by Maxime Larivé

July 8, 2016

In 2014, Scotland decided to remain in the United Kingdom (UK) for one reason: membership in the European Union (EU). Two years later, citizens of the UK decided at 51.8% to leave the EU, known as Brexit. If most of the analyses have focused on the consequences of the Brexit on UK-EU relations, UK-US special relationship, and other economic outcomes, the Brexit raises an important question about the future unity of the United Kingdom and Scottish inclusion in the EU.

On June 23, Scotland with Northern Ireland and the City of London voted in favor of remaining in the EU. Hours after the results of the referendum, Scottish Prime Minister Nicola Sturgeon declared that Scotland was taken out of the EU out of its will. “The vote across England and Wales was a rejection of the EU,” said PM Sturgeon “and it was a sign of divergence between Scotland and large parts of the rest of the UK and how we see our place in the rest of the world.” Such a statement clearly underlines the deep divisions within the United Kingdom.

A lot of the talks have been about UK membership in the EU. But until the article 50 of the Treaty of Lisbon is invocated by the exiting member state, such a member state keeps its membership, its duties, and its responsibilities. It may take some time for Scotland to explore its options, as Britain has an ongoing deep political crisis. Prime Minister Cameron announced hours after the results in favor of the Brexit that he will be resigning in early fall and that his successor will be the one undertaking the exiting process. This announcement triggered a political crisis within the governing party, the Tories, and the Brexit camp. The two leaders of the Brexit campaign, Boris Johnson and Nigel Farage have declared that they will not be candidates to succeed to Cameron leaving a surprising political void.

During a summit of EU heads of states and governments at the end of June, France and Spain underlined that they would not initiate or even entertain the idea of talks about Scotland’s role in the EU. Spanish Prime Minister Rajoy explained at the summit that Scotland does not have the competence to negotiate with the EU. He continued by claiming that if “the UK leaves, Scotland leaves.” From Madrid, the line of conduct is clear, avoiding any empowerment of regional independence. François Hollande, the French President, continued by clarifying that the exiting process will take place between the UK and the EU, not with Scotland.

So what are the options for Scotland in order to fulfill its desire to remain in the EU? In a report published by the French think tank, Friends of Europe, Kristy Hughes argues that Scotland has four choices in the face of Brexit: first, leave the EU with the rest of the UK; second, move rapidly to a second independence referendum with the aim of returning to the EU; third, challenge and stall or block the Brexit process, creating a deep political and constitutional crisis; and fourth, leave the EU with the rest of the UK, and argue for Scotland to have the power to negotiate a differentiated relationship with the EU that is closer than the rest of the UK may choose.

But the lack of desire from London to even talk of a divorce with the EU until the next appointment of a Prime Minister is creating an unprecedented crisis in Europe. Discussions between Britain and Scotland are ongoing; but, according to David Lidington, Minister for Europe at the UK Foreign Office, Scotland’s future relationship with the EU will be from the outside. Until London clarifies its position and long-term interests and relationship with the EU, Scotland may very well have to wait.

Maxime H. A. Larivé, Ph.D., is the Associate Director of the European Union Center at the University of Illinois at Urbana-Champaign.