, for instance if they wished to open up
certain sectors of the economy such as tourism.

12

A FOUR-NATION EXIT STRATEGYAnother constraint on divergence is that the devolved administrations have lessanalytical and implementation capacity than the UK government, which means theymight find it easier to follow the lead of Whitehall and to align their strategies with theshared evidence base provided through SAGE. The devolved administrations can also
‘piggyback’ on work taking place for England. For example, NHS England is developing
a contact-tracing app, which will use proximity tracking to identify those who havebeen in close contact with a person who has tested positive for Covid-19. This work islikely to be useful for the three devolved administrations in implementing their own
testing strategies, from which they can benefit without expending significant resources
developing this complicated technology.
In practical terms, the UK government can also bring to bear greater resources totackle the pandemic, which may further limit the practical scope for divergence.
For example, the UK government has funded five drive-through coronavirus testing
centres in Scotland as part of UK-wide efforts to scale up testing capacity. Although
the Scottish government is responsible for defining eligibility for testing, key workers
must book through the UK government’s online portal.47 This has increased testing
capacity in Scotland significantly.48 There are clear benefits for the devolved nations inparticipating in UK-wide schemes, but reliance on technology and systems developedin or commissioned by Whitehall is likely to limit the scope for significant policy
differences to emerge.

Conclusion
Many key decisions about the coronavirus exit strategy will be taken, for their nations,by ministers in Edinburgh, Cardiff and Belfast – not at Westminster. A four-nation exit
strategy is likely to be preferable on all sides, but co-ordination between the UK anddevolved governments need not equal complete uniformity of approach. There may
be legitimate reasons for divergence in some areas. Most important is that variation
is based on shared evidence, with transparency about how decisions are being taken,
as this will enable the scrutiny and accountability of decision makers, both to the UK’s
legislatures and to the public at large.
Ministers and officials from across the UK will need to maintain close relations and aconstant flow of information as big decisions are taken about the exit strategy. The four
administrations, and most importantly the UK government, will need to make plain in
public communications and parliamentary debates which rules will apply where andwhy any differentiation is taking place. There should be no divergence by accident.
The reality is that practical and capacity constraints are likely to limit greatly thescope for major differences to emerge between the UK nations. But in the end,
ministers in each of the four governments must make their own decisions, andwill be held to account accordingly.

13

A FOUR-NATION EXIT STRATEGYAnnex: Coronavirus response – social distancing measures
Table 1 Coronavirus response: social distancing measures and economic support
andeconomic
support across the UK
acrossthe UK
MeasureGuidance on social
distancing andavoiding mass
gatherings

Territorial extent

UK-wideDate

Current status

16 March (guidanceon mass gatherings
released in Scotland
15 March)

Until further notice

Social distancing measures

20 March
Schools closed except
MeasureTerritorial extent
for childrenof keyDevolved
workers
Payment of VAT and
self-assessed income UK-wide
tax deferredPubs, restaurants,
gyms
other
Cashand
grantsto socialvenuesordered toself-employedof
close
80% of profits up to£2,500 a month
People prohibitedfrom leaving theirhome without areasonable excuse

Economic support

Gatherings of morethan two peoplebanned if not fromsame household

Cash grantsforLegislation
givingsomepowers
businesses;
policetoretail, lockdown
leisure andenforce
hospitality sector;
and fishing industry

Enhanced sick pay
and employment andsupport entitlement

Economic support

SMEs reimbursed
for the cost of staff
sick pay

Date

Current
statusUntil
further
notice20 March

Payments ordinarily
due by June/July not
due until 2021

20
March
20 March
20 March
20 March

Devolved
UK-wide20
March
26 March
20 March

Devolved –announced jointly byprime minister andfirst ministers

Devolved
Devolved

23 March
11 March – support
for small businesses
and retail, leisure and23
Marchhospitality sector
11 March – support
for Marchsmall businesses
23
and retail, leisure andhospitality sector
23 March
11 March – support
for small businesses
andMarch
retail, in
leisureand26
England,hospitality
sector
Scotland
and
Wales

Runs for at least three
Reviewed bymonthsministers every three
weeks
First
payments to
be made in June forfirst three months ofscheme

Reviewed byministers every three
weeks

Reviewed by ministers
One-off
payments
every threeweeks

11 March – support
differencesin
Legislation
expires28
in Northern Smallfor Marchsmall businesses
designof months
schemesaftersix
Irelandand retail, leisure and between nations
hospitality sector
20 April – support forfishing sector
25 March – support for
11
Marchfishing
sectorUK-wideNo end date set

16 April – support forfishing sector

Government
purchases ofshort-term debt ofmajor companies

3 April – support forfishing sector

UK-wideBusinessrates
Governmentholidays forEngland, Scotland andguaranteedloans toWales
retail, leisure andbusinesses
hospitality firms
Job retention scheme– pays 80% of payroll
UK-widecosts
forinfurloughedDelay
non-domestic
staff
up
to
£2,500pm
rates charges andNorthern Ireland
rates holiday
for all
Increased
generosity
ofbusinesses
Universal Credit
UK-wideand Housing Benefit
UK-wide20 March

England14

Scotland

17
March
18 March
18 March
19 March
20 March
17 March

20 March
Wales

Schemes extended tocover mid-size firms
Appliesfor 2020/21
and 100%
guarantees
tax
year
introducedsince
policy first announced
Similar schemes
applied in threenationswithsomeCurrently
set
to runvariations
for four months,
backdated from
1 MarchRates
holiday forthree months
No end date set
Northern Ireland

A FOUR-NATION EXIT STRATEGY
Source: Institute for Government analysis.

Measure

Territorial extent

Payment of VAT and
self-assessed income
tax deferred
Cash grants to
self-employed of
80% of profits up to£2,500 a month

UK-wideDate

Current status
Payments ordinarily
due by June/July not
due until 2021

20 March

Runs for at least threemonthsUK-wide26 March

First payments to
be made in June forfirst three months ofscheme11 March – support
for small businesses
and retail, leisure andhospitality sector

Economic support

11 March – support
for small businesses
and retail, leisure andhospitality sector

Cash grants forsome businesses;
retail, leisure andhospitality sector;
and fishing industry

11 March – support
for small businesses
and retail, leisure andhospitality sector
11 March – support
for small businesses
and retail, leisure andhospitality sector

Devolved

One-off payments
Small differences indesign of schemes
between nations

20 April – support forfishing sector
25 March – support forfishing sector
16 April – support forfishing sector
3 April – support forfishing sector
Applies for 2020/21
tax year

18 March
Business rates
holidays forretail, leisure andhospitality firms

England, Scotland and
18 March
Wales

Similar schemes
applied in threenations with somevariations

19 March
Delay in non-domestic
rates charges andNorthern Ireland
rates holiday for all
businesses
UK-wideEngland

ScotlandRates holiday forthree months

17 March

Wales

Northern Ireland

Source: Institute for Government analysis.

15

A FOUR-NATION EXIT STRATEGY

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18

A FOUR-NATION EXIT STRATEGYAbout the authors
Akash Paun
Akash is a senior fellow at the Institute for Government, where
he has worked for over a decade. Akash leads the Institute’s
devolution research programme. He has previously worked at
the UCL Constitution Unit and the British Academy.

Jess SargeantJess is a senior researcher at the Institute for Government,
working on devolution and Brexit. She previously worked in
the House of Lords Library and the UCL Constitution Unit.

Alex Nice
Alex is a researcher at the Institute for Government, focusing
on constitutional issues. He has previously worked at the
Economist Intelligence Unit and the Royal Institute ofInternational Affairs (Chatham House).

Acknowledgements
We are very grateful to colleagues at the Institute forGovernment for their help with the production of this paper.
In particular, we would like to thank Kelly Shuttleworth andElspeth Nicholson for their research support and Hannah
White, Joseph Owen and Bronwen Maddox for comments
on earlier drafts of the paper. Thanks also to Will Driscoll,Rowena Mayhew and the members of the communications
team for their work in delivering this publication.

19

A FOUR-NATION EXIT STRATEGYThe Institute for Government is theleading think tank working to makegovernment more effective.
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