Implementing the Withdrawal Agreement (WA) for EU citizens in the UK and the Northern Ireland Protocol faced significant challenges.
Citizens’ rights
The Home Office did not know how many EU citizens there were in the UK, nor how many Brexit would affect.
Eventually, as of 30 September 2025, since the scheme launch in 2018, the Home Office had issued 4.3 million settled status grants. Further, an estimated 1.5 million people held pre-settled status. These figures are unlikely to reflect the current resident population, as some may have left the UK.
The government set up the Independent Monitoring Authority (IMA) to oversee the implementing of the citizens’ rights element. This had to be in place by the end of the transition period (with leadership, staff, infrastructure, systems and information flows).
Sources:
Home Office, EU Settlement Scheme statistics as at 31 May 2021, reported 10 June 2021
Home Office, Apply to the EU Settlement Scheme
Home Office, How many Indefinite Leave (Settlement and EUSS settled status) and Citizenship grants have been issued in the UK?, November 2025
Northern Ireland Protocol
The government was unable to fully implement the Northern Ireland Protocol by 31 December 2020. This was because the Protocol involved complex customs arrangements with regulatory and customs checks between NI and GB:
- WA established a Ireland/Northern Ireland Specialised Committee to take decisions on key details
- Co-chaired by officials from UK government and European Commission
- First meeting held on 30 April 2020 with further meetings on 28 September in Brussels and 19 October 2020
- UK government published its command paper on 30 May 2020 outlining its planned approach to the Protocol
However, it was impossible for government and business to implement the necessary changes by the end of 2020. In addition, failure to comply with the WA meant the European Commission could begin infringement proceedings against the UK through the ECJ.
In June 2020, the House of Lords EU Committee took evidence from organisations in the Northern Ireland agri-food supply chain. This extended from the grain trade and farmers to food processors and retail, as well as the fishing industry. The Committee wrote to the Secretary of State on 1 July 2020, setting out its key findings and concerns:
- The Protocol is an opportunity for Northern Ireland (NI) to have a unique position in trade, but a UK-EU free trade agreement is critical to making this possible.
- There are significant risks if implementation of the Protocol lacks adequate preparation and a careful approach. For example, divergence in standards between NI and GB could threaten the viability of some NI agri-food business operations. And, NI consumers could face higher food prices.
- There is an urgent need for the Government to engage and start detailed discussions on implementation proposals with NI agrifood businesses.
Sources:
Institute for Government, Getting Brexit done, What happens now?, January 2020
Lords Select Committee, 3 July 2020
Key events
30 March 2020 – Withdrawal Agreement Joint Committee meets for the first time, co- chaired by Michael Gove and European Commission Vice-President Maroš Šefčovič
20 May 2020 – Government publishes its approach to implementing the Northern Ireland Protocol. This set out how the UK will meet its obligations under the Protocol – upholding Northern Ireland’s place in the UK and respecting the Belfast (Good Friday) Agreement.
- Michael Gove gives a statement to the House of Commons on the subject: Northern Ireland Protocol: UK Approach.
12 June 2020 – Second meeting of the Withdrawal Agreement Joint Committee.
16 July 2020 – Government publishes a White Paper on the UK Internal Market. It sets out policy options to protect the flow of goods and services across the UK after the transition period.
- Secretary of State for Business, Energy and Industrial Strategy leads a debate in the House of Commons.
9 September 2020 – UK Internal Market Bill is introduced.
10 September 2020 – Withdrawal Agreement Joint Committee meets to discuss matters including the UK Internal Market Bill and the Northern Ireland Protocol.
- Government publishes its legal position on the UK Internal Market Bill and Northern Ireland Protocol.
- Maroš Šefčovič meets Michael Gove in London for an extraordinary meeting of the EU-UK Joint Committee.
- Vice-President Šefčovič states that adoption of the Bill would constitute an extremely serious violation of the WA and of international law.
- A statement issued by the European Commission reads:
“The EU does not accept the argument that the aim of the draft [internal market] bill is to protect the Good Friday (Belfast) agreement. In fact, it is of the view that it does the opposite.“
28 September 2020 – Withdrawal Agreement Joint Committee meets.
- Speaking after the meeting, European Commission Vice-President Maroš Šefčovič restates the EU’s opposition to the UK Internal Market Bill, saying:
“We maintain that the bill if adopted in its current form would constitute an extremely serious violation of the [Northern Ireland] protocol as an essential part of the Withdrawal Agreement and of international law. The Withdrawal Agreement is to be implemented, not to be renegotiated, let alone unilaterally changed, disregarded or disapplied.“
1 October 2020 – European Commission President Ursula von der Leyen announces the EU will initiate legal proceedings to prevent the UK from trying to use domestic legislation to override aspects of the Brexit Withdrawal Agreement.
19 October 2020 – Withdrawal Agreement Joint Committee meets.
- Michael Gove gives a statement to the House of Commons, updating Members on:
- the UK Government’s negotiations with the EU;
- the future trading relationship;
- the work of the UK/EU Joint Committee established under the withdrawal agreement.
- The Lords begin the Second Reading debate of the UK Internal Market Bill.
26 October 2020 to 9 November 2020 – Five days of the Committee Stage debate on the UK Internal Market Bill debate in the House of Lords.
11 November 2020 – The Immigration Act receives Royal Assent, meaning free movement will end at 11pm on 31 December 2020
18 November 2020 – Minister of State in the Northern Ireland Office updates the House of Commons on preparations for the implementation of the Northern Ireland Protocol.
- First Day of the Report Stage debate on the UK Internal Market Bill in the House of Lords.
- In a defeat for the Government, peers back an amendment to the bill (by 367 votes to 209). The amendment aimed to prevent the sidelining of Scotland, Wales and Northern Ireland in the drawing up of internal market rules.
7 December 2020 – MPs debate Lords amendments to the UK Internal Market Bill.
17 December 2020 – UK Internal Market Bill receives Royal Assent and becomes an Act of Parliament: the United Kingdom Internal Market Act.
The Withdrawal Agreement Joint Committee meets via video conference to endorse all formal decisions and other practical solutions related to the implementation of the Withdrawal Agreement, as of 1 January 2021.