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Defining an alternative arrangement for the UK's future relationship with the European Union following ‘Brexit’ will raise both substantive and institutional issues. In the public debate, the latter tend to be underestimated. The present article is based on the thesis that, should the UK seek a market access agreement based on EU law rules, it will face strict institutional demands from the Union that go far beyond the element, often mentioned in the ‘Brexit’ debate in the context of EEA membership, of having to accept EU-made law as it comes. The thesis is derived from experience with the EU's legal arrangements with other partners, notably the EFTA States as well the current negotiations with Andorra, Monaco and San Marino.

This paper aims to show that the Convention for the Elimination of All Forms of

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