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British Öresund commuters protected from no-deal Brexit: UK embassy

British citizens who already live in Sweden and commute across to the Öresund Bridge to work in Copenhagen will be able to continue working under the same tax and employment conditions as today, even if there is a 'no-deal' Brexit.

Published: 12 March 2019 10:27 CET
Updated: 12 March 2019 15:03 CET

British Öresund commuters protected from no-deal Brexit: UK embassy

About 150 British people came to the meeting at Malmö's Town Hall. Photo: Richard Orange/The Local

“In the case of no deal, provided that you were working in Copenhagen at the time of whatever exit date, then you are fine to keep on in that existing employment,” Dr Jonas Bruun, from the British embassy in Copenhagen, told UK citizens at a town hall meeting in Malmö on Monday evening, attended by The Local.

But those who are now looking for a job in Copenhagen, or those who have a job but then lose it, face a more uncertain situation.

“It becomes a little bit more complicated if you lose that job in a no-deal situation,” Bruun said. “The Danish legislation does not cover what will happen in that situation.”

Bruun later told The Local that the Danish Ministry of Employment had confirmed to him that anyone with the status of 'frontier worker' at the time of the UK's exit from the European Union would still be able to receive unemployment benefit if they lost their jobs.

They would also be able to change jobs between Danish employees without altering their situation.

They would not, however, be able to move to take a new job in Sweden and then return to working in Denmark with the same rights.

“You can go from Lego to Carlsberg. But you can't work in Sweden and then come back,” he said.

Those who lose their 'frontier worker' status will no longer be able to take advantage of the deal between Sweden and Denmark over 'frontier workers', and will instead be treated in the same way as “third country citizens”, unless or until a new deal is reached to cover this.

Jonas Bruun (left), a policy officer at the British Embassy in Copenhagen and Peter Ruskin (right) Deputy Head of Mission at the British Embassy in Stockholm. Photo: Richard Orange

Under a 2003 deal between Denmark and Sweden, workers commuting across the Öresund Bridge pay income tax in Denmark at the same time as receiving healthcare, education and other welfare in Sweden.

The problem for Öresund commuters stems from the fact that while Sweden last week announced a one-year 'grace period' for UK citizens, Denmark is not offering a similar arrangement.

READ ALSO: Here's what Brits in Sweden will need to do if there's a no-deal Brexit

Meggan Collins, who lives in Malmö but who has been studying architecture in Copenhagen, said she was disappointed that British cross-border workers would only be able to take advantage of the Öresund deal if they already had jobs.

“This puts me in a pretty sticky situation,” she told The Local. “A lot of the architecture jobs are in Denmark, not in Malmö, so I do feel a bit threatened now.”

She said she was worried that the starting salary for a newly qualified architect in Denmark would be too low to qualify her for a work permit under Denmark's points system for third country nationals, and that the six-month contracts normally offered would be too short.

“I'm graduating in Denmark with a Danish degree that I've been doing for seven years now, and I'm going to come out not being able to get the highest job that I can in Denmark.”

Meggan Collins and her British boyfriend Jacob Coles. Photo: Richard Orange

Lawmakers in London are set to vote on Prime Minister Theresa May's Brexit deal on Tuesday, a day after May said she had secured a new and improved deal to leave the EU.

The British PM said on Monday she had secured “legally binding” guarantees from the EU designed to get the Brexit deal through the British parliament and avert a chaotic withdrawal.

She announced the move after a late evening dash to Strasbourg to hammer out the changes with top European officials, as the clock ticked down to Britain's scheduled divorce from the bloc on March 29th.

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INTERVIEW: How best to respond to the Sweden Democrats' Swexit gambit

In tweets, interviews, one article in the Aftonbladet tabloid and a second one in Svenska Dagbladet newspaper, Sweden Democrat leader Jimmie Åkesson outlined his party’s new tougher position, with calls for mandatory referendums on extensions of EU powers, an analysis of how to reduce the negative impacts of EU membership, and, finally, cautionary preparations to leave.

Vi sverigedemokrater vill nu utreda hur vårt land kan förhindra mer maktöverföring till EU, maximera vårt inflytande och nå bättre förhandlingsresultat. Det skriver Jimmie Åkesson och Charlie Weimers.https://t.co/xORmEgulzB

— SvD Debatt (@SvDDebatt) May 16, 2023

For Manners, a political scientist and EU expert, this is all about repositioning the party.

“He’s caught in a very difficult position in that he’s effectively in a governing coalition, although they’re not in government, and they have no clear anti-system position, because they are in effect part of the ruling coalition in some strange way.”

Reviving a battle against the EU would allow the party to position itself against the broadly pro-EU Moderate and Liberal parties in the coalition, and also against the Social Democrats, Green and Centre parties of the opposition.

“In some respects, this is an attempt to ignite support within the party for something distinctive that makes them look different to the other three partners in the ruling coalition,” Manners explained.

It will also, though, help it find someone to blame if some of its most prominent policies wins fail to make it through parliament and into Swedish law.

Åkesson and other leading Sweden Democrats, Manners believes, are quickly realising that many of the most hardline policies on migration, energy and environment won in the agreement with the three governing parties will be impossible to enact, as they clash with laws already agreed at an EU level or with the European Convention on Human Rights, or will be challenged by the European Court of Human Rights.

“What’s become clear over time is that almost nothing EU-related in the Tidö Agreement has materialised in the way that Åkesson, or in fact the other parties, imagined,” Manners said.

This has probably come as a shock, he added.

“I’ve met enough SD MPs and MEPs that I don’t think they have that sense of consciousness of what it might mean to enter into a ruling coalition agreement like the Tidö Agreement and the extent to which it would be literally impossible to enact some of the policies made, so I think this probably comes as a little bit of a surprise for them.”

The European Court of Human Rights and the European Convention on Human Rights, he pointed out, “really binds your hands on a lot of the migration issues and on the treatment of refugees”.

The same was true for a slew of other policies in the agreement, as anyone with an understanding would have known.

“It was quite clear that actually, the government can have little influence over EU energy policy and environment policy and to a certain extent other EU-associated policy,” Manners said. “These are policies that are quite distinctly agreed at the EU level, not at national levels.”

As the Sweden Democrats have realised this, their animosity to the EU, downplayed since 2019, has revived.

Åkesson’s two articles, while stopping short of calling for Sweden to leave the European Union, contain some radical proposals nonetheless.

The first article complained that EU membership was becoming like “a straitjacket” for Sweden, with EU decisions determining Swedish legislation over forestry, vehicles and fuel, and much of what happens in regional and local government.

The second proposed three government inquiries designed to prevent more powers being transferred from Sweden to the EU:

an inquiry into mandatory referendums on any significant extension of EU powers or funding requirements
an inquiry into what actions Sweden can take to ensure that it is prepared to leave the EU, such as removing parts of constitution which state that Sweden is an EU member and training civil servants in trade negotiations
an inquiry into reducing the negative impacts of EU membership, by analysing which EU directives have been “over-implemented”, and ensuring that Sweden only meets the minimum requirements of EU laws

Manners said that the referendum inquiry was the one that the government should perhaps be most wary of.

“If I were the Sweden Democrats, I would be after a referendum and I think that’s what they want: anything that splits both their enemies and their coalition members,” he said.

Rather than an in-out referendum on EU membership, like the one held in the UK, the Sweden Democrats were probably hoping instead to engineer a referendum on a future planned extension of EU powers.

Manners thinks that pro-European Union forces in Sweden should learn from the example of the UK and go into action as soon as possible, moving to educate the Swedish public in advance not only of the risks of leaving the EU, but also of having the kinds of opt-outs from some EU policy areas, as Denmark has had.

After Danish voters rejected the Maastricht Treaty in a 1992 referendum, the country obtained four opt-outs from the treaty, covering the Euro, defence and security policy, justice and home affairs, and citizenship.

The result, Manners argues, was “a total waste of diplomatic capital”, with Denmark’s government and EU diplomats spending all their time managing their opt-outs, meaning they had no energy to push forward other policies they wanted to advance in the EU.

While the idea of Sweden rejecting a core piece of future EU legislation, let alone voting to leave the EU, may seem far-fetched, Manners said experience showed it was all too possible.

“It seems hard to imagine in Sweden, but having seen it happen in the UK, and certainly in Denmark over and over (…) it comes with a surprise and it comes with a shock. And the surprise is that anyone is stupid enough to hold a referendum, and the shock is that you have no way of predicting what will happen at any referendum.”

For the Sweden Democrats, a referendum would allow it to dominate one whole side of the debate, attracting any voters wishing to prevent the expansion of EU powers.

However the risks of the new policy gambit were at least as big as the potential benefits, Manners argued, with few supporting the proposed ideas even within the Sweden Democrats.

“I think actually it will quite possibly backfire. If you look at some of the dog whistle sentences in the article in Aftonbladet, one is, ‘we need to evaluate our membership of the EU’. Well, there’s literally no support for that.”

A recent survey of Swedish voters, carried out by the SOM Institute at Gothenburg University, found that support for EU membership was higher today than at any time since Sweden joined the EU in 1994, with 68 percent of voters in favour and only 11 percent against.

This was even the case for Sweden Democrat voters, a full 43 percent of whom said they were “essentially in favour” of Swedish EU membership, up from 23 percent as recently as 2021. Only 31 percent of Sweden Democrats said they were “essentially against” EU membership.

This picture could change if Åkesson and his party colleagues start to campaign on the issue and Manners said he thought it was important for pro-EU forces in Sweden to use this opportunity to make their case.

“The place that Swexit would really hurt is down here in the south of Sweden,” he said, based in Lund. “Imagine all the agriculture and the small and medium-sized industries in Skåne. Imagine all the transport and commuters, all the jobs that are dependent on flowing across the bridge. It’s going to get hurt twice as bad as the rest of Sweden. And this is the base for the Sweden Democrats.”

He said he believed that pro-EU politicians and media in Sweden should actively discuss the most concrete, material impacts of leaving the European Union.

He mentioned the long queues of trucks you would expect ahead of the Öresund Bridge, the likely impact on the krona, or the impact on the big investment decisions currently being made in the north of Sweden in car battery manufacturing or Green Steel.

Even having the debate or putting in place the inquiries Åkesson was proposing could risk these investments or affect the currency, said Manners.

“Countries do need to have a discussion about what it might potentially mean to leave the EU, so that there is a far greater awareness of the heightened risks,” he said. “Because we never had that discussion in the UK.”

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