The results of the Brexit referendum are proving to be as much a threat to the United Kingdom's unity as they are to the unity of the European Union. For Scotland and Northern Ireland, two countries in the United Kingdom where a majority of voters opted to remain in the European Union, the decision to leave the Continental bloc is especially concerning. Scotland's 2014 independence referendum and more recent opinion polls in Northern Ireland highlight their dilemma: Voters in each place want to remain in both the United Kingdom and the European Union. This contradiction will shape London's negotiations with the European Union over the future of their relationship.
Over the past two decades, political negotiations (most notably, the Good Friday Agreement of 1998) have significantly reduced tension between Northern Ireland and the government in London. The peace process also opened the border between the two Irelands — which was heavily militarized during The Troubles — giving people on both sides some sense of unity. Today, thousands of people cross the border every day to go to work, run errands or take a vacation. But now the Brexit vote has thrown the future of the island into question.
Politicians in the Republic of Ireland are watching the situation in Northern Ireland closely and discussing a possible reunification. Irish Prime Minister Enda Kenny said Monday that if the people of Northern Ireland want to leave the United Kingdom, they should be able to decide by vote to join the Republic of Ireland instead. The day before that, the leader of the country's main opposition party made similar statements. Depending on the terms of the United Kingdom's new relationship with the European Union, the Republic of Ireland could end up bordering a non-EU member state, where the free movement of goods, services and people no longer applies. In that case, border controls between the two Irelands would need to be reinstated, a prospect that could increase popular support in Northern Ireland for reunification.
So far, most people in Northern Ireland want to stay in the United Kingdom. Opinion polls conducted before the Brexit referendum showed that Northern Irish voters would rather receive greater autonomy from London than reunite with the Republic of Ireland. But that could change. Though religion and national identity play an important role in this position, economic well-being is also a concern. The more the British economy suffers because of the Brexit, the more likely people will be to demand a reunification referendum. Of the states in the United Kingdom, Northern Ireland is the most dependent on EU support, including agricultural subsidies and development aid for infrastructure. Moreover, companies currently operating in Northern Ireland could decide to relocate to the Republic of Ireland to continue their business with the European Union. So even though Northern Ireland's first minister rejected Kenny's proposal to have a cross-border debate over the impact of Brexit, a weak economy, rising unemployment or falling subsidies could revive the reunification campaign.
Scotland, where 65 percent of the electorate voted to stay in the European Union, faces a similar conundrum. After the Brexit vote, the Scottish government said it would try to preserve the country's access to the Continent and raised the possibility of a second referendum on independence from the United Kingdom. In 2014, 55 percent of Scottish voters elected to remain in the United Kingdom, but leaving the European Union could change people's opinions. The British government is aware of the risks. Shortly after her appointment to office, Prime Minister Theresa May visited Scotland to meet with the first minister, and she has suggested that the need to find common ground with Scotland was a reason for postponing formal negotiations with Brussels.
Of course, it is not unheard of for only part of an EU country to leave the bloc. In the 1980s, Greenland, which is part of Denmark, left the European Community following a referendum while Denmark retained its membership. But Greenland is an island unto itself, which made the separation relatively easy. (Likewise, the United Kingdom's Isle of Man and Channel Islands are not part of the European Union.) Scotland, on the other hand, occupies the same island as England and Wales, and they have no border controls between them. Much as Northern Ireland's change in EU membership would affect its open border with the Republic of Ireland, Scotland's continued access to EU goods, services and workers would require some form of border control with England and Wales. It would be hard for Scotland to retain EU membership without forsaking its place in the United Kingdom.
For now, the Scottish government will refrain from taking bold or unilateral action. Instead, Scotland will likely wait to see what the final agreement between the United Kingdom and the European Union looks like before making any significant moves, while using the threat of a new independence referendum to influence the negotiations. Since a final exit agreement will not be ready for at least two and a half more years, the threat of Scottish independence — though no less real — is not immediate.
Meanwhile, the United Kingdom will have to decide what kind of relationship it wants to have with Europe. It could choose to emulate Norway, whose membership in the European Economic Area gives it access to most EU structures despite the fact that it is not in the Continental bloc. Because Norway participates in the common market and does not have border controls with neighboring EU members Sweden and Finland, following its example could alleviate migration and trade concerns in Northern Ireland and Scotland.
But doing so would also mean accepting EU workers, which could irritate British voters who saw the Brexit as a chance to reduce immigration to the United Kingdom. During the referendum campaign, members of the "leave" camp dismissed the possibility of pursuing a Norway-style association agreement for that very reason. May even said that ending the free movement of European workers was more important than preserving the United Kingdom's access to the EU internal market. Even so, Northern Ireland and Scotland will pressure London to reach a deal with the European Union that is as similar to the pre-Brexit situation as possible. And as the United Kingdom negotiates its exit from the European Union, the threat of territorial disintegration will weigh heavy.