REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation and application of the Trade and Cooperation Agreement between the European Union and the United Kingdom of Great Britain and Northern Ireland 1 January – 31 December 2024
Date: 2025-04-04
Institutions: European Commission, Secretariat-General
Subjects: United Kingdom, application of EU law, cooperation agreement (EU), cooperation policy, trade agreement, trade agreement (EU)

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2025  COM(2025) 149 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation and application of the Trade and Cooperation Agreement between the European Union and the United Kingdom of Great Britain and Northern Ireland                       1 January – 31 December 2024  
 
 
Contents 

1. 

Introduction ......................................................................................................................... 2 

2. 

Institutional framework....................................................................................................... 2 

3.  Complaints and dispute settlement ..................................................................................... 4 

3.1. 

3.2. 

Complaints .......................................................................................................................... 4 

Dispute settlement ............................................................................................................... 4 

4.  Sectoral implementation ..................................................................................................... 4 

4.1. 

Trade in goods ..................................................................................................................... 4 

4.2. 
enterprises ........................................................................................................................................... 9 

Services and investment, digital trade, public procurement, and small and medium-sized 

4.3. 

4.4. 

4.5. 

4.6. 

4.7. 

4.8. 

4.9. 

Intellectual property rights. ............................................................................................... 13 

Level playing field ............................................................................................................ 13 

Energy ............................................................................................................................... 13 

Transport ........................................................................................................................... 14 

Fisheries ............................................................................................................................ 15 

Social security coordination .............................................................................................. 16 

Law enforcement and judicial cooperation in criminal matters ........................................ 17 

4.10. 

Association of the United Kingdom to certain EU programmes ...................................... 17 

5.  Developments in the law of the United Kingdom ............................................................ 18 

5.1. 

5.2. 

5.3. 

Cross-cutting matters ........................................................................................................ 18 

Subsidy control and taxation ............................................................................................. 19 

Labour and social standards, environment and climate .................................................... 20 

6.  Conclusions ....................................................................................................................... 20 

Annex 1: Meetings in 2024 of the joint bodies and other structures established by the TCA . 22 

Annex 2: Overview of the actions for implementation agreed by the Partnership Council on 
16 May 2024 ..................................................................................................................... 24 

Annex 3: Decisions and recommendations adopted by the Partnership Council or Committees 
established by the TCA in 2024 ........................................................................................ 25 

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1. Introduction 

In  2024,  the  relationship  between  the  European  Union  (EU)  and  the  United  Kingdom  of 
Great Britain and Northern Ireland (United Kingdom) was based on continued collaboration 
under the framework of the Trade and Cooperation Agreement (TCA, or ‘the Agreement’)1.  

Since  its  entry  into  force  on  1  January  2021,  the  TCA  has  established  a  comprehensive 
framework for collaboration between the EU and the United Kingdom in areas such as trade, 
transport,  fisheries,  energy,  social  security  coordination,  and  law  enforcement  and  judicial 
cooperation  in  criminal  matters,  while  fostering  fair  competition,  sustainable  development 
and respect for fundamental rights. 

This fourth report on the implementation of the TCA, as required by Article 2(4) of Council 
Decision (EU) 2021/689 of 29 April 20212, provides an overview of key developments in the 
functioning  of  the  TCA’s  governance  structures  (Section  2)  and  in  relation  to  enforcement 
tools,  dispute  settlement  and  complaints  (Section  3).  The  report  also  summarises  progress 
across areas covered by the TCA (Section 4) and outlines relevant legislative developments 
in the United Kingdom impacting its implementation (Section 5).  

2. Institutional framework 

In 2024, the joint bodies and other structures established under the TCA actively monitored 
and facilitated its implementation, with 35 meetings held across all policy areas covered by 
the Agreement. This engagement represents a higher frequency of interaction than with any 
other non-EU country with which the EU has a comparable relationship in terms of trade and 
cooperation.  A  comprehensive  list  of  these  meetings  is  in  Annex  1.  The  Commission 
continues to publish online the agendas and minutes of these joint bodies’ meetings3. 

The  Partnership  Council,  the  main  body  set  up  under  the  TCA,  oversees  the  TCA’s 
implementation at political level. It met on 16 May 20244. The EU, represented by then Vice-
President  Maroš  Šefčovič,  and  the  United  Kingdom,  represented  by  then  Foreign  Secretary 
David Cameron, reaffirmed their commitment to fully exploiting the potential the TCA has to 
offer. The Partnership Council reviewed progress in implementing the TCA, noting positive 

1  Trade  and  Cooperation  Agreement  between  the  European  Union  and  the  European  Atomic  Energy 
Community, of the one part, and  the United Kingdom of Great Britain and Northern Ireland, of the other part, 
OJ L149, 30.4.2021, p.10, ELI: http://data.europa.eu/eli/agree_internation/2021/689(1)/oj  

2 Council Decision (EU) 2021/689 of 29 April 2021 on the conclusion, on behalf of the Union, of the Trade and 
Cooperation Agreement between the European Union and the European Atomic Energy Community, of the one 
part,  and  the  United  Kingdom  of  Great  Britain  and  Northern  Ireland,  of  the  other  part,  and  of  the  Agreement 
between the European Union and the United Kingdom of Great Britain and Northern Ireland concerning security 
procedures  for  exchanging  and  protecting  classified 
information,  OJ  L149,  30.4.2021,  p.2:  ELI: 
http://data.europa.eu/eli/dec/2021/689/oj. 

3  Meetings  of  the  EU-United  Kingdom  Partnership  Council  and  Specialised  Committees  under  the  Trade  and 
Cooperation 
https://ec.europa.eu/info/strategy/relations-non-eu-countries/relations-united-
kingdom/eu-uk-trade-and-cooperation-agreement/meetings-eu-uk-partnership-council-and-specialised-
committees-under-trade-and-cooperation-agreement_en. 

Agreement: 

4  The  minutes  of  the  meeting  are  available  at:  https://commission.europa.eu/publications/third-meeting-
partnership-council-established-eu-uk-trade-and-cooperation-agreement_en. 

2 

 
 
 
 
steps  such  as  the  United  Kingdom’s  association  with  Horizon  Europe  and  the  Copernicus 
component  of  the  EU  Space  programme,  as  well  as  the  intense  activity  of  the  TCA’s  joint 
bodies,  which  led  to  more  than  25  formal  meetings  in  2023.  Key  discussions  included 
cooperation in climate and energy, with plans for a new working group on security of supply 
and  a  roadmap  for  electricity  trading.  On  trade  and  the  level  playing  field,  the  co-chairs 
supported cooperation on competition matters and regular exchanges on market surveillance, 
while also discussing the United Kingdom’s new “border target operating  model5”. The co-
chairs  also  highlighted  strengthened  collaboration  on  health  security  between  the  European 
Centre  for  Disease  Control  and  the  United  Kingdom  Health  Security  Agency.  On  internal 
security,  they  noted  advances  in  counter-terrorism  and  cyber  issues  and  agreed  on  further 
technical  work  to  enable  the  sharing  of  vehicle  data.  Annex  2  provides  an  overview  of  the 
actions  for  implementation  agreed  at  the  Partnership  Council.  In  the  area  of  fisheries,  the 
issue of access to waters post-2026 was raised by the EU. It also raised the question of the 
United  Kingdom  sponsorship  system  for  the  temporary  movement  of  service  suppliers  (for 
further details on services and investment, see Section 4.2).  

The 19 committees established under Article 8 of the TCA met throughout the year, actively 
monitoring and facilitating the Agreement’s implementation across all relevant sectors. These 
meetings  enabled  structured  reviews  of  progress  on  commitments  made  in  the  TCA, 
providing  a  platform  for  technical  exchanges  on  various  implementation  issues,  including 
forthcoming regulatory developments. Several key decisions and recommendations were also 
adopted. These decisions and recommendations are summarised in Annex 3. 

The Parliamentary Partnership Assembly, established under Article 11 of the TCA, did not 
convene  in  2024.  Its  fifth  meeting,  originally  scheduled  for  18-19  March  2024  in  Brussels, 
was postponed due to the United Kingdom Parliament's calendar.  

Civil  society  representatives  remained  actively  engaged  in  the  TCA’s  implementation.  The 
EU Domestic Advisory Group, established under Article 13 of the TCA, met regularly and 
provided  valuable  input6.  The  Commission  continues  to  pay  close  attention  to  the  group’s 
activity and recommendations, which offer important insights into civil society perspectives 
on the implementation of the TCA and broader EU-United Kingdom relations.  

The Civil Society Forum, established under Article 14 of the TCA to facilitate dialogue on 
the implementation  of Part Two of the Agreement  (which  covers trade, transport,  fisheries, 
and other arrangements) was held on 20 September 2024 in Brussels.  As in previous years, 
the meeting focused on key implementation issues related to trade in goods, the level playing 
field,  regulatory  cooperation,  trade  in  services,  and  energy.  The  Commission  values  the 
perspectives  shared  by  civil  society  organisations,  trade  unions,  EU  businesses,  and  other 
workers’  organisations  within  the  Forum  and  aims  to  promote  these  interests  in  its 
discussions with the United Kingdom on TCA implementation. 

5 The border target operating model is the rulebook for the United Kingdom’s new import regime. 

6  Minutes  of  the  meetings:  https://www.eesc.europa.eu/en/sections-other-bodies/other/eu-domestic-advisory-
group-under-eu-uk-tca/events. 

3 

 
 
 
 
3. Complaints and dispute settlement 

The  Commission  has  put  in  place  mechanisms  to  enforce  TCA  commitments,  resolve 
potential disputes, and address complaints from EU stakeholders. 

3.1.  Complaints 

In  2024,  seven  complaints  were  submitted  through  the  centralised  tools  set  up  by  the 
Commission  to  ensure  efficient  monitoring  of  the  TCA  implementation7.  Two  complaints 
were related to the United Kingdom’s border target operating model, specifically highlighting 
long  waiting  times  at  the  border  and  proportionality  of  fees  levied  under  the  United 
Kingdom’s common user charges in the absence of actual control activities. The Commission 
has been engaging with  the United Kingdom to  address these concerns.  The remaining five 
submissions  pertained  to  matters  falling  outside  the  scope  of  the  TCA  and  have  been 
followed-up accordingly8. 

3.2.  Dispute settlement 

The United Kingdom’s decision to prohibit sandeel fishing in British waters as of 26 March 
2024  led  the  EU  to  invoke  the  TCA  dispute  settlement  mechanism  on  16  April  2024,  with 
proceedings ongoing. Despite these steps, the Commission continues to be open to finding an 
amicable solution. 

For further details, see Section 4.7 on fisheries. 

4. Sectoral implementation 

The sectoral implementation of the TCA progressed smoothly, with all commitments due in 
2024  either  completed  or  on  track.  This  section  outlines  the  main  achievements  and 
highlights  key  policy  developments  in  the  United  Kingdom  across  various  sectors.  Where 
possible, it also provides data on trade flows between the EU and the United Kingdom. 

4.1.  Trade in goods 

Overall, the trade-related arrangements set out in the TCA have been effective and functioned 
smoothly. 

In  line  with  Article  31  of  the  TCA,  the  EU  and  the  United  Kingdom  exchanged  import 
statistics in 20249. These statistics indicate that preference utilisation rates10 remain high and 

7  https://ec.europa.eu/assets/sg/complaint_eu_uk_tca/complaints_en/  and  https://trade.ec.europa.eu/access-to-
markets/en/content/single-entry-point-0. 

8  These  submissions  raised  issues  such  as  EU  farming  grants  not  being  available  in  Northern  Ireland  and  the 
right to United Kingdom state benefits for United Kingdom citizens residing in the EU, or topics unrelated to 
EU-United Kingdom relations including problems at border crossings other than with the United Kingdom, and 
difficulties in obtaining information from customs authorities on goods to be carried across to Belarus. 

9 The data refers to the year 2023. 

4 

 
 
 
 
are  comparable  to  those  of  the  previous  year:  89.1%  of  EU  preference-eligible  goods 
exported to the United Kingdom and 80.4% of preference-eligible goods imported from the 
United  Kingdom  benefited  from  the  preferences  under  the  TCA.  These  rates  are  consistent 
with those observed for other partners with whom the EU has free trade agreements11. 

Cooperation  between  the  EU  and  the  United  Kingdom  on  value  added  tax  and  claims 
concerning taxes and duties was made fully operational in 2024. This followed the adoption 
in  2023  of  the  four  decisions  needed  to  fully  implement  the  Protocol  on  Administrative 
Cooperation  and  Combating  Fraud  in  the  Field  of  Value  Added  Tax  and  on  Mutual 
Assistance  for  the  Recovery  of  Claims  Relating  to  Taxes  and  Customs  Duties  (VAT 
Protocol) referred to  in  Article 120 of the TCA, rendering the previous transitory measures 
obsolete. The statistics reported by Member States as part of the transitory measures referred 
to above12 show that the number of requests, both for information and for recovery, remains 
stable, and limited.  

In 2024, the EU and the United Kingdom  worked together to  update the product-specific 
rules  of  origin  in  Annex  3  of  the  TCA  to  reflect  the  World  Customs  Organization’s 
Harmonized System (HS) 2022 classification of goods. This update, necessitated by changes 
introduced by the World Customs Organization to account  for technological  advancements, 
new  products,  and  evolving  trade  patterns,  ensures  that  the  TCA  remains  up  to  date.  The 
Partnership  Council  adopted  the  corresponding  decision  to  approve  this  update  on  5 
November 202413. 

In  April  2024,  the  United  Kingdom  started  to  apply  a  new  set  of  import  requirements  and 
controls  as  laid  out  in  its  border  target  operating  model.  As  a  result  of  this  new  set  of 
requirements  and  controls,  identity  and  documentary  checks  became  mandatory  also  for 
medium-risk products of animal origin, plants, and plant products imported from the EU that 
the UK has categorised as of medium risk14. According to EU exporters, the implementation 
of the new import regime has been posing some difficulties, such as (i) frequent changes in 
risk categorisation  without  proper notification;  (ii) full implementation  of the common user 
charge  despite  partial  implementation  of  border  controls;  (iii)  inconsistent  interpretation  of 
import  requirements  by  different  border  posts;  (iv)  failure  to  recognise  the  EU  as  a  single 

10 The preference utilisation rate  reflects the  share of imports or exports entering under trade preferences as a 
share of the total value of imports or exports eligible for preferences by partner country.  

11  For  further  details  on  the  implementation  of  the  EU’s  free  trade  agreements,  see  the  Report  from  the 
Commission to the European Parliament,  the Council, the European Economic and Social Committee and the 
Committee  of 
Implementation  and  Enforcement  of  EU  Trade  Policy: 
https://policy.trade.ec.europa.eu/enforcement-and-protection/implementing-and-enforcing-eu-trade-
agreements_en. 

the  Regions  on 

the 

12 Member States and the United Kingdom had until then been reporting data regularly to allow for assessing the 
use of the temporary measures under the VAT Protocol. 

13  Decision  No  1/2024  of  the  Partnership  Council  modifying  Annex  3  to  the  TCA  (Product  Specific  Rules  of 
Origin), OJ L, 2024/2837, 5.11.2024, ELI: https://eur-lex.europa.eu/eli/dec/2024/2837/oj. 

14 Inspection rates by commodity type are published on United Kingdom government’s website, but the extent 
of their applications remains unclear. For  live animals (classified as a high-risk category), border checks have 
not  yet  been  implemented  due  to  the  absence  of  approved  seaport  border  control  posts  designated  for  such 
checks. Similarly, border checks are not yet in place for consignments from the island of Ireland, as no border 
control posts have been established on the west coast of Britain. 

5 

 
 
 
sanitary and phytosanitary entity in respect of certification requirements; (v) outdated import 
requirements  not  compatible  with  the  international  standards;  (vi)  delays  in  introducing 
electronic certification; and (vii) long waiting times in carrying out controls for consignments 
selected for physical checks15. 

The  EU  has  consistently  raised  these  issues  with  the  United  Kingdom  in  the  TCA  joint 
bodies, including the Trade Specialised Committees on Sanitary and Phytosanitary Measures, 
and  on  Customs  Cooperation  and  Rules  of  Origin  as  well  as  the  Trade  Partnership 
Committee. In these discussions, the EU has emphasised the critical importance of providing 
timely  and  accurate  information  on  border  procedures  (Articles  102(e)  and  111  TCA)  and 
avoiding  excessive  trade  burdens  (Article  101(a)  TCA).  However,  the  United  Kingdom’s 
responses  have  not  yet  fully  addressed  these  concerns.  The  EU  continues  to  monitor  the 
implementation of the United Kingdom’s import regime and remains committed to working 
through  the  TCA  mechanisms  to  address  ongoing  issues  and  minimise  disruption  to  trade 
between the EU and the United Kingdom. 

Separately,  on  24  January  2024,  the  United  Kingdom  announced  plans  to  legislate  for  the 
indefinite  recognition  of  the  CE  marking16  across  additional  product  regulations.  This 
includes  the  18  regulations  previously  announced  and  3  new  categories:  (i)  ecodesign  for 
energy-related  products,  (ii)  explosives,  and  (iii)  restrictions  on  hazardous  substances  in 
electrical  and  electronic  equipment.  The  continued  recognition  of  the  CE  marking  in  the 
United Kingdom eases compliance challenges for EU manufacturers and facilitates the export 
of the products that require such marking from the United Kingdom to the EU. 

Trade in goods between the EU and the United Kingdom evolved as follows in 202417. 

In  the  first  three  quarters  of  2024,  the  EU  exported  goods  worth  EUR  255  billion  to  the 
United Kingdom, which represents an increase of 1.7% compared to the same period in 2023, 
and an increase of 5.6% compared to the same period in 201918. EU goods imports from the 
United  Kingdom  in  the  first  three  quarters  of  2024  amounted  to  EUR  123  billion, 
representing a 11.5% decrease compared to the same period in 2023 and a decrease of 14.7% 
compared  to  the  same  period  in  2019.  Therefore,  while  goods  exports  from  the  EU  to  the 
United Kingdom have been slightly increasing, imports from the United Kingdom to the EU 

15  Shortly  before  the  deadline of  31  October 2024  for  the  requirement  to  present  customs  safety  and  security 
declarations  to  start  applying,  the  United  Kingdom  again  delayed  the  start of  application  to  31  January  2025. 
Delays  in  implementing  controls  for  EU  and  EFTA  live  animal  imports  and  checks  on  non-qualifying  goods 
from Ireland are expected to continue until summer 2025, with existing procedures remaining in place. 

16 CE marking is a certification that indicates a product has been assessed by the manufacturer and deemed to 
meet  EU  safety,  health  and  environmental  protection  requirements.  It  is  required  for  products  manufactured 
anywhere in the world that are then marketed in the EU. 

17 All figures are based – unless specified otherwise – on Eurostat data: 
https://ec.europa.eu/eurostat/web/international-trade-in-goods/overview. 

18 The report uses 2019 as a benchmark because it reflects trade between the EU and the United Kingdom under 
single  market  conditions,  and  before  the  COVID  pandemic  affected  data.  In  2019,  trade  data  followed  EU 
Member  State  statistical  concepts.  Since  January  2021,  trade  with  the  United  Kingdom  is  reported  separately 
from  Northern  Ireland,  using  non-EU  trade  concepts  for  the  United  Kingdom  and  intra-EU  concepts  for 
Northern Ireland. Eurostat publishes goods trade with the United Kingdom in its ‘extra-EU’ datasets. 

6 

 
 
 
have  continued  to  decline.  In  the  first  three  quarters  of  2024,  the  EU  ran  a  sizeable  goods 
trade surplus with the United Kingdom amounting to EUR 132 billion.  

In the first three quarters of 2024, EU goods exports to other non-EU countries increased by 
0.9%  compared  to  the  same  period  in  2023  and  by  24.6%  compared  to  the  same  period  in 
2019.  EU  goods  imports  from  other  non-EU  countries  fell  by  5%  compared  to  the  same 
period in 2023 and increased by 28.6% compared to the same period in 2019. This confirms 
the  trend  observed  since  the  United  Kingdom’s  withdrawal,  with  trade  in  goods  growing 
more rapidly with other non-EU countries than with the United Kingdom. 

Figure 1: EU trade in goods with the United Kingdom compared to EU trade with the rest of 
the world, first  three quarters of 2019, first three quarters of 2023 and  first three quarters of 
2024, EUR billion. Source: Eurostat (dataset ext_st_eu27_2020sitc) 

In the first three quarters of 2024, total trade in  goods with the United Kingdom accounted 
for 10.2% of the EU’s total trade with its international partners, representing no change from 
the same period of 2023 and a decrease from 12.7% in the same period of 2019. 

In the first three quarters of 2024, the United Kingdom was the destination of 13.3% of EU 
goods exports (compared to 13.2% in the same period of 2023 and 15.3% in the same period 
of 2019), second to the United States (20.6%). The United Kingdom was the origin of 6.8% 
of  the  EU’s  goods  imports  (compared  to  7.3%  in  the  same  period  of  2023  and  10%  in  the 
same period of 2019), in third place behind China (21.1%) and the United States (13.9%). 

By  way  of  general  comparison,  in  2023  the  EU  was  the  destination  of  49%  of  the  United 
Kingdom’s goods exports and the origin of 55% of the United Kingdom’s goods imports19.  

This  data  highlights  that  the  EU  remains  the  United  Kingdom’s  most  significant  trading 
partner for goods. At the same time, the EU’s trade in goods has become more diversified in 
recent years. 

19 House of Commons. (2024) Statistics on UK-EU trade. Available at: 
https://commonslibrary.parliament.uk/research-briefings/cbp-7851/. 

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Figure  2:  EU  trade  in  goods  with  its  top  three  international  partners,  first  three  quarters  of 
2019,  first  three  quarters  of  2023  and  first  three  quarters  of  2024,  (%).  Source:  Eurostat 
(dataset ext_st_eu27_2020sitc) 

The sectors where EU goods exports to the United Kingdom showed the highest increase in 
2024 compared to 2023 were food, drinks and tobacco (+3.2%) and machinery and transport 
equipment  (+2.6%). EU  goods imports from  the United Kingdom  in  2024 decreased across 
all product categories. 

Figure 3: EU trade in goods with the United Kingdom by the Standard International Trade Classification (SITC) for 
goods, first three quarters of 2019, first three quarters of 2023 and first three quarters of 2024, EUR billion. Source: 
Eurostat (dataset ext_st_eu27_2020sitc) 

8 

 
 
 
 
 
4.2.  Services and investment, digital trade, public procurement, and small 

and medium-sized enterprises 

The  implementation  of  the  TCA  in  the  areas  of  services  and  investment,  digital  trade, 
intellectual  property,  public  procurement,  and  small  and  medium-sized  enterprises  has 
generally proceeded smoothly, with no major issues except for the question of the application 
of the United  Kingdom’s  sponsorship system for work visas to  EU services providers.  In 
the United Kingdom, an employer willing to employ a foreign worker needs to be licenced by 
the Home Office and then assign a certificate of sponsorship to that foreign worker (in both 
steps a fee is due by the employer), for that worker to be able to apply for a visa (who would 
also  incur  in  additional  fees).  Despite  being  primarily  designed  to  manage  migration  (i.e. 
foreign workers who reside in the United Kingdom), the system is also applied by the United 
Kingdom to foreign service suppliers (including from the EU) who only come temporarily to 
the United Kingdom  to supply a service (and irrespective of the whether the supply of that 
service  falls  under  the  commitments  in  a  free  trade  agreement  such  as  the  TCA)  –  in  that 
case, the service provider needs to be sponsored by its  customer to be able to apply for the 
visa.  The  EU  has  repeatedly  raised  this  system’s  complexity,  disproportionate  burden  and 
lack  of  clarity  surrounding  this  system  in  the  TCA  joint  bodies20.  The  application  of  this 
system  to  EU  service  suppliers  continues  to  hinder  the  TCA’s  implementation,  with  only 
seventeen  visas21  granted  in  2024  to  EU  service  suppliers  despite  the  close  economic  ties 
between the EU and United Kingdom and the market opening commitments of the TCA. As a 
result, EU services suppliers are hampered from serving clients in the United Kingdom. The 
EU continues to urge the United Kingdom to exempt services suppliers covered by the TCA 
from the sponsorship system, as it undermines the United Kingdom’s TCA commitments on 
the  supply  of  services  through  temporary  presence  (see  Articles  123  of  the  TCA  and 
following). 

On  the  recognition  of  professional  qualifications,  the  Commission  is  awaiting  a  revised 
joint recommendation to be submitted by the Architects’ Council of Europe and the  United 
Kingdom’s Architects Registration Board, under  Article 158(3) of the TCA, with a view to 
the  possible  start  of  the  negotiations  on  an  arrangement  for  the  recognition  of  professional 
qualifications  for  architects22.  No  other  professional  association  has  contacted 
the 
Commission  to  signal  an  interest  in  the  recognition  of  professional  qualifications  by  the 
United Kingdom. 

In  line  with  Article  211(1)  of  the  TCA,  the  EU  and  the  United  Kingdom  have  agreed  to 
cooperate on various aspects of digital trade regulation. In this spirit, the Commission (DG 
Communications  Networks, Content and  Technology) and OFCOM  (the United Kingdom’s 
regulator for broadcasting, telecommunications, and postal services) signed an administrative 
arrangement  on  30  April  2024.  The  arrangement  focuses  on  the  supervision  of  risk 

20  In  the  Partnership  Council  meeting  of  16  May  2024,  in  the  Trade  Specialised  Committee  on  Services, 
Investment  and  Digital  Trade  meeting  of  24  October  2024,  and  in  the  Trade  Partnership  Committee  of  12 
December 2024. 
21 Service Supplier (Global Business Mobility) visa. 
22 As explained in last year’s report, the proposal from the initial Joint Recommendation of October 2022 was 
unbalanced and prejudicial to EU architects. 

9 

 
 
 
assessment and mitigation efforts by providers of large online platforms, in areas such as: (i) 
the  protection  of  minors  online;  (ii)  the  age-appropriate  design  of  technologies;  (iii)  the 
transparency  of  online  platforms;  (iv)  the  impacts  of  algorithms  on  systemic  risk;  and  (v) 
measures to detect and report illegal content online. This cooperation will primarily involve 
the  exchange  of  information.  The  arrangement  does  not  cover  the  exchange  of  confidential 
information  related  to  regulated  entities,  and  each  party  maintains  its  regulatory  and 
supervisory  autonomy  under  its  respective  legislation23.  This  administrative  arrangement  is 
non-binding and carries no financial implications. 

In the area of intellectual property, discussions between the EU Intellectual Property Office 
and the United Kingdom’s Intellectual Property Office  on a memorandum of understanding 
to improve administrative cooperation, as provided for in Article 273(2)(g) of the TCA, have 
not yet been concluded.  

In 2024, trade in services between the EU and the United Kingdom evolved as set out in the 
paragraphs below24. 

In  the  first  three  quarters  of  2024,  the  EU  exported  services  worth  EUR  220  billion  to  the 
United Kingdom, which represents an increase of 6.2% compared to the same period in 2023, 
and  an  increase  of  33.2%  compared  to  the  same  period  in  2019.  The  value  of  EU  services 
imports from  the  United Kingdom  in  the  first  three quarters  of 2024 was  EUR  177  billion, 
representing an 8.5% increase compared to the same period in 2023 and an increase of 35.3% 
compared to  the same period in  2019. Unlike trade in  goods, bilateral  trade in  services has 
increased considerably. In the first three quarters of 2024, the EU ran a services trade surplus 
with the United Kingdom amounting to EUR 43 billion.  

In the first three quarters of 2024, EU services exports to other non-EU countries increased 
by  10.3%  compared  to  the  same  period  in  2023  and  increased  by  44.5%  compared  to  the 
same  period  in  2019.  EU  services  imports  from  other  non-EU  countries  increased  by  7.9% 
compared to  the same period in  2023 and by  42.9% compared to  the same period in  2019. 
This  confirms  the  trend  observed  since  the  United  Kingdom’s  withdrawal,  with  trade  in 
services  growing  more  dynamically  with  other  non-EU  countries  than  with  the  United 
Kingdom, similar to the trend observed in trade in goods. 

23  The  Commission  is  entrusted  with  certain  implementation  and  enforcement  tasks  under  Regulation  (EU) 
2022/2065 of the European Parliament and of the Council of 19 October 2022 on a Single Market For Digital 
Services (Digital Services Act), OJ L 277, 27.10.2022, p.1, ELI: http://data.europa.eu/eli/reg/2022/2065/oj. 

24 All figures are based – unless specified otherwise – on Eurostat data: 
https://ec.europa.eu/eurostat/web/balance-of-payments/overview  
https://ec.europa.eu/eurostat/web/international-trade-in-services/overview. 

10 

 
 
 
Figure  4:  EU  trade  in  services  with  the  United  Kingdom  compared  to  EU  trade  with  the  rest  of  the  world,  first  three 
quarters of 2019,  first  three  quarters  of  2023  and  first  three  quarters  of  2024,  EUR  billion. Source:  Eurostat  (dataset 
bop_eu6_q) 

In the first three quarters of 2024, total trade in services with the United Kingdom accounted 
for 18.7% of the EU’s total trade with its international partners, representing a slight decrease 
from  19.0%  in  the  same  period  of  2023  and  a  decrease  from  19.8%  in  the  same  period  of 
2019. 

The United Kingdom was the destination of 19.3% of EU services exports in  the first three 
quarters  of  2024  (compared  to  19.9%  in  the  same  period  of  2023  and  20.6%  in  the  same 
period of 2019), second to the United States (21.1%). The United Kingdom was the origin of 
18.0% of the EU’s services imports in the first three quarters of 2024 (compared to 17.9% in 
the same period of 2023 and 18.8% in the same period of 2019), second to the United States 
(34.7%). 

By way of general comparison, in 2023 the EU accounted for 36% of the United Kingdom’s 
services exports and 46% of its services imports25, demonstrating that the EU has been by far 
the most important partner in the United Kingdom’s trade in services. As with trade in goods, 
the EU’s trade in services has also become more diversified in recent years. 

25 House of Commons. (2024) Statistics on UK-EU trade. Available at: 
https://commonslibrary.parliament.uk/research-briefings/cbp-7851/. 

11 

 
 
 
 
 
 
Figure  5:    EU  trade  in  services  with  its  top  three  international partners,  first  three  quarters  of  2019,  first  three 
quarters of 2023 and first three quarters of 2024, (%). Source: Eurostat (dataset bop_eu6_q) 

The sectors where EU exports to the United Kingdom showed the strongest increase in 2024 
compared  to  2023  were  ‘other  (SA,  SB,  SE,  SK,  SL)’26  (+11.7%),  telecom  and  computer 
(+10.7%), other business services (+8.3%) and insurance and pension services (+7.8%). The 
largest  increases  for  EU  imports  from  the  United  Kingdoms  were  found  in  the  sectors  of 
insurance and pension services (+21.9%), charges for the use of intellectual property (15.9%), 
financial services (14.4%), and ‘other (SA, SB, SE, SK, SL)’27 (+13.2%). 

Figure  6:  EU  trade  in  services  with  the  United  Kingdom  in  the  first  three  quarters  of  2024  compared  to  the  same 
period of 2023 and the same period of 2019, by type of service, EUR billion. Source: Eurostat (dataset bop_eu6_q) 

26 The types of services included under ‘Other’ are: SA  - manufacturing services on physical inputs owned by 
others,  SB  -  maintenance  and  repair  services,  SE  -  construction,  SK  -  personal,  cultural,  and  recreational 
services, SL - government goods and services and services not allocated. 

12 

 
 
 
 
 
4.3. 

Intellectual property rights. 

Discussions on a memorandum of understanding between the EU Intellectual Property Office 
and 
improve  administrative 
cooperation, as provided for in Article 273(2)(g) of the TCA, are still ongoing.  

the  United  Kingdom’s  Intellectual  Property  Office 

to 

4.4.  Level playing field 

In  October  2024,  the  European  Commission  and  the  United  Kingdom  concluded  technical 
discussions  on  a  competition  cooperation  agreement27,  following  a  June  2023  Council 
Decision  authorising  negotiations.  This  agreement,  a  ‘supplementing  agreement’  under 
Article  361(4)  of  the  TCA,  will  allow  the  Commission,  national  competition  authorities  of 
EU  Member  States,  and  the  United  Kingdom’s  Competition  and  Markets  Authority  to 
cooperate directly in competition investigations. It is the first EU agreement enabling national 
competition authorities to work with a non-EU country’s competition authority, as is foreseen 
by  the  TCA  for  the  United  Kingdom.  This  agreement  will  facilitate  the  coordination  of 
investigations,  the  notification  of  major  antitrust  and  merger  cases,  and  the  sharing  of 
information, while ensuring that conflicts are avoided. Confidential information will only be 
exchanged with the consent of the undertaking involved. This agreement will enter into force 
after ratification by both the EU and the United Kingdom.  

There were  also several policy developments  relevant for the level playing field throughout 
2024  in  the  areas  of  subsidies,  taxation  and  labour  and  social  standards,  which  are  further 
detailed in Section 5 below.  

4.5.  Energy 

Considering the current geopolitical context and the shared ambition for climate neutrality, it 
is particularly important to strengthen cooperation on energy between the EU and the United 
Kingdom. The significance of collaboration in this field was underlined at the third meeting 
of the Partnership Council, which focused on climate and energy issues. Significant progress 
has  since  been  made  in  implementing  the  energy  provisions  of  the  TCA,  including  the 
developments set out in the paragraphs below: 

To support efforts to diversify away from Russian fuels, EU-United Kingdom cooperation on 
security of supply under Article 315 of the TCA remains of great importance. Ahead of the 
2024-2025 winter season, technical exchanges took place on gas and electricity preparedness, 
and  the  safety  of  offshore  operations.  Furthermore,  the  EU  and  the  United  Kingdom  also 
agreed  to  strengthen  this  cooperation  by  establishing  a  new  Working  Group  on  Security  of 
Supply during the fifth meeting of the Specialised Committee on Energy28. Meetings of this 
working group are planned for 2025. 

Exchanges have taken place with respect to the development of offshore renewable energy, 
in  line  with  Article  321  of  the  TCA  and  under  the  framework  of  the  Memorandum  of 

27 Press release: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5468. 

28 Decision No 2/2024 of the Specialised Committee on Energy: 741b6df6-7270-4cb1-b00e-9ac18a1e12b7_en. 

13 

 
 
 
 
 
Understanding  on  offshore  renewable  energy  cooperation  between  the  participants  of  the 
North Seas Energy Cooperation and the United Kingdom29.  

The  EU  and  the  United  Kingdom  also  advanced  cooperation  between  their  transmission 
systems  operators  and  regulatory  authorities,  as  outlined  in  Articles  317  and  318  of  the 
TCA. In particular, both Parties agreed on guidance30 for the arrangements between their gas 
and  electricity  transmission  system  operators31,  and  between  their  regulatory  authorities32. 
The  fifth  meeting  of  the  Specialised  Committee  on  Energy  subsequently  endorsed  these 
arrangements, setting the stage for intensified collaboration between the EU and the United 
Kingdom. 

One key challenge remains the implementation of the new electricity trading arrangements 
set out in Article 312 and Annex 29 of the TCA. To clarify the next steps and provide further 
momentum,  the  EU  and  the  United  Kingdom  agreed  on  a  roadmap  outlining  key 
implementation  milestones33.  In  December  2024,  the  Specialised  Committee  on  Energy 
adopted  a  recommendation  requesting  additional  technical  work  from  the  EU  and  United 
Kingdom transmission system operators on implementing these trading arrangements34. This 
implementation work will continue in 2025, in line with the roadmap’s indicative timeline. 

4.6.  Transport 

Implementation of the TCA in the area of transport has proceeded smoothly, focused on the 
effective exercise of the rights mutually granted by the EU and the United Kingdom. 

In the area of aviation safety, of the 20 applications for validation of certificates issued by 
the  United  Kingdom’s  Civil  Aviation  Authority,  9  have  so  far  been  approved  by  the  EU 
Aviation  Safety  Agency  (EASA)  under  Article  446  in  conjunction  with  Annex  30  of  the 
TCA. With support from EASA, the United Kingdom authorities have now validated 14 out 
of  21  projects  submitted  by  EU  applicants,  consistent  with  expected  activity  levels  for 
certificate validation. 

29  Memorandum  of  understanding  on  offshore  renewable  energy  cooperation  between  the  participants  of  the 
North Seas Energy Cooperation (NSEC), of the one side, and the United Kingdom of Great Britain and Northern 
Ireland, 
https://circabc.europa.eu/ui/group/9198696f-e42c-4a88-b4f1-
side: 
7a1788eb9b7c/library/6eba274d-4cae-4e40-b9b7-c9775812803a/details. 

other 

the 

of 

30  Decision  No  1/2024  of  the  Specialised  Committee  on  Energy,  OJ  L,  2024/1550,  31.5.2024,  ELI: 
http://data.europa.eu/eli/dec/2024/1550/oj. 

31  The  European  Network  of  Transmission  System  Operators  for  Electricity  and  the  European  Network  of 
Transmission System Operators for Gas in the EU and the transmission system operators for electricity and gas 
in the United Kingdom. 

32  The  EU  Agency  for  the  Cooperation  of  Energy  Regulators  and  the  regulatory  authority  in  the  United 
Kingdom. 

33 See Annex C of the minutes of the meeting of the Specialised Committee on Energy of 7 November 2024: 
https://commission.europa.eu/document/download/02c700d0-3e75-4af0-ae45-
119983d9cf6c_en?filename=20241107-eu-uk-sce-5th-meeting-final-en.pdf. 

34  Recommendation  No  1/2024  of  the  Specialised  Committee  on  Energy:  388d6f57-7f4a-46b1-802f-
7ea585673517_en. 

14 

 
 
 
 
 
 
In the area of air transport, by the end of 2024, a total of 23 bilateral agreements35 on all-
cargo  services  had  been  concluded  between  EU  Member  States  and  the  United  Kingdom 
under  Articles  419(4)  and  419(9)  of  the  TCA,  unchanged  from  2023.  Additionally,  25  EU 
Member States have been allowing flexible, short-term permissions for certain non-scheduled 
flights carrying goods or passengers between the United Kingdom and the EU (covering the 
‘third  and  fourth  freedom’  of  aviation,  that  is,  the  right  to  fly  passengers  from  one’s  own 
country to another country and the right to fly passengers from another country to one’s own 
country,  respectively).  Some  of  these  permissions  are  open-ended  as  long  as  they  apply  to 
specific airlines rather than broadly to the United Kingdom. 

In road transport, work is ongoing to implement the TCA’s provisions on the exchange of 
information and data between national electronic registers (c.f. Article 14, Section 1 of Part A 
of TCA Annex 31). This includes connecting the United Kingdom to the European Registers 
of Road Undertakings (ERRU), which links national registers of road transport undertakings 
and  contains  information  on  serious  infringements  of  road  transport  rules.  In  this  regard, 
work is  also  underway to  draw up a list  of serious infringements,  which will be  exchanged 
via ERRU once the United Kingdom is connected. These initiatives are designed to enhance 
cooperation and data sharing between the EU and the United Kingdom. 

4.7.  Fisheries 

In 2024, the EU and the United Kingdom continued their good cooperation in implementing 
the  TCA’s  provisions  in  the  fisheries  sector.  The  Specialised  Committee  on  Fisheries 
provided  a  forum  for  discussions  on  the  sustainable  management  of  shared  fishing  stocks. 
However, three specific issues led to concerns on the EU side.  

First, effective since 26 March 2024, the United Kingdom decided to prohibit the fishing of 
sandeel in the English waters of the North Sea36 and in all Scottish waters37, preventing EU 
vessels  from  operating  this  sustainable  fishery.  The  EU  questions  the  compatibility  of  the 
United Kingdom’s decision in this matter with the TCA. As a result, in April 2024, the EU 
initiated  formal  consultations  with  the  United  Kingdom  under  the  TCA  dispute  settlement 
mechanism.  These  consultations  ended  without  a  mutually  agreed  solution,  and  the  EU 
subsequently  requested  the  establishment  of  an  arbitration  tribunal.  A  ruling  on  the 
compatibility  of  the  prohibition  with  the  TCA  is  expected  by  the  end  of  April  2025  at  the 
latest. In the meantime, the EU remains open to reaching an amicable solution38.  

35 The following Member States have signed bilateral agreements with the United Kingdom: Austria, Belgium, 
Bulgaria,  Croatia,  Cyprus,  Czechia,  Denmark,  Estonia,  Finland,  France,  Germany,  Greece,  Hungary,  Italy, 
Ireland, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Slovakia, Slovenia and Sweden. 

36 https://www.gov.uk/government/news/nature-recovery-to-be-accelerated-as-the-government-delivers-on-
measures-to-protect-land-and-sea. 

37 https://www.gov.scot/publications/sandeel-prohibition-fishing-scotland-order-2024-final-business-regulatory-
impact-assessment/. 

38 Further information on the dispute is available in the April 2024 press release on the opening of consultations: 
https://ec.europa.eu/commission/presscorner/detail/fen/ip_24_2050  and in the Daily News of 25 October 2024 
on the EU’s request for establishment of arbitration tribunal: 
https://ec.europa.eu/commission/presscorner/detail/en/mex_24_5470.  

15 

 
 
 
 
Second, the EU closely  monitored the  management measures adopted and planned by the 
United  Kingdom.  While  recognising  the  regulatory  autonomy  of  both  Parties,  the  EU 
expressed concern about  the possible impact  of these measures on the EU fleet  and closely 
monitors  whether  all  UK  measures  comply  with  the  objectives  and  principles  of  the  TCA. 
The EU welcomed the United Kingdom’s readiness to engage in discussions on the matter. 

Third,  the  EU  continued  to  emphasise  to  the  United  Kingdom  the  utmost  importance  of 
putting  in  place  arrangements  for  stable,  reciprocal  access  to  waters  from  July  2026 
onwards.  However,  the  United  Kingdom  deemed  it  premature  to  engage  in  discussions  on 
this matter.  

In  December  2024,  the  EU  and  the  United  Kingdom  concluded  their  annual  consultations 
under  Article  498  of  the  TCA  to  determine  the  total  allowable  catches  for  shared  stocks  in 
2025.  The  Parties  reached  a  comprehensive  agreement  covering  all  stocks,  thus  securing 
fishing opportunities of about 428,000 tonnes for the EU fleet, estimated to be worth almost 
EUR 1.4 billion based on historic landing prices adjusted for inflation.39  

4.8.  Social security coordination 

The  implementation  of  the  Protocol  on  Social  Security  Coordination  to  the  TCA  (‘the 
Protocol’) was smooth, with no systemic or structural issues identified.   

To  provide  further  guidance  on  the  interpretation  of  certain  provisions  of  the  Protocol, 
namely  its  Article  SSC.11  on  the  legislation  applicable  to  detached  workers  and  self-
employed  persons  temporarily  working  outside  the  competent  State,  the  Specialised 
Committee on Social Security Coordination adopted Recommendation No 1/202440 on 5 June 
2024. 

On  8  November  2024,  the  Specialised  Committee  on  Social  Security  Coordination  adopted 
Decision No 1/2024, amending certain Annexes to the Protocol.41 The aim of this decision is 
to update the references to national legislation and policy choices of the States relevant to the 
implementation of the Protocol.  

Furthermore,  the  Specialised  Committee  on  Social  Security  Coordination  continued  its 
technical  work  on  various  topics,  including:  (i)  changes  to  structured  electronic  documents 
and portable documents; (ii) procedures for reimbursing the cost of sickness benefits; and (iii) 
the  transposition  of  relevant  decisions  of  the  Administrative  Commission  for  the 
Coordination of Social Security Systems. 

39 See press release: https://oceans-and-fisheries.ec.europa.eu/news/eu-and-uk-agree-fishing-opportunities-2025-
worth-eu14-billion-eu-fishers-2024-12-09_en. 

40 Recommendation No 1/2024 of the Specialised Committee on Social Security Coordination, OJ L, 2024/1754, 
24.6.2024, ELI: http://data.europa.eu/eli/reco/2024/1754/oj. 

41  Decision  No  1/2024  of  the  Specialised  Committee  on  Social  Security  Coordination,  OJ  L,  2024/3002, 
8.11.2024, ELI: http://data.europa.eu/eli/dec/2024/3002/oj.  

16 

 
 
 
 
 
 
 
4.9.  Law enforcement and judicial cooperation in criminal matters 

Implemention of the TCA in relation to law enforcement and judicial cooperation functioned 
smoothly. 

In  the  area  of  exchanges  of  DNA  profiles  and  fingerprints,  by  the  end  of  2024,      all 
Member States and the United Kingdom had granted each other access to their national DNA 
databases  for  automated  searching,  in  line  with  Article  530  of  the  TCA.  Additionally,  22 
Member  States42  and  the  United  Kingdom  granted  each  other  access  to  their  national 
databases for fingerprints, in line with Article 534 of the TCA. 

Regarding  the  exchange  of  vehicle  registration  data,  in  2024,  the  United  Kingdom 
informed  the  Specialised  Committee  on  Law  Enforcement  and  Judicial  Cooperation  that  it 
had  implemented  its  obligations  under  Part  Three,  Title  II  of  the  TCA.  Subsequently,  the 
Council initiated the procedure to evaluate this implementation in line with Article 540 TCA 
and Annex 39. On the basis of the evaluation report, the Council will decide on the date from 
which Member States may begin supplying data to the United Kingdom. The Member States 
and  the  United  Kingdom  will  then  be  able  to  conduct  automated  searches  in  each  others’ 
national databases under Article 537 TCA. 

4.10.  Association of the United Kingdom to certain EU programmes 

On 1 January 2024, in line with the conditions set out in Part Five of the TCA43, the United 
Kingdom became an associated country to Horizon Europe and the Copernicus component of 
the  Space  Programme  under  the  2021-2027  multiannual  financial  framework44.  The 
implementation  of  Part  Five  of  the  TCA  in  2024  has  in  general  proceeded  smoothly  with 
respect to these programmes. United Kingdom entities can now not only take part in the grant 
award  procedures  under  the  Horizon  Europe  programme  but  many  of  those  entities  have 
already received funding. 

In  2024,  under  Article  22(5)  of  Regulation  (EU)  2021/695  establishing  Horizon  Europe, 
United  Kingdom  entities  were  prevented  from  participating  in  certain  actions  under  the 
Horizon  Europe  programme  linked  to  the  EU's  strategic  assets,  interests,  autonomy,  or 
security.  This  restriction  to  the  participation  of  the  United  Kingdom  entities  applied  to  33 
actions  (out  of  approximately  1000  actions)  notably  in  the  areas  of  quantum  and  space 
research under the Horizon Europe Work Programme 2023-2024, out of which 3 actions are 
financed by 2024 budgetary appropriations and considered as exclusions under the TCA.  

A  specific  issue  to  highlight  is  the  difficult  conditions  faced  by  EU  researchers  benefiting 
from  Horizon  Europe  who  wish  to  exercise  mobility  towards  the  United  Kingdom,  due  to 
increased visa fees and the healthcare surcharge. At the Partnership Council meeting of May 

42 Austria, Belgium, Bulgaria, Croatia, Czechia, Denmark, Estonia, Finland, France, Germany, Hungary, Latvia, 
Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia and Sweden. 

43 See last year’s report for further information on the procedure for the association. 

44 The United Kingdom also obtained access to services of the EU Space Surveillance and Tracking component 
of the Space Programme. 

17 

 
 
 
 
2024,  the  EU  urged  the  United  Kingdom  to  revert  to  the  previous  levels  of  visa  fees  and 
healthcare surcharge. 

Additionally, the United Kingdom has benefitted from the services provided by Copernicus, 
and the United Kingdom entities have been able to participate in calls for tenders under the 
Copernicus component of the Space programme.   

In accordance with Article 730 of the TCA, a statistical cooperation arrangement was signed 
between  Eurostat  and  the  United  Kingdom  Statistics  Authority  on  9  October  2024.  This 
arrangement  sets  out  the  framework  for  collaboration  between  Eurostat  and  the  United 
Kingdom Office for National Statistics, enabling the exchange of statistical data relevant for 
the  United  Kingdom’s  participation  in  certain  EU  programmes.  The  arrangement  aims  to 
facilitate the sharing of statistical information to support decision-making in both the EU and 
the United Kingdom and is part of the ongoing implementation of the TCA. 

5. Developments in the law of the United Kingdom 

The  Commission  continued  to  monitor  closely  legislative  developments  in  the  United 
Kingdom, in particular with regard to their impact on the commitments under the TCA.  

This section summarises developments in the relevant laws of the United Kingdom that have 
a cross-cutting nature (Section 5.1.), that relate to subsidy control and taxation (Section 5.2.) 
and labour and social standards, environment and climate (Section 5.3). It looks at the most 
significant  legislative  proposals  (bills)  and  adopted  legislation  (acts).  In  cases  where 
legislation was adopted, the report highlights its relevance for the TCA. Announcements of 
policy intentions and public consultations are not covered. While these  announcements may 
indicate a policy direction, it would be premature to draw conclusions about their relevance 
for the TCA. 

5.1.  Cross-cutting matters 

The previous government  of the  United Kingdom  passed legislation  (the  Illegal  Migration 
Act45  and  the  Safety  of  Rwanda  Act46)  to  prevent  people  who  enter  the  United  Kingdom 
illegally from staying, but to detain and promptly remove them, either to their home country 
or  to  another  country.  The  Northern  Ireland  High  Court  ruled  on  13  May  202447  that 
provisions  of  the  Illegal  Migration  Act  are  incompatible  with  the  Windsor  Framework 
(Article 2(1)) and should be disapplied, and  it declared other provisions  to  be incompatible 
with  the  European  Convention  on  Human  Rights.  On  30  January  2025,  the  new  United 
Kingdom Prime Minister introduced to Parliament a new law on immigration48 which would 
repeal  the  Safety  of  Rwanda  Act  and  certain  provisions  of  the  Illegal  Migration  Act.  The 

45 Illegal Migration Act 2023: https://www.legislation.gov.uk/ukpga/2023/37. 

46 Safety of Rwanda (Asylum and Immigration) Act 2024: https://www.legislation.gov.uk/ukpga/2024/8. 

47 Summary of judgment - In re NIHRC and JR 295 (Illegal Migration Act 2023): 
https://www.judiciaryni.uk/judicial-decisions/summary-judgment-re-nihrc-and-jr-295-illegal-migration-act-
2023 
48 Border Security, Asylum and Immigration Bill: https://bills.parliament.uk/bills/3929. 

18 

 
 
  
 
 
Prime Minister also pledged that the United Kingdom would not withdraw from the European 
Convention on Human Rights. In the meantime, the Illegal Migration and Safety of Rwanda 
Acts  remain  on  the  statute  books,  although  most  of  their  provisions  have  not  been 
implemented. 

On 23 October 2024, the new government of the United Kingdom tabled the Data (Use and 
Access)  Bill.49  The  objective  of  the  Bill  is,  among  other,  to  reform  certain  elements  of  the 
data  protection  framework  in  the  United  Kingdom,  on  which  the  Commission  based  its 
decisions  concerning  the  adequacy  of  the  level  of  protection  for  personal  data.  The  Bill 
intends to make changes in several areas, notably on: (i) the legal grounds for the processing 
of personal data; (ii) the rules for the transfer of personal data to other countries; and (iii) the 
set-up  and  functioning  of  the  independent  data  protection  supervisory  authority.  The 
Commission will continue to monitor the legislative process.   

The  United  Kingdom  has  continued  to  develop  its  domestic  regulatory  framework  post-
Brexit,  with  significant  developments  including  the  Product  Regulation  and  Metrology 
Bill50.  This  Bill  allows  for  selective  alignment  with  updates  to  EU  product  and  metrology 
standards where beneficial.  

5.2.  Subsidy control and taxation 

The  Commission  continued  to  closely  monitor  the  United  Kingdom’s  subsidies  regime, 
focusing in particular on: (i) the functioning of the United Kingdom’s Subsidy Transparency 
Database;  (ii)  the  enforcement  activities  of  the  Subsidy  Advice  Unit  within  the  United 
Kingdom’s  Competition and Markets  Authority; and  (iii) the role of the  United Kingdom’s 
courts and tribunals in ensuring compliance with subsidy rules. 

In  this  context,  the  Commission  took  note  of  the  introduction  of  new  subsidy  initiatives, 
notably the National Wealth Fund51,  announced in the King’s Speech of 17 July  2024, and 
the  Great  British  Energy  Bill52.  The  Commission  will  remain  vigilant  to  ensure  the  full 
compliance  of  these  initiatives  with  the  subsidy  provisions  of  the  TCA  and  to  prevent  any 
negative  effects  on  trade  and  investment  between  the  EU  and  the  United  Kingdom.  The 
Commission  is  also  closely  monitoring  the  effectiveness  of  the  enforcement  system  of  the 
United Kingdom’s subsidy control regime. Discussions on these matters have been integrated 
into  ongoing  exchanges  in  the  framework  of  the  Trade  Specialised  Committee  on  Level 
Playing Field for Open and Fair Competition and Sustainable Development. 

49  Data  (Use  and  Access)  Bill  [HL]:  https://bills.parliament.uk/bills/3825.  The  Data  Protection  and  Digital 
Information (No 2) Bill of the previous government was discontinued.  

50 Product Regulation and Metrology Bill [HL]: https://bills.parliament.uk/bills/3752. 

51  The  National  Wealth  Fund  was  announced  in  the  King’s  Speech  of  17  July  2024.  Through  public  private 
partnerships,  the  National  Wealth  Fund  aims  to  mobilise  private  investment  for  the  United  Kingdom’s  clean 
energy transition. It will have a total capitalisation of £27.8 billion. 

52 The purpose of this Bill is to enable the Secretary of State for Energy Security and  Net Zero to designate a 
company  as  Great  British  Energy.  Great  British  Energy  will  be  a  company  wholly-owned  by  the  United 
Kingdom  Government.  Its  objectives  will  be  to  facilitate,  encourage  and  participate  in  the  production, 
distribution,  storage  and  supply  of  clean  energy;  the  reduction  of  greenhouse  gas  emissions  from  energy 
produced from fossil fuels; improvements in energy efficiency; and measures for ensuring energy security. 

19 

 
 
 
 
As regards taxation, in line with the Joint Declaration on Countering Harmful Tax Regimes 
adopted  alongside  the  TCA53,    the  EU  and  the  United  Kingdom  held  the  first  Dialogue  on 
Countering  Harmful  Tax  Regimes  in  Brussels  on  10  October  2024.  This  dialogue  aims  to 
facilitate discussions on shaping and implementing international standards to combat harmful 
tax  regimes,  particularly  those  standards  developed  under  the  OECD’s  Base  Erosion  and 
Profit Shifting (BEPS) 2.0 project. The meeting, co-chaired by the EU and United Kingdom 
delegations, provided an opportunity for both sides to share experiences and outlooks on: (i) 
Pillars  1  and  2  of  BEPS  2.0;  and  (ii)  parallel  developments  at  the  United  Nations.  This 
constructive exchange reflects the TCA’s commitment to fostering cooperation on key global 
challenges while respecting respective powers in the field of direct taxation. 

5.3.  Labour and social standards, environment and climate 

The  EU  has  closely  monitored  developments  related  to  the  Employment  Rights  Bill, 
including  the  announced  repeal  of  the  Strikes  (Minimum  Services  Level)  Act  on  6  August 
202454.  These  issues  were  addressed  during  the  fourth  meeting  of  the  Trade  Specialised 
Committee  on  Level  Playing  Field  for  Open  and  Fair  Competition  and  Sustainable 
Development,  held  on  9  October  2024.  At  this  meeting,  the  EU  and  the  United  Kingdom 
discussed  their  ongoing  cooperation  within  the  International  Labour  Organization,  focusing 
in particular on the development of a new instrument aimed at regulating platform work. 

In  February  2024,  the  United  Kingdom  introduced  a  mandatory  Biodiversity  Net  Gain 
requirement,  aimed  at  improving  nature  restoration  through  a  10%  net  gain  in  biodiversity. 
This measure introduces additional environmental conditionality in planning and permitting. 
The potential impact on trade and investment remains to be seen. 

6. Conclusions 

The Trade and Cooperation Agreement (TCA) remains a strong and effective foundation for 
EU-United  Kingdom  relations.  It  is  a  very  good  agreement  and  offers  the  best  possible 
outcome  within  the  red  lines  drawn  by  the  United  Kingdom.  While  it  does  not  replace  EU 
membership, the Agreement strikes a balance that ensures meaningful cooperation across all 
relevant areas. 

As  highlighted  in  this  report,  the  TCA  has  already  yielded  important  results,  but  its  full 
potential has yet to be fully explored. There is still scope to  increase its impact and deepen 
EU-United Kingdom collaboration.  

In  line  with  the  Commission’s  political  guidelines  for  2024-2029,  which  emphasise  the 
importance  of  strengthening  ties  with  like-minded  partners  in  an  increasingly  competitive 
global  environment,  the  Commission  is  committed  to  building  on  this  framework.  By 
aligning  efforts  with  these  broader  strategic  goals,  the  TCA  plays  a  key  role  in  advancing 

53 OJ L 444, 31.12.2020, p. 1475, ELI: http://data.europa.eu/eli/declar/2020/2252/oj.  

54 https://www.gov.uk/government/news/public-services-back-on-track-as-strikes-act-to-be-repealed. 

20 

 
 
 
 
 
cooperation  with  the  United  Kingdom,  promoting  shared  priorities,  and  contributing  to  a 
stable and constructive partnership in a rapidly changing geopolitical landscape. 

21 

 
 
 
Annex 1: Meetings in 2024 of the joint bodies and other structures 
established by the TCA  

Date 

Joint body/structure 

2 February 

Dialogue on Counter-terrorism: 1st meeting 

5 March 

20 March 

24 April 

16 May  

16 May 

22 May 

23 May 

5 June 

12 June 

19 June 

31 July 

EU Domestic Advisory Group: 10th meeting 

Fisheries (Working Group): 7th meeting 

Medicinal Products (Working Group): 1st meeting 

Partnership Council: 3rd meeting 

Motor Vehicles and Parts (Working group): 1st meeting 

EU-United Kingdom Financial Regulatory Forum55: 2nd meeting 

Fisheries (Specialised Committee): 8th meeting 

Social Security Coordination (Specialised Committee): 4th meeting 

Organic Products (Working Group): 1st meeting  

EU Domestic Advisory Group: 11th meeting 

Fisheries (Working Group): 8th meeting 

4 September 

Air Transport (Specialised Committee): 4th meeting 

19 September  EU Domestic Advisory Group: 12th meeting 

20 September  Civil Society Forum: 3rd meeting 

24 September 

Fisheries (Specialised Committee): 9th meeting 

30 September 

Administrative Cooperation in VAT and Recovery of Taxes and Duties 
(Trade Specialised Committee): 4th meeting 

3 October 

7 October 

9 October 

Public Procurement (Trade Specialised Committee): 4th meeting 

Technical Barriers to Trade (Trade Specialised Committee): 4th meeting 

Level Playing Field for Open and Fair Competition and Sustainable 
Development (Trade Specialised Committee): 4th meeting 

10 October 

Dialogue on Harmful Tax Regimes:56 1st meeting 

17 October 

21 October 

Customs Cooperation and Rules of Origin (Trade Specialised Committee): 
4th meeting 

Sanitary and Phytosanitary Measures (Trade Specialised Committee): 4th 
meeting 

23 October 

Goods (Trade Specialised Committee): 4th meeting 

55 Pursuant to the Joint Declaration on Financial Services Regulatory Cooperation between the European Union 
and the United Kingdom, made by the Parties on the occasion of the conclusion of the TCA. 

56  Pursuant  to  the  Joint  Political  Declaration  on  Countering  Harmful  Tax  Regimes,  made  by  the  Parties  on 
occasion of the conclusion of the TCA. 

22 

 
 
 
 
24 October 

Services, Investment and Digital Trade (Trade Specialised Committee): 4th 
meeting 

4 November 

Regulatory Cooperation (Trade Specialised Committee): 4th meeting 

7 November 

Energy (Specialised Committee): 5th meeting 

13 November 

Intellectual Property (Trade Specialised Committee): 4th meeting 

14 November  Road Transport (Specialised Committee): 4th meeting 

21 November  Aviation Safety (Specialised Committee): 4th meeting 

5-6 December  Dialogue on cyber issues: 2nd meeting 

11 December 

Participation in Union Programmes (Specialised Committee): 4th meeting 

12 December 

EU Domestic Advisory Group: 13th meeting  

12 December 

Trade Partnership Committee: 4th meeting 

13 December 

Law Enforcement and Judicial Cooperation (Specialised Committee): 4th 
meeting 

23 

 
 
 
 
Annex 2: Overview of the actions for implementation agreed by 
the Partnership Council on 16 May 2024 

Topic 

State of play 

Working Group on Energy 
Security of Supply 

COMPLETED:  Working  Group  established  by 
Specialised Committee on Energy on 7 November 2024. 

the 

Roadmap on Efficient 
Electricity Trading 
Arrangements 

Agreement on Competition 
Cooperation 

United Kingdom Access to 
the EU’s Rapid Alert 
System for Dangerous Non-
Food Products (Safety Gate) 

Joint Action Plan between 
the European Centre for 
Disease Control (ECDC) 
and its United Kingdom 
counterpart 

United Kingdom Access to 
EU vehicle registration data 

COMPLETED:  Roadmap  agreed  by 
Committee on Energy on 7 November 2024. 

the  Specialised 

NEAR COMPLETION: Technical discussions concluded at 
the end of October 202457. Ratification procedures underway 
by both Parties for formal conclusion.  

ONGOING: Technical discussions are still in progress.  

COMPLETED: Joint Action Plan became operational on 15 
July 2024. 

ONGOING: Preparatory work is in progress. On 20 May, the 
United Kingdom submitted its letter of readiness, stating that 
it had implemented the obligations under Part Three Title II of 
the TCA. Subsequently, the competent Working Parties in the 
Council  of  the  EU  initiated  the  evaluation  procedure  under 
Article 540 TCA. 

Arrangements for 
information exchange on 
transport managers and road 
haulage operators 

ONGOING: Two decisions by the Specialised Committee on 
Road Transport required – on a common list of infringements 
and on the modalities for the United Kingdom’s reconnection 
to 
the  ERRU  (European  Registers  of  Road  Transport 
Undertakings). 

57 Press release: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_5468. 

24 

 
 
 
 
 
Annex 3: Decisions and recommendations adopted by the 
Partnership Council or Committees established by the TCA in 2024 

Date 

5 April 

5 June 

Decision or Recommendation 

Decision  No  1/2024  of  the  Specialised  Committee  on  Energy  on  the 
guidance  on  frameworks  for  cooperation  between,  respectively,  ENTSO-E 
and  the  United  Kingdom  transmission  system  operators  for  electricity, 
ENTSOG  and  the  United  Kingdom  transmission  system  operators  for  gas, 
and ACER and the regulatory authority in the United Kingdom designated in 
accordance  with  Article  310  of  the  Trade  and  Cooperation  Agreement 
(GEMA and Utility Regulator)58 

Recommendation  No  1/2024  of  the  Specialised  Committee  on  Social 
Security Coordination as regards further guidance on the implementation of 
the  Protocol  on  Social  Security  Coordination  to  the  Trade  and  Cooperation 
Agreement (the Protocol) concerning the interpretation of Article SSC.11 of 
the  Protocol  on  the  legislation  applicable  to  detached  workers  and  self-
employed persons temporarily working outside the competent State59 

30 September  Decision  No  1/2024  of 

the  Trade  Specialised  Committee  on 
Administrative  Cooperation  in  VAT  and  Recovery  of  Taxes  and  Duties 
amending  Decision  4/2023  on  standard  forms  for  the  communication  of 
information  and  statistical  data,  the  transmission  of  information  via  the 
Common  Communication  Network  and  the  practical  arrangements  for  the 
organisation  of  contacts  between  central 
liaison 
departments60 

liaison  offices  and 

5 November  Decision No 1/2024 of the Partnership Council  modifying Annex 3 to the 

Trade and Cooperation Agreement (Product Specific Rules of Origin)61 

7 November  Decision No 2/2024 of the Specialised Committee on Energy as regards the 

establishment of a Working Group on Security of Supply62 

8 November  Decision  No  1/2024  of  the  Specialised  Committee  on  Social  Security 
Coordination as regards the amendment of certain Annexes to the Protocol 
on Social Security Coordination63 

58 OJ L, 2024/1550, 31.5.2024, ELI: http://data.europa.eu/eli/dec/2024/1550/oj. 

59 OJ L, 2024/1754, 24.6.2024, ELI: http://data.europa.eu/eli/reco/2024/1754/oj. 

60 OJ L, 2024/2736, 24.10.2024, ELI: http://data.europa.eu/eli/dec/2024/2736/oj. 

61 OJ L, 2024/2837, 6.11.2024, ELI: http://data.europa.eu/eli/dec/2024/2837/oj. 

62 Decision No 2/2024 of the Specialised Committee on Energy: 741b6df6-7270-4cb1-b00e-9ac18a1e12b7_en. 

63 OJ L, 2024/3002, 8.11.2024, ELI: http://data.europa.eu/eli/dec/2024/3002/oj  

25 

 
 
 
19 December  Recommendation  No  1/2024  of  the  Specialised  Committee  on  Energy  to 
each Party concerning the preparation of technical procedures for the efficient 
use of electricity interconnectors64 

64 Recommendation No 1/2024 of the Specialised Committee on Energy: 388d6f57-7f4a-46b1-802f-
7ea585673517_en. 

26