UK prime minister Keir Starmer spent much of 2025 trying to persuade voters that there was substance to the ‘reset’ on EU-UK relations which he has been talking about since taking power in July 2024.

His government’s so-called ‘Brexit Reset’ bill will make the most substantive changes so far.

The reset bill was promised last year and though it has not yet been published — it is likely to come out by early February — briefings by UK ministers indicate that it will give them the power to align the UK’s rulebook with the EU on goods and services. The likely first step will be an agreement to align the UK’s rules on agricultural production and phytosanitary standards.

Nothing related to Brexit is without controversy in the UK and Starmer’s critics in London say that the bill is a ruse to unpick Brexit by stealth. 

But public opinion, for once, is with Starmer: Last week, a survey published by Yonder Data Solutions for FGS Global, a PR firm, found that 72 percent of Britons believe that leaving the EU has been damaging to their economy, immigration control, and national sovereignty. 

Some ministers have started to say that leaving the EU is part of the cause of the UK’s economic woes – comments that were taboo ever since the June 2016 referendum on quitting the single market. 

The governments of former prime ministers Theresa May and Boris Johnson rejected “dynamic regulatory alignment” — a process that would have seen the UK copy and paste EU laws onto its own statute — during the post-Brexit negotiation process.

Instead, the UK’s Trade and Co-operation Agreement (TCA) gives it the right to diverge from EU law.

But in practice, both the conservative government of former PM Rishi Sunak and Starmer’s new Labour administration have introduced laws on digital services, carbon pricing, and emissions cuts that are very similar, if not identical, to the EU’s. 

Almost all of the trade deals that the UK has cut with other countries are also nearly identical to the EU’s own trade pacts. 

Overhaul

The bill is almost certain to be welcomed by most of Starmer’s Labour MPs, the bulk of whom opposed Brexit and accepted it only reluctantly.

They are also likely to support a draft bill proposed by the Liberal Democrats that would take the UK into a customs union with the EU, and which will be voted on in the coming weeks — that will cause a headache for Starmer who has publicly ruled out a customs union. 

But not everyone wants an overhaul.

The TCA is due to be reviewed in 2026, five years after it came into force. The International Chambers of Commerce UK, a trade lobby group, argued in a paper published on 7 January, that ministers could increase EU-UK trade without renegotiating the TCA by instead “focusing on digital trade, paperless borders, and cutting red tape”. 

“Businesses cannot afford to wait years for new treaties, nor need them in the short term,” said ICC UK’s secretary general, Chris Southworth. 

Nor has there been much appetite among EU officials to reopen the TCA.

Both sides believe that the policy areas ripe for ‘reset’ can be done via the existing TCA: For example, provisions to allow UK students to participate in the EU’s ‘Erasmus+’ student exchange programme – announced in December – already existed in the TCA, but the Sunak government had complained that the price tag for access was too high. 

Money, and the UK’s contribution in exchange for being part of EU programmes, will likely be the main sticking point.

Last year, talks between the EU Commission and the UK on access to the ‘SAFE’ defence procurement plan collapsed when the EU demanded an access fee of several billion euros, while the UK was not prepared to go beyond tens of millions. 

On phytosanitary standards and emissions trading, the EU expects the UK to pay contributions for infrastructure and to the bloc’s cohesion policy. 

The EU also wants safeguards should there be a new government in the next few years. 

While closer EU relations are broadly popular and Starmer’s Labour party has a 160-seat majority, to push them through parliament, the Starmer government itself is toxically unpopular, languishing close to 20 percent in the polls, around 10 points behind Nigel Farage’s anti-EU Reform party. 

That explains why the EU has demanded a ‘Farage clause’ to provide guarantees that a Reform-led government will pay for the cost of re-introducing infrastructure and border checks on goods and farm produce. 

But this could be less of a guarantee than it sounds.

Farage insists that his government would refuse to pay up, taking us back to the days when Boris Johnson, as prime minister, threatened to table a law overriding the Northern Ireland protocol, and the EU initiated legal action. 

Any ‘reset’, in other words, is likely to be fragile. 

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