Brexit’s obscure impacts: the borders of Cyprus

Brexit’s obscure impacts: the borders of Cyprus 1 avril, 2018

The territorial issues concerning Brexit are the boundary between Northern Ireland and the Republic of Ireland, and, although a bit less well-known, the boundary between Gibraltar and Spain. But there is a third one, very less-publicised: the boundary between the UK military areas of Akrotiri and Dhekelia, and Cyprus. It’s not something small since they together make up for 3% of the territory of the island of Cyprus, and thousands of Cyprus citizens, therefore EU citizens, work and live there. Consequently, what are exactly these two UK military bases doing there? And more importantly, how do they pose a problem since Brexit, where are the current negotiations about this, and what kind of agreements could be found?

What are Akrotiri and Dhekelia?

The UK has retained two Sovereign Base Areas (SBAs) on Cyprus under the 1960 Treaty of Establishment for the independence of its former colony Cyprus: the base of Akrotiri and the base of Dhekelia. They are not just composed of an airfield or a military harbor: they are like small towns, with factories, schools, agricultural fields, and more that 7,700 native cypriots live in the area themselves (CIA, 2018). The two military zones have British Overseas Territory status, such as St-Barthelemy since 2012, which means that they are out of the EU. Therefore, there are less implications than with Gibraltar or Ulster for instance, which is in the EU. However, the two bases do apply and respect some EU laws because of a Protocol annexed to the Act of Accession of Cyprus in 2004 (Lang and Miller, 2017). Therefore, Brexit will have an impact there as well. We will go into more details in the next chapter.

Briefly speaking, the two military bases are 254 km square, and geostrategically useful to monitor and intercept data transmissions from the Middle East. While Akrotiri only has a border with Greek Cyprus, Dhekelia only has a small boundary, the rest of it is conterminous with the Turkish-Cypriot administered area, which is outside the EU and therefore not relevant to any of the issues in this article.

Which implications for Cyprus?

Under Article 2(1) of the Protocol, the SBAs are partially part of the EU customs union in three domains: VAT, agriculture and fisheries. Since the SBAs are already outside the EU, will they keep these three domains anyway? Anyhow, concerns have been raised about the future status of around 15,000 Cypriots – EU citizens – working in the SBAs. “It matters for Cyprus if it’s a hard or soft Brexit,” Cypriot Foreign Minister Ioannis Kasoulides said in an interview (Georgiou and Tugwell, 2017). We can understand why: Brexit could impact the free movement of Cypriot workers in the SBAs, as well as their right to settle, openly start business, get their social security, and freely send their children to the few schools present in the zones. If there’s no overall Brexit deal, Cypriot farmers producing goods in the base areas may not get any subsidies from the Common Agricultural Policy for instance.

Moreover, Akrotiri and Dhekelia followed Cyprus after the adoption of the euro in 2008, making the Sovereign Base Areas the only territory under British sovereignty to officially use the euro (Theodoulou, 2008). Consequently, will the euro stay eligible after Brexit? It is likely since these two territories are already outside the euro area anyway, but we never know, it’s something to keep in mind. Finally, even the sovereignty of the area around the bases themselves could be at stake.

What can be negotiated?

Cyprus, Ireland and Spain are the only three EU countries that have been given the green light to conduct bilateral talks with the UK on a Brexit-related issue. All the rest of the negotiations takes place solely between the UK and the EU. The first bilateral talks between the UK and the Republic of Cyprus took place in October 2017. No issue have been legally settled yet.
The agreement between the UK and Cyprus on the status of the bases will be part of the withdrawal deal, Kasoulides previously said (ibid). However, some legal scholars (Dony, 2018) argues that it won’t be the case anymore, and that only the border concern with Ireland will be in the withdrawal deal; Gibraltar and Cyprus will be in the deal on the future of the relations between the UK and the EU during the transition period. Indeed, as soon the UK won’t be part of the EU anymore, on March 30 2019, an almost-two-year transition period will start until the 31st of December 2020 where the the framework for its future relationship with the Union will be negotiated. This will give the requisite time for the UK to tackle the issue of the borders between Cyprus and its two sovereign bases (Piris, 2018).

British High Commissioner in Cyprus Matthew Kidd highlighted that relations between Cyprus and the UK were “warm and friendly and that both share a position of wanting to keep the status quo, and for no changes in citizenship between the two to be introduced” (Browne, 2017), which is the most likely scenario. However, whatever deal may be found could be served as an occasion for Cyprus to clarify the legal status of the Bases, or even try to take them back since the territories in question did not gain independence in 1960 with the rest of Cyprus and remained a vestige of the colony ceded to the UK in 1914 (Yiolitis, 2016). Cyprus did not always have a say in the developments of their country: they used to be weak and newly independent. Now they can. In addition to that, Cyprus, with the Treaty of Establishment, ceded the right to its territorial seas to the Bases. Territorial water normally are entitled only to states under international law. Cyprus will try to clarify to which extent the bases really are sovereign and try to gain as much as possible in any deal.

Finally, in the case of a soft Brexit, the stakeholders could choose to keep implementing the objectives of the Protocol, or other provisions of the (current) EU Treaty and relevant EU legislation in the Bases. While in the case of a hard Brexit, if the two countries fail to reach any agreement, then they may have to return to the status of the bases under the 1960 treaty. That wouldn’t cover issues such as EU agricultural policy or free movement of workers.

Brexit is bigger than planned

Even in the unlikely case of the UK giving back his bases to Cyprus, there would be troubles here too: Dhekelia is almost entirely in the Turkish area of Cyprus, therefore Northern Turkish Cyprus would claim for it. Anyhow, nothing has been agreed so far, and the only official guidelines for the European Council state that the EU and the UK will need to agree on arrangements on the SBAs “and recognise in that respect bilateral agreements and arrangements between the Republic of Cyprus and the United Kingdom which are compatible with EU law, in particular as regards the situation of those EU citizens resident or working in the Sovereign Base Areas” (Lang and Miller, ibid). All these issues is just a fraction of what reveals Brexit as being bigger than anyone expected, with implications almost everywhere.

Robin Vanholme is a Master student in European Studies at the Institute for European Studies, ULB

Bibliographie :

-BROWNE, B., “High Commission looks to reassure British expats ahead of Brexit talks”, CyprusMail Online, 16 June 2017,
-CIA World Factbook 2017
-DONY, Marianne, “Brexit”, Public EU Law course, ULB, 19 February 2018.
-EU, Act concerning the conditions of accession of the Czech Republic, the Republic of Estonia, the Republic of Cyprus, the Republic of Latvia, the Republic of Lithuania, the Republic of Hungary, the Republic of Malta, the Republic of Poland, the Republic of Slovenia and the Slovak Republic and the adjustments to the Treaties on which the European Union is founded, 2004.
-GEORGIOU, G. and TUGWELL, P., “Brexit Raises Questions About U.K. Sovereign Bases on Cyprus”, Bloomberg, 6 October 2017,
-LANG, A. and MILLER, V., “Brexit: the talks begin”, Briefing Paper, House of Commons Library, n° 8017, 12 July 2017, p.37.
-PIRIS, J.-C., “Brexit: la période de transition”, Question d’Europe, n°461, 5 février 2018, p. 4.
-THEODOULOU, M., “Euro reaches field that is forever England”, The Times, 27 December 2007.
-YIOLITIS, E., “Back to base: what does Brexit mean for UK sovereign bases in Cyprus?”, Harneys article, September 2016.

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