ABSTRACT
The procurement regulation which the UK would be subject to in the event of an EU exit largely depends on the type of trading relationship the UK maintains with the EU. There are a few potential trading ‘models’ which could be emulated in the developing EU-UK relationship (Tables 5.1 and 5.2). An analysis of these models offers guidance as to how UK procurement regulation could develop if one of these models were to be adopted. The trading model which aligns most closely with the current EU procurement regime is the European Economic Area (“EEA”) model, in which the UK would largely retain the same procurement regime. Other models include the European Free Trade Association (“EFTA”) model and a model based on the EU’s trade arrangement with Canada 1 . There is also the World Trade Organisation’s (“WTO”) Government Procurement Agreement (“GPA”), which offers a more lightly regulated option, with some recognisable key principles. Examining the EU’s procurement arrangements with Turkey and Ukraine also offers a perspective on potential future arrangements.
