Brexit (/ˈbrɛksɪt, ˈbrɛɡzɪt/;[1] a portmanteau of "British" and "exit") is the withdrawal of the United Kingdom (UK) from the European Union (EU). Following a referendum held on 23 June 2016 in which 51.9 percent of those voting supported leaving the EU, the Government invoked Article 50 of the Treaty on European Union, starting a two-year process which was due to conclude with the UK's exit on 29 March 2019. That deadline has since been extended to 31 October 2019.[2][3]

Withdrawal from the EU has been advocated by both left-wing and right-wing Eurosceptics, while pro-Europeanists, who also span the political spectrum, have advocated continued membership and maintaining the customs union and single market. The UK joined the European Communities (EC) in 1973 under the Conservative government of Edward Heath, with continued membership endorsed by a referendum in 1975. In the 1970s and 1980s, withdrawal from the EC was advocated mainly by the political left, with the Labour Party's 1983 election manifesto advocating full withdrawal. In 1987, the Single European Act, the first major revision of 1957's Treaty of Rome, formally established the single European market and European Political Cooperation.

From the 1990s, opposition to further European integration came mainly from the right. When in 1992 the Maastricht Treaty, which created the European Union (EU) and the single market and guaranteed the four basic freedoms (the free movement of goods, services, capital and people around the EU) was brought before Parliament, there were divisions within the Conservative Party, leading to a rebellion over the Treaty.

The UK Independence Party (UKIP), formed in 1993, grew strongly in the early 2010s and the influence of the cross-party People's Pledge campaign has also been described as influential in bringing about a referendum. The Conservative Prime Minister, David Cameron, pledged during the campaign for the 2015 general election to hold a new referendum—a promise which he fulfilled in 2016 following pressure from the Eurosceptic wing of his party. Cameron, who had campaigned to remain, resigned after the result and was succeeded by Theresa May, his former Home Secretary. She called a snap general election less than a year later but lost her overall majority. Her minority government was supported in key votes by the Democratic Unionist Party.

On 29 March 2017, the Government of the United Kingdom invoked Article 50 of the Treaty on European Union. Theresa May announced the government's intention not to seek permanent membership of the European single market or the EU customs union after leaving the EU and promised to repeal the European Communities Act of 1972 and incorporate existing European Union law into UK domestic law. Negotiations with the EU officially started in June 2017. In November 2018, the Draft Withdrawal Agreement, negotiated between the UK Government and the EU, was published. The House of Commons voted against the agreement by a margin of 432 to 202 (the largest parliamentary defeat in history for a sitting UK government) on 15 January 2019, and again on 12 March with a margin of 391 to 242 against the agreement. On 14 March 2019, the House of Commons voted for the Prime Minister, Theresa May, to ask the EU for such an extension of the period allowed for the negotiation. Members from across the House of Commons rejected the agreement, with the leadership of the Labour Party stating in the House of Commons that any deal must maintain a customs union and single market, and with a large percentage of Conservative Party members rejecting the Irish backstop as it was drafted in the EU withdrawal agreement.

The broad consensus among economists is that Brexit will likely reduce the UK's real per capita income in the medium term and long term, and that the Brexit referendum itself damaged the economy.[a] Studies on effects since the referendum show a reduction in GDP, trade and investment, as well as household losses from increased inflation. Brexit is likely to reduce immigration from European Economic Area (EEA) countries to the UK, and poses challenges for UK higher education and academic research. As of July 2019, the size of the "divorce bill"—the UK's inheritance of existing EU trade agreements—and relations with Ireland and other EU member states remains uncertain. The precise impact on the UK depends on whether the process will be a "hard" or "soft" Brexit, or whether there is a no-deal Brexit; whereby the UK would leave the EU without a withdrawal agreement.

Terminology and etymology

In the wake of the referendum of 23 June 2016, many new pieces of Brexit-related jargon have entered popular use.[17][18]

Article 50
Article 50 of the Treaty on European Union is a procedure in the treaty that sets out how member states can leave the Union, with a two-year timetable for leaving. Article 50 was triggered by Prime Minister Theresa May at the end of March 2017.
Backstop
A term referring to the government's proposal to keep Northern Ireland in some aspects of the European Union Customs Union and of the European Single Market to prevent a hard border in Ireland, so as not to compromise the Good Friday Agreement.
Blind / Blindfold Brexit
Coined in September 2018 to describe a scenario where the UK leaves the EU without clarity on the terms of a future trade deal.[19][20] EU and British negotiators would then have until 31 December 2020 to sign off on a future trade deal, during which time the UK would effectively remain a member of the EU, but with no voting rights.[21][22]
Brexit
Brexit (like its early variant, Brixit)[23] is a portmanteau of "British" and "exit". Grammatically, it has been called a complex nominal.[24] The first attestation in the Oxford English Dictionary is a Euractiv blog post by Peter Wilding on 15 May 2012.[25][26][27] It was coined by analogy with "Grexit", attested on 6 February 2012 to refer to a hypothetical withdrawal of Greece from the eurozone (and possibly also the EU altogether, although there was never a clear popular mandate for it).[28] At present, Brexit is impending under the EU Treaties and the UK Acts of Parliament, and the current negotiations pursuant thereto.[29][27]
Canada plus / Canada model
This is shorthand for a model where the United Kingdom leaves the European Union and signs a free trade agreement. This would allow the UK to control its own trade policy as opposed to jointly negotiating alongside the European Union, but would require rules of origin agreements to be reached for UK–EU trade. It is likely this would lead to trade being less "free" than joining the EFTA, and result in additional border controls being required, which is an issue of contention, particularly on the island of Ireland. The Canadian–European Union deal took seven years to negotiate, but Brexiteers argue it would take much less time between the UK and EU as the two participants already align on regulatory standards.[30]
Chequers Agreement
The short name given by the media to The framework for the future relationship between the United Kingdom and the European Union, the government's white paper drawn up at Chequers and published on 12 July 2018, which set out the sort of relationship the UK government wanted with the EU after Brexit.[31][32] The government published the updated draft on 22 November 2018.[33]
Clean break Brexit
This term, used particularly by the Brexit Party, is more generally known as a no-deal Brexit.[34]
Customs Union
A customs union is an agreement under which two or more countries agree not to impose taxes on imported goods from one another and to apply a common tariff on goods imported from countries not party to the agreement. For more information.
Divorce bill
It is expected that the UK will make a contribution toward financial commitments that it had approved while still a member of the EU, but are still outstanding. The amount owed is officially referred to as the financial settlement but has informally been referred to as an exit bill or divorce bill.[35] While serving as Brexit Secretary, Dominic Raab said the UK will not pay the full financial settlement to the EU in a no-deal scenario but would instead pay a significantly lower amount to cover the UK's "strict legal obligations".[36] The UK Government's estimate of the financial settlement in March 2019 was £38 billion.[37] After normal member contributions payable to 31 October 2019 of £5 billion, a final settlement of £33 billion on 31 October is currently estimated.[38]
Hard and soft Brexit
"Hard Brexit" and "soft Brexit" are unofficial terms that are commonly used by news media[39] to describe the prospective relationship between the UK and the EU after withdrawal. A hard Brexit (also called a no-deal Brexit) usually refers to the UK leaving the EU and the European Single Market with few or no deals (trade or otherwise) in place, meaning that trade will be conducted under the World Trade Organization's rules, and services will no longer be provided by agencies of the European Union (such as aviation safety).[40] Soft Brexit encompasses any deal that involves retaining membership in the European Single Market and at least some free movement of people according to European Economic Area (EEA) rules.[41] Theresa May's "Chequers agreement" embraced some aspects of a "soft" Brexit.[42] Note that the EEA and the deal with Switzerland contain fully free movement of people, and that the EU has wanted that to be included in a deal with UK on fully free trade.
Hard border
Because of Brexit, a physical border could be erected between Northern Ireland, a constituent part of the United Kingdom, and the Republic of Ireland, an EU member state. This raises concerns about the future of the Good Friday Agreement (or Belfast Agreement), a peace deal signed in 1998 which helped to end the Northern Ireland conflict (The Troubles).
Indicative vote
Indicative votes are votes by members of parliament on a series of non-binding resolutions. They are a means of testing the will of the House of Commons on different options relating to one issue.[43] MPs have voted on eight different options for the next steps in the Brexit process on 27 March 2019; however, none of the proposals earned a majority in the indicative votes.[44] MPs also voted on four options on 1 April 2019 in the second round of indicative votes. Still, none of the proposals earned a majority.[45]
Leaver
Those supporting Brexit are sometimes referred to as "Leavers".[46][47] Alternatively the term "Brexiteers",[48][49] or "Brexiters" has been used to describe adherents of the Leave campaign.[50][51][52][53] Likewise, the pejorative term "Brextremist", a portmanteau of "Brexiter" and "Extremist" has been used by some outlets to describe Leavers of an overzealous, uncompromising disposition.[54][55][56]
Lexit
also Lexiter. A portmanteau of 'left-wing' and 'Brexit', referring to left-wing advocacy of EU withdrawal.[57][58][59][60]
Meaningful vote
A meaningful vote is a vote under section 13 of the European Union (Withdrawal) Act 2018, requiring the government to arrange for a motion proposing approval of the outcome of negotiations with the EU to be debated and voted on by the House of Commons before the European Parliament decides whether it consents to the withdrawal agreement being concluded on behalf of the EU in accordance with Article 50(2) of the Treaty on European Union.[61]
Managed no-deal
"Managed no-deal Brexit"[62] or "managed no deal Brexit"[63] was increasingly used near the end of 2018, in respect of the complex series of political, legal and technical decisions needed if there is no withdrawal agreement treaty with the EU when the UK exits under the Article 50 withdrawal notice. The Institute for Government has advised that the concept is unrealistic.[64]
No-deal Brexit
This means the UK would leave the European Union without a withdrawal agreement.[65]
Norway model/ Norway plus
This is shorthand for a model where the United Kingdom leaves the European Union but becomes a member of the European Free Trade Association (EFTA) and the European Economic Area, possibly with the addition of a customs union ("plus"). EFTA and EEA membership would allow the UK to remain in the single market but without having to be subject to the Common Fisheries Policy, Common Agricultural Policy, and the European Court of Justice (ECJ). The UK would be subject to the EFTA court, which largely shadows the ECJ, have to transfer a large amount of EU law into UK law, and have little say on shaping EU rules (some of which the UK will be compelled to take on). The UK would also have to allow freedom of movement between the EU and UK, which was seen as a key issue of contention in the referendum.[66]
People's Vote
People's Vote is an advocacy group launched in April 2018, who calls for a public vote on the final Brexit deal. The People's Vote march is part of a series of demonstrations against Brexit.
Remainer
Those in favour of the UK remaining in the EU are sometimes referred to as "Remainers".[67] The derogatory term "Remoaner" (a blend of "remainer" and "moan") is sometimes used by Brexiters to describe adherents of the Remain campaign.[68][50][52]
Second referendum
A second referendum (otherwise known as People's vote) has been proposed by a number of politicians and pressure groups. The Electoral Commission of UK has the responsibility for nominating lead campaign groups for each possible referendum outcome.[69]
Slow Brexit
The term ‘slow Brexit’ was first coined by
The Inner Six (blue) and Outer Seven (green) of European integration in 1961

The "Inner Six" European countries signed the Treaty of Paris in 1951, establishing the European Coal and Steel Community (ECSC). The 1955 Messina Conference deemed that the ECSC was a success, and resolved to extend the concept further, thereby leading to the 1957 Treaties of Rome establishing the European Economic Community (EEC) and the European Atomic Energy Community (Euratom). In 1967, these became known as the European Communities (EC). The UK attempted to join in 1963 and 1967, but these applications were vetoed by the President of France, Charles de Gaulle.[72]

Accession and period of European Union membership

Some time after de Gaulle's relinquishing of the French presidency the UK successfully applied for EC membership, and the Conservative prime minister Edward Heath signed the Treaty of Accession in 1972.[73] Parliament passed the European Communities Act later that year[74] and the UK joined Denmark and Ireland in becoming a member of the EC on 1 January 1973.[75]

The opposition Labour Party won the February 1974 general election without a majority and then contested the subsequent October 1974 general election with a commitment to renegotiate Britain's terms of membership of the EC, believing them to be unfavourable, and then hold a referendum on whether to remain in the EC on the new terms.[76] Labour again won the election (this time with a small majority), and in 1975 the United Kingdom held its first ever national referendum, asking whether the UK should remain in the European Communities. Despite significant division within the ruling Labour Party,[77] all major political parties and the mainstream press supported continuing membership of the EC. On 5 June 1975, 67.2 per cent of the electorate and all but two[78] UK counties and regions voted to stay in;[79] support for the UK to leave the EC in 1975 appears unrelated to the support for Leave in the 2016 referendum.[80]

Comparison of results of 1975 and 2016 referendums

The Labour Party campaigned in the 1983 general election on a commitment to withdraw from the EC without a referendum,[81] although after a heavy defeat Labour changed its policy.[81] In 1985, the Thatcher government ratified the Single European Act—the first major revision to the Treaty of Rome—without a referendum.

In October 1990, under pressure from senior ministers and despite Margaret Thatcher's deep reservations, the United Kingdom joined the European Exchange Rate Mechanism (ERM), with the pound sterling pegged to the deutschmark. Thatcher resigned as Prime Minister the following month, amid Conservative Party divisions arising partly from her increasingly Eurosceptic views. The United Kingdom and Italy were forced to withdraw from the ERM in September 1992, after the pound sterling and the lira came under pressure from currency speculation ("Black Wednesday").[82]

Under the Maastricht Treaty, the European Communities became the European Union on 1 November 1993,[83] reflecting the evolution of the organisation from an economic union into a political union.[84] Denmark, France, and Ireland held referendums to ratify the Maastricht Treaty. In accordance with British constitutional convention, specifically that of parliamentary sovereignty, ratification in the UK was not subject to approval by referendum. Despite this, the British constitutional historian Vernon Bogdanor wrote at the time that there was "a clear constitutional rationale for requiring a referendum" because although MPs are entrusted with legislative power by the electorate, they are not given authority to transfer that power (the UK's previous three referendums all concerned the transfer of parliamentary powers). Further, as the ratification of the treaty was in the manifestos of the three major political parties, voters opposed to ratification had no way to express that opposition. For Bogdanor, while the ratification of the treaty by the House of Commons might be legal, it would not be legitimate—which requires popular consent. The way in which the treaty was ratified, he judged, was "likely to have fundamental consequences both for British politics and for Britain's relationship with the European Community."[85][86] This perceived democratic deficit directly led to the formation of the Referendum Party and the United Kingdom Independence Party.

Euroscepticism, opt-outs and 'outers'

Prime ministers and Tory leaders Thatcher (l.) and Cameron (r.) used eurosceptic rhetoric while being in favour of British EU membership and the development of the European Single Market. Euroscepticism—and in particular the impact of the UK Independence Party (founder and leader Farage pictured m.) on the Conservatives' election results—contributed to Cameron's 2015 attempt to renegotiate the UK's EU membership and ultimately the holding of the 2016 referendum.

Thatcher, who had supported the common market and the Single European Act, in the Bruges speech of 1988 warned against "a European super-state exercising a new dominance from Brussels". She influenced Daniel Hannan, who in 1990 founded the Oxford Campaign for Independent Britain; "With hindsight, some see this as the start of the campaign for Brexit", Financial Times later wrote.[87] In 1994, Sir James Goldsmith formed the Referendum Party to contest the 1997 general election on a platform of providing a referendum on the nature of the United Kingdom's relationship with the rest of the European Union.[88][89] The party fielded candidates in 547 constituencies at that election, and won 810,860 votes—2.6 per cent of the total votes cast[90]—but failed to win a parliamentary seat due to the vote being spread across the country. The Referendum Party disbanded after Goldsmith's death in 1997.

The UK Independence Party (UKIP), a Eurosceptic political party, was formed in 1993. It achieved third place in the UK during the 2004 European elections, second place in the 2009 European elections and first place in the 2014 European elections, with 27.5 per cent of the total vote. This was the first time since the 1910 general election that any party other than Labour or the Conservatives had taken the largest share of the vote in a nationwide election.[91] UKIP's electoral success in the 2014 European election is documented as the strongest correlate of the support for the leave campaign in the 2016 referendum.[92]

UKIP won two by-elections (triggered by defecting Conservative MPs) in 2014; in the 2015 general election, the party took 12.6 per cent of the total vote and held one of the two seats won in 2014.[93]

Policy opt-outs of European Union member states

Country # of
opt-ins
or
opt‑outs
Policy area
Schengen Area Economic and Monetary Union (EMU) Security and Defence Policy (CSDP) Area of freedom, security and justice (AFSJ) Charter of Fundamental Rights Social Chapter
 Denmark 3 INT OO OO OO NO NO
 Ireland 2 OI NO NO OI NO NO
 Poland 1 NO NO NO NO OO NO
 United Kingdom 4 OI OO NO OI OO FO
Legend
  •  OI  — opt-in – possibility to opt in on a case-by-case basis.
  •  OO  – opt-out in place
  •  FO  – former opt-out that was subsequently abolished.
  •  INT  – participates on an intergovernmental basis, but not under EU law
  •  NO  – fully participating in policy area

Opinion polls 1977–2015

Both pro- and anti-EU views have had majority support at different times since 1977.[94] In the European Communities membership referendum of 1975, two-thirds of British voters favoured continued EC membership. There is Euroscepticism both on the left and right of British politics.[95][96][97]

According to a statistical analysis published in April 2016 by Professor John Curtice of Strathclyde University, surveys showed an increase in Euroscepticism (defined as a wish to sever or reduce the powers of the EU) from 38% in 1993 to 65% in 2015. Euroscepticism should, however, not be confused with the wish to leave the EU: the BSA survey for the period July–November 2015 showed that 60 per cent backed the option to continue as an EU member and 30 per cent backed the option to withdraw.[98]

Referendum of 2016

Negotiations for membership reform

In 2012, Prime Minister David Cameron initially rejected calls for a referendum on the UK's EU membership,[99] but then suggested the possibility of a future referendum to endorse his proposed renegotiation of Britain's relationship with the rest of the EU.[100] According to the BBC, "The prime minister acknowledged the need to ensure the UK's [renegotiated] position within the European Union had 'the full-hearted support of the British people' but they needed to show 'tactical and strategic patience'."[101] On 23 January 2013, under pressure from many of his MPs and from the rise of UKIP, Cameron announced that a Conservative government would hold an in-or-out referendum on EU membership before the end of 2017, on a renegotiated package, if elected in the 7 May 2015 general election.[102] This was included in the Conservative Party manifesto for the election.[103][104]

The Conservative Party won the election with a majority. Soon afterwards, the European Union Referendum Act 2015 was introduced into Parliament to enable the referendum. Cameron favoured remaining in a reformed European Union, and sought to renegotiate on four key points: protection of the single market for non-eurozone countries, reduction of "red tape", exempting Britain from "ever-closer union", and restricting immigration from the rest of the European Union.[105]

In December 2015, opinion polls showed a clear majority in favour of remaining in the EU; they also showed support would drop if Cameron did not negotiate adequate safeguards[definition needed] for non-eurozone member states, and restrictions on benefits for non-British EU citizens.[106]

The outcome of the renegotiations was announced in February 2016. Some limits to in-work benefits for new EU immigrants were agreed, but before they could be applied, a member state such as the UK would have to get permission from the European Commission and then from the European Council, which is composed of the heads of government of every member state.[107]

In a speech to the House of Commons on 22 February 2016, Cameron announced a referendum date of 23 June 2016, and commented on the renegotiation settlement.[108] He spoke of an intention to trigger the Article 50 process immediately following a leave vote, and of the "two-year time period to negotiate the arrangements for exit."[109]

After the original wording for the referendum question was challenged,[110] the government agreed to change the official referendum question to "Should the United Kingdom remain a member of the European Union or leave the European Union?"

Campaign groups

A "Vote Leave" poster in Omagh, Northern Ireland, saying "We send the EU £50 million every day. Let's spend it on our NHS instead."

The official campaign group for leaving the EU was Vote Leave[111] after a contest for the designation with Leave.EU.[112][113] Vote Leave was later found to have exceeded its allowed spending limit during the campaign.[114]

The official campaign to stay in the EU, chaired by Stuart Rose, was known as Britain Stronger in Europe, or informally as 'Remain'. Other campaigns supporting remaining in the EU included Conservatives In,[115] Labour in for Britain,[116] #INtogether (Liberal Democrats),[117] Greens for a Better Europe,[118] Scientists for EU,[119] Environmentalists For Europe,[120] Universities for Europe[121] and Another Europe is Possible.[122]

Referendum result

The result was announced on the morning of 24 June: 51.89 per cent voted in favour of leaving the European Union, and 48.11 per cent voted in favour of remaining a member of the European Union.[123][124] Comprehensive results are available from the UK Electoral Commission Referendum Results site. A petition calling for a second referendum attracted more than four million signatures,[125][126] but was rejected by the government on 9 July.[127]

United Kingdom European Union membership referendum, 2016
National result
Choice Votes %
Leave the European Union 17,410,742 51.89%
Remain a member of the European Union 16,141,241 48.11%
Valid votes 33,551,983 99.92%
Invalid or blank votes 25,359 0.08%
Total votes 33,577,342 100.00%
Registered voters and turnout 46,500,001 72.21%
Voting age population and turnout 51,356,768 65.38%
Source: Electoral Commission
National referendum results (without spoiled ballots)
Leave:
17,410,742 (51.9%)
Remain:
16,141,241 (48.1%)
Results by Country of the United Kingdom/region of England (left) and by council district (GB) & UK Parliament constituency (NI) (right)
  Leave
  Remain

Voter demographics and trends

According to researchers based at the University of Warwick, areas with "deprivation in terms of education, income and employment were more likely to vote Leave". The Leave vote tended to be greater in areas which had lower incomes and high unemployment, a strong tradition of manufacturing employment, and in which the population had fewer qualifications.[128] It also tended to be greater where there was a large flow of Eastern European migrants (mainly low-skilled workers) into areas with a large share of native low-skilled workers.[128] Those in lower social grades (especially the 'working class') were more likely to vote Leave, while those in higher social grades (especially the 'upper middle class') more likely to vote Remain.[129]

According to Thomas Sampson, an economist at the London School of Economics, "Older and less-educated voters were more likely to vote 'leave' [...] A majority of white voters wanted to leave, but only 33 per cent of Asian voters and 27 per cent of black voters chose leave. There was no gender split in the vote [...] Leaving the European Union received support from across the political spectrum [...] Voting to leave the European Union was strongly associated with holding socially conservative political beliefs, opposing cosmopolitanism, and thinking life in Britain is getting worse".[5] Econometric studies show that "education and, to a lesser extent, age were the strongest demographic predictors of voting behaviour". Support for leaving was linked with "poor economic outcomes at the individual or area level" and with "self-reported opposition to immigration, but not with exposure to immigration".[5]

Opinion polls found that Leave voters believed leaving the EU was "more likely to bring about a better immigration system, improved border controls, a fairer welfare system, better quality of life, and the ability to control our own laws", while Remain voters believed EU membership "would be better for the economy, international investment, and the UK's influence in the world". Polls found that the main reasons people voted Leave were "the principle that decisions about the UK should be taken in the UK", and that leaving "offered the best chance for the UK to regain control over immigration and its own borders". The main reason people voted Remain was that "the risks of voting to leave the EU looked too great when it came to things like the economy, jobs and prices".[130]

Resignations, contests, and appointments

After the result was declared, Cameron announced that he would resign by October.[131] He stood down on 13 July 2016, with Theresa May becoming Prime Minister after a leadership contest. George Osborne was replaced as Chancellor of the Exchequer by Philip Hammond, former Mayor of London Boris Johnson was appointed Secretary of State for Foreign and Commonwealth Affairs, and David Davis became Secretary of State for Exiting the European Union. Labour leader Jeremy Corbyn lost a vote of confidence among his parliamentary party, and an unsuccessful challenge of his leadership was launched. On 4 July, Nigel Farage announced his resignation as leader of UKIP.[132]

Irregularities

Irregularities have been alleged in the conduct of the referendum campaign.

On 11 May 2018, the UK Electoral Commission found against Leave.EU, which ran a separate campaign to the official pro-Brexit group Vote Leave, following its investigations into alleged irregularities during the referendum campaign.[133][134] Leave.EU's co-founder Arron Banks has stated that he rejects the outcome of the investigation and will be challenging it in court.[135]

In July 2018, the UK Electoral Commission found Vote Leave to have broken electoral law, spending over its limit.[136] Also, the House of Commons Culture, Media and Sport Select Committee released an interim report on Disinformation and ‘fake news’, stating that the largest donor in the Brexit campaign, Arron Banks, had "failed to satisfy" the Committee that his donations came from UK sources, and may have been financed by the Russian government.[137][138]

Litigation

There has been litigation to explore the constitutional footings on which Brexit stands after R (Miller) v Secretary of State for Exiting the European Union (the Miller case) and the 2017 Notification Act: