EUROPEAN COMMISSION
Brussels, 21.4.2026
COM(2026) 166 final
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL
on the implementation and application of the Trade and Cooperation Agreement between the European Union and the United Kingdom of Great Britain and Northern Ireland
1 January – 31 December 2025
Table of Contents
1.Introduction
2.Institutional framework
3.Complaints and dispute settlement
3.1.
Complaints
3.2.
Dispute settlement
4.Sectoral implementation
4.1.
Trade in goods
4.2.
Services and investment, digital trade, public procurement, and small and medium-sized enterprises
4.3.
Intellectual property rights.
4.4.
Level playing field
4.5.
Energy
4.6.
Transport
4.7.
Fisheries
4.8.
Social security coordination
4.9.
Law enforcement and judicial cooperation in criminal matters
4.10.
Association of the United Kingdom to certain EU programmes
4.11.
Other areas
5.Developments in the law of the United Kingdom
6.Conclusions
Annex 1: Meetings of the joint bodies and other structures established by the TCA
Annex 2: Decisions, recommendations and declarations adopted by the Partnership Council and Committees established by the TCA
Annex 3: Overview of the implementation of the TCA- related actions agreed in the Common Understanding
1.Introduction
In 2025, the European Union (EU) and the United Kingdom of Great Britain and Northern Ireland (United Kingdom) took a significant step forward in their relationship by holding the first bilateral summit since the United Kingdom's departure from the EU. The summit on 19 May 2025 in London marked a renewed commitment to cooperation. The leaders welcomed agreement on the EU-UK Security and Defence Partnership and agreed to establish a new strategic partnership based on the Withdrawal Agreement, including the Windsor Framework, and the Trade and Cooperation Agreement (TCA, or ‘the Agreement’).
The renewed agenda for enhanced bilateral cooperation – the Common Understanding - reflects a shared commitment to the full, timely and faithful implementation of these agreements. Regarding the TCA, the Common Understanding outlines actions to increase cooperation, including securing full reciprocal access to fishing waters until 30 June 2038, extending energy cooperation, strengthening health-security collaboration, progressing the linkage of emissions trading systems, addressing implementation of specific TCA services-provisions, reinforcing judicial, law-enforcement, competition policy cooperation, and associating the United Kingdom to Erasmus+ programme.
By the end of 2025, significant progress had been reached in implementing the Common Understanding. An agreement in principle was secured on the United Kingdom’s participation in Erasmus+, and exploratory discussions on the United Kingdom’s possible participation in the EU internal electricity market were concluded, paving the way for further progress in 2026.
Cooperation also continued on a number of initiatives that fall outside the scope of the TCA. These included negotiating agreements on a common sanitary and phytosanitary area and the Youth Experience Scheme, as well as cooperation on irregular migration, including its external dimension. Both sides also committed to exchange information on efficient border management and to pursue technical regulatory dialogues on energy technologies, drug risks and threats.
This fifth report on the implementation and application of the TCA, as required by Article 2(4) of Council Decision (EU) 2021/689 of 29 April 2021
, presents key developments in 2025. It covers the functioning of the institutional framework (Section 2), complaints and dispute settlement (Section 3), and progress across the various areas of the TCA, including updates on the implementation of the actions agreed in the Common Understanding (Section 4). The report also highlights legislative developments in the United Kingdom that affect the TCA’s implementation (Section 5).
2.Institutional framework
This section outlines the key activities and developments of the joint bodies and other structures established under the TCA to monitor and facilitate its implementation. A full list of meetings is presented in Annex 1.
The committees established under Article 8 of the TCA met throughout the year. These meetings enabled structured reviews of progress on commitments made in the TCA and provided a platform for technical exchanges on various implementation issues, including forthcoming regulatory developments. Several decisions and recommendations were adopted, which are presented in Annex 2. Where relevant, the meetings of the Specialised Committees were preceded by the meetings of the working groups, established under Article 9 of the TCA.
The Parliamentary Partnership Assembly, established under Article 11 of the TCA, met twice: on 17 and 18 March in Brussels and on 17 and 18 November in London. These meetings focused on foreign and security policy, climate and energy, workers’ rights, cultural exchanges, artificial intelligence, data and digital cooperation, youth opportunities, trade, customs, sanitary and phytosanitary measures, and regulatory cooperation in financial services. Following the March meeting, the Assembly issued a recommendation to the Partnership Council on strengthening EU-UK cooperation ahead of the 19 May Summit, and following the November meeting, on security, trade and global challenges.
The EU Domestic Advisory Group, established under Article 13 of the TCA and composed of representatives from civil society organisations, met several times in 2025. At its meeting on 13 June, the group discussed the outcome of the summit. This discussion resulted in a joint statement, adopted with the United Kingdom Domestic Advisory Group during their meeting on 23 June in London, calling for the prompt implementation of the actions set out in the Common Understanding. At its 16 September meeting, the Commission provided an update to the Domestic Advisory Group on the implementation of the Common Understanding.
The Civil Society Forum, established under Article 14 of the TCA to facilitate dialogue on the implementation of Part Two of the Agreement, which covers trade, transport, fisheries and other arrangements, was held for the fourth time on 24 June in London. As in previous years, the forum focused on implementation issues related to trade in goods and services, energy and climate, the level playing field, sustainability and regulatory cooperation. Most participants welcomed the momentum in the relationship following the 19 May summit and expressed hope that this dynamic would continue.
The Partnership Council convened on 2 February 2026.
3.Complaints and dispute settlement
This section summarises the work of the mechanisms established to address complaints from EU stakeholders, resolve disputes and enforce TCA commitments.
3.1.Complaints
In 2025, six complaints were submitted through the tools set up by the Commission to ensure efficient monitoring of the TCA’s implementation
. Only two complaints concerned the implementation of the TCA. The remaining four submissions related to matters outside the scope of the TCA and the Commission addressed them accordingly.
3.2.Dispute settlement
The arbitration proceedings the EU initiated on 25 October 2024, pursuant to Article 739 of the TCA, concerning the United Kingdom’s decision to prohibit sandeel fishing in its waters as of 26 March 2024, were concluded on 28 April 2025.
In its ruling, the arbitration tribunal found that the prohibition of sandeel fishing in English waters was inconsistent with the United Kingdom’s obligations under Article 496(1) of the TCA, read in conjunction with Article 494(3)(f). The tribunal concluded that the United Kingdom had failed to give due regard to the principle of proportionality in adopting the measure. It further determined that as a result, the United Kingdom had breached its obligation to grant full access to its waters for sandeel fishing, in accordance with Article 2(1)(a) of Annex 38 to the TCA. The ruling required the United Kingdom to take the necessary measures to bring itself into compliance with the relevant provisions of the TCA.
The United Kingdom subsequently revised its assessment by including updated scientific elements and impact assessments and made a new decision on the closure of English waters to sandeel fishing. On 25 June 2025, it notified the EU of the measures it had taken to bring itself into compliance with the ruling. The Commission assessed that information in light of the ruling and concluded against requesting a compliance review.
Regarding the panel of experts for disputes relating to the chapter on the level playing field for open and fair competition and sustainable development, pursuant to Article 409 of the TCA on 23 February 2026 the Commission adopted a proposal for a Council decision to establish the list of individuals who are willing and able to serve as members of the panel of experts.
4.Sectoral implementation
This section highlights achievements in the policy areas covered by the TCA, and the progress made in implementing the actions agreed in the Common Understanding that fall within the scope of the TCA. It also presents data on trade flows in goods and services between the EU and the United Kingdom.
4.1.Trade in goods
Overall, the trade-related arrangements set out in the TCA have been effective and functioned well.
In line with Article 31 of the TCA, the EU and the United Kingdom exchanged import statistics. These show that approximately 39.5% of EU exports to the United Kingdom and 48.5% of EU imports from the United Kingdom were eligible for preferential treatment under the trade agreement. The remaining trade flows concerned tariff lines that were already duty-free on an MFN basis.
The preference utilisation rates remain high and are comparable to those of the previous year: 88% of EU preference-eligible goods exported to the United Kingdom and 83.2% of preference-eligible goods imported from the United Kingdom benefited from the preferences under the TCA. These rates are consistent with those observed for other partners with which the EU has free trade agreements.
An overview of the development of trade flows in goods
between the EU and the United Kingdom in 2025 is presented below.
The EU recorded a substantial trade surplus in goods with the United Kingdom, amounting to EUR 188 billion. The EU exported goods worth EUR 346 billion to the United Kingdom, which represents an increase of 0.8% compared to 2024. Goods imports from the United Kingdom amounted to EUR 159 billion, representing a 3.1% reduction compared to 2024.
The sectors showing the strongest growth in EU exports to the United Kingdom were food, drinks, and tobacco (+3.5%), raw materials (+3.3%), and chemicals and related products (+3.3%). The only export category that declined was mineral fuels (-2.5%). On the import side, there were increases for imports of food, drinks, and tobacco (+3.8%) and raw materials (+4.1%), while imports of the remaining goods categories declined. The largest decrease was observed in mineral fuels (-14.2%). Overall, these developments highlight a divergence in trade dynamics across sectors, with energy-related products continuing to contract, whereas food, drinks, and tobacco, and raw materials maintained moderate growth.
Compared to other non-EU countries, EU trade in goods with the United Kingdom was less dynamic. In 2025, EU exports to other non-EU countries increased by 2.4% compared to 2024, while EU imports from other non-EU countries rose, by 2.9%. In 2025, total trade in goods with the United Kingdom accounted for 9.8% of the EU’s overall trade with international partners, down from 10.1% in 2024. The United Kingdom remained the second-largest destination for EU exports, receiving 13.1% of total EU goods exports, compared to 13.3% in 2024, after the United States (20.9%). On the import side, the United Kingdom was the source of 6.3% of the EU’s goods imports, down from 6.7% in 2024, ranking third after China (22.3%) and the United States (14.1%). These figures confirm the continuation of a trend identified in the previous Commission’s annual reports on the implementation of the TCA, whereby trade in goods with other non-EU partners expanded more rapidly than trade with the United Kingdom since its withdrawal from the EU.
When looking at how trade in goods has developed since the TCA began to apply in 2021, EU exports to the United Kingdom have shown consistent growth. In 2025, exports reached EUR 346 billion, up from EUR 282 billion in 2021, an increase of 23%. The strongest annual growth occurred between 2021 and 2022, reflecting a rebound from the impact of COVID-19. In contrast, EU imports from the United Kingdom followed a more volatile path, rising sharply from EUR 147 billion in 2021 to EUR 216 billion in 2022, also reflecting post-pandemic adjustment, before declining steadily to EUR 159 billion in 2025. This divergence between exports and imports suggests that the EU economy adapted effectively to the new trade conditions with the United Kingdom following its departure from the EU.
Figure 1: EU trade in goods with the United Kingdom, 2021-2025, in EUR billion, source: Eurostat (dataset
ext_lt_maineu
)
4.2.Services and investment, digital trade, public procurement, and small and medium-sized enterprises
The implementation of the TCA in the areas of services and investment, digital trade, intellectual property, public procurement, and small and medium-sized enterprises has generally proceeded smoothly, with the exception of persistent problems related to the United Kingdom’s sponsorship system for visas applied to EU service providers who are covered by the TCA.
Since 2022, the EU has consistently raised concerns within the TCA joint bodies about the system’s complexity, disproportionate burden, and lack of clarity. The sponsorship requirement continues to hinder the effective implementation of the TCA for EU service suppliers, as reflected by the issuance of only 49 visas in the first nine months of 2025 to EU nationals under the Service Supplier route, which covers EU Independent Professionals and Contractual Service Suppliers. As a result, EU service providers continue to encounter significant barriers to serving clients in the United Kingdom, while the government remains reluctant to address the issue. As agreed in the Common Understanding, a dialogue on the implementation of the TCA’s commitments on the entry and temporary stay of natural persons for business purposes, aims to resolve this long-standing issue that hampers the full implementation of the TCA.
Another dialogue was set up on the implementation of the TCA’s commitments on the recognition of professional qualifications, in line with the Common Understanding.
In the area of financial services, the EU - United Kingdom Financial Regulatory Forum, held in accordance with the Memorandum of Understanding of 2023, met twice in 2025: on 12 February in London and on 1 October in Brussels. Discussions covered a range of topics, including macroeconomic and financial stability outlooks, banking regulation, digital finance, capital market reforms and sustainable finance. Following both meetings, joint statements were issued summarising the outcomes.
An overview of trade flows in services between the EU and the United Kingdom in 2025 is provided below
.
In the first three quarters of 2025, the EU exported services worth EUR 230 billion to the United Kingdom, which represents an increase of 5.1% compared to the same period in 2024. The value of imports from the United Kingdom in the first three quarters of 2025 was EUR 183 billion, representing a 4% increase compared to the same period in 2024. In the first three quarters of 2025, the EU ran a services trade surplus with the United Kingdom of EUR 47 billion. The sectors in which EU exports to the United Kingdom recorded the strongest growth in 2025 compared to 2024 were maintenance and repair services (+20.7%) and charges for the use of intellectual property (+20.3%). On the import side, the largest increases from the United Kingdom were observed in charges for the use of intellectual property (+15%), followed by travel (+12.2%).
In the first three quarters of 2025, total trade in services with the United Kingdom accounted for 18.7% of the EU’s total trade with its international partners, down from 18.6% in the same period of 2024. The United Kingdom was the destination of 19.8% of EU services exports in the first three quarters of 2025 (compared to 19.1% in the same period of 2024), second to the United States (21.5%). The United Kingdom was the origin of 17.5% of the EU’s imports in the first three quarters of 2025 (compared to 17.9% in the same period of 2024), second to the United States (36.5%).
When looking at how trade in services has developed since the TCA began to apply in 2021, EU exports of services to the United Kingdom have shown steady growth, rising from EUR 150 billion in the first three quarters of 2021 to EUR 230 billion in the first three quarters of 2025, an increase of over 53%. EU imports of services from the United Kingdom also increased steadily, from EUR 125 billion in 2021 to EUR 183 billion in 2025 (+47%). The strongest growth occurred between 2021 and 2022, reflecting a rebound from the impact of COVID-19 on travel, tourism, and other service sectors. Overall, these trends indicate that trade in services with the United Kingdom has been expanding steadily for both exports and imports.
Figure 2: EU trade in services with the United Kingdom, first three quarters of 2021-2025, EUR billion, source: Eurostat (dataset
bop_eu6_q
)
4.3.Intellectual property rights
The EU Intellectual Property Office and the United Kingdom’s Intellectual Property Office continued their discussions on a memorandum of understanding to improve administrative cooperation in the area of intellectual property, as referred to in Article 273(2)(g) of the TCA.
4.4.Level playing field
As noted in the Common Understanding, the first supplementary agreement under Article 361(4) of the TCA was agreed in 2025 and signed on 25 February 2026. The Competition Cooperation Agreement:
·puts in place a framework for cooperation on competition matters between, on the one hand, the Commission and EU Member States' competition authorities and, on the other, the United Kingdom’s Competition and Markets Authority;
·provides that important antitrust and merger investigations should be brought to each party’s attention;
·allows the coordination of investigations between the jurisdictions involved when necessary (which on the EU side may involve the Commission or Member States’ competition authorities, depending on the case);
·sets out clear principles of cooperation designed to avoid conflicts between jurisdictions.
4.5.Energy
The most significant energy-related development in 2025 was the political agreement reached at the EU-United Kingdom summit on 19 May to extend energy cooperation between the parties on a continuous basis. Both sides shared the political understanding that the TCA’s energy-related objectives should be pursued on a continuous basis, making it appropriate to extend the application of the energy title. This was formalised through the adoption of Declaration No 1/2025 and of Decision No 2/2025 of the Partnership Council of 19 June 2025 that provides for the first extension until 31 March 2027. This framework offers stability and predictability for stakeholders in both the EU and the United Kingdom, facilitates business, and ensures market stability.
As regards the electricity trading arrangements, the Specialised Committee on Energy continued its examination of the Multi-Region Loose Volume Coupling (MRLVC) referred to in Annex 29 to the TCA. In accordance with Recommendation No. 1/2024, the Transmission System Operators for electricity of the EU and the United Kingdom submitted to the Specialised Committee on Energy a joint report on the implementation of the MRLVC on 30 September 2025. In turn, on 27 and 28 October 2025 respectively, the United Kingdom’s national energy regulators and the EU Agency for the Cooperation of Energy Regulators submitted their informal opinions to the Specialised Committee on Energy, which will further assess the opinions in 2026. These documents did not establish a satisfactory way of proceeding with the MRLVC.
As a result, on the basis of the Common Understanding, the European Commission and the United Kingdom held and concluded exploratory talks on the United Kingdom's participation in the EU internal electricity market. The European Commission has on this basis adopted a recommendation for a negotiation framework for the participation of the United Kingdom in the internal electricity market of the EU and on the financial contribution of the United Kingdom towards reducing economic and social disparities between the regions of the EU.
Lastly, the Working Group on Security of Supply, established by Decision No 2/2024 of the Specialised Committee on Energy, met three times in 2025 to adopt its Terms of Reference and to discuss security of supply ahead of the summer and winter periods.
4.6.Transport
Implementation of the TCA in the area of transport proceeded smoothly, focusing on the effective exercise of the rights mutually granted by the parties.
In the area of aviation safety, of the 32 applications for validation of certificates issued by the United Kingdom’s Civil Aviation Authority, 23 were approved by the EU Aviation Safety Agency (EASA) under Article 446 in conjunction with Annex 30 of the TCA. With support of the EASA, the United Kingdom authorities validated 4 of 11 projects submitted by EU applicants, which is consistent with expected activity levels for certificate validation.
In the area of air transport, by the end of 2025, air traffic between the EU and the United Kingdom was expected to have reached pre-pandemic levels. A total of 26 arrangements on all-cargo services and procedures for the approval of non-scheduled flights were concluded between the EU Member States and the United Kingdom under Articles 419(4) and 419(9) of the TCA. Additionally, the EU Member States and the United Kingdom granted ad-hoc authorisations for scheduled flights carrying goods or passengers between the United Kingdom and the EU beyond the freedoms provided for in Article 419 of the TCA. The United Kingdom and 25 Member States granted these authorisations by means of ”block permits” covering a number of flights for a given air carrier.
In the area of road transport, work continued to implement the provisions of the TCA on the exchange of information and data contained in national electronic registers (c.f. Article 14, Section 1 of Part A of TCA Annex 31). This included connecting, as of 1 January 2026, the United Kingdom to the European Registers of Road Undertakings, which links national registers of road transport operators, allowing the exchange of information on serious infringements committed by road transport undertakings in the other Party, as well as other information contained in the national electronic registers. These initiatives aim to strengthen cooperation and improve data sharing between the EU and the United Kingdom, and were formalised through Decisions No 1/2025, No 2/2025 and No 3/2025 of the Specialised Committee on Road Transport.
4.7.Fisheries
The landmark political agreement reached at the EU–United Kingdom Summit to guarantee full reciprocal access to waters beyond 30 June 2026 until 30 June 2038 is the most significant development in the area of fisheries. Formalised through Decision No. 1/2025 of the Partnership Council and Decision No. 1/2025 of the Specialised Committee on Fisheries under the TCA, this agreement provides long-term stability and predictability for EU fishers, securing their rights and safeguarding livelihoods, and marks a significant step forward in the implementation of the Common Understanding.
Furthermore, the Commission actively engaged in discussions with the United Kingdom regarding its marine protected areas. While fully supporting the protection of marine ecosystems, the Commission highlights the need for approaches that balance conservation with socio-economic considerations and protection of EU fishing rights. The Commission remains committed to constructive dialogue with the United Kingdom’s authorities.
Lastly, in December 2025, the EU and the United Kingdom concluded their annual consultations under Article 498 of the TCA to determine the total allowable catches for shared stocks in 2026. The agreement ensures that EU fleets can fish up to 288 000 tonnes, worth over EUR 1.2 billion.
4.8.Social security coordination
As in previous years, the implementation of the Protocol on Social Security Coordination to the TCA (‘the Protocol’) continued in a constructive manner, with no systemic or structural issues identified.
The Specialised Committee on Social Security Coordination carried out its technical work, in particular on: (i) changes to structured electronic documents and portable documents; (ii) procedures for reimbursing the cost of sickness benefits; (iii) the transposition of relevant decisions of the Administrative Commission for the Coordination of Social Security Systems; and (iv) exploratory talks on the possibility of including a new provision in the implementing rules of the Protocol, allowing States to derogate from the rules on applicable legislation by common agreement in well-defined situations and in the interest of the persons concerned. No Decisions or Recommendations were adopted in 2025.
4.9.Law enforcement and judicial cooperation in criminal matters
In 2025, further progress was made in enhancing cooperation in this area.
By the end of the year, 25 Member States and the United Kingdom had granted each other access to their national fingerprint databases, in accordance with Article 534 of the TCA. This built on the progress made in 2024, when all Member States and the United Kingdom granted each other access to their national DNA databases for automated searching, in line with Article 530 of the TCA.
Concerning the exchange of vehicle registration data, an evaluation visit and pilot project were carried out in the United Kingdom to assess its implementation of the obligations set out in Part Three, Title II of the TCA. Based on the resulting evaluation report of 17 October 2025, the Council will determine the date from which Member States may begin supplying data to the United Kingdom. Once this decision has been adopted, both the Member States and the United Kingdom will be able to conduct automated searches in each other’s national databases, as provided under Article 537 of the TCA.
On 24 September, Europol and the United Kingdom’s National Crime Agency signed a working arrangement on the liaison officers seconded by the United Kingdom to Europol. It allows the United Kingdom to second up to 20 liaison officers to Europol and specifies the liaison officers’ tasks, their rights and obligations and the costs involved in accordance with Article 577(2)(d) of the TCA.
In accordance with Article 630(2) of the TCA, the EU reviewed its notifications to the United Kingdom as regards surrender of requested persons and notified the Specialised Committee on Law Enforcement and Judicial Cooperation accordingly. Such a review must be done every five years following the entry into force of the TCA.
4.10.Association of the United Kingdom to certain EU programmes
As of 2024, the United Kingdom has been associated to several EU programmes, including Horizon Europe and the Copernicus component of the Union Space programme. This enables entities from the United Kingdom to engage in collaborative research and innovation projects across the EU and beyond.
According to the latest data, since 2024 the United Kingdom has been the fourth-largest recipient of grants of all participating countries (after Germany, Spain, and France), with UK entities securing approximately EUR 1.2 billion in Horizon Europe funding. The United Kingdom also leads in Marie Skłodowska-Curie actions, enabling its universities and institutions to participate in doctoral networks and coordinate projects.
Furthermore, at the May 2025 summit, both parties agreed to work towards the United Kingdom’s association to the Erasmus+ programme. Negotiations for the United Kingdom’s association as of 1 January 2027 were concluded by the Commission in December 2025. They will be followed by a Commission proposal to the Council for an amendment of Protocol I to the TCA, which in turn will be followed by the legislative and procedural steps required for the Specialised Committee on Participation in Union Programmes to adopt the updated terms of Protocol I, governing the United Kingdom’s association with Erasmus+. This marks a significant step towards broader participation in mobilities between the EU and the United Kingdom, as well as cooperation in all sectors covered by the programme (education, training, youth and sport).
4.11.Other areas
In the area of health security, exploratory talks were held with a view to maximising bilateral cooperation on the detection of and preparedness for future pandemics, and on the response to emerging health threats.
In line with the Common Understanding and following the Council’s adoption on 11 June 2025 of a Decision and negotiation directives, negotiations began with a view to concluding an international agreement on the Youth Experience Scheme, introducing a new visa pathway and facilitating the participation of young people from the EU and the United Kingdom in a range of activities.
5.Developments in the law of the United Kingdom
Pursuant to the ongoing monitoring by the Commission, this section reviews legislative developments in the United Kingdom, as required by Article 2(4) of Council Decision (EU) 2021/689, with a particular focus on the most significant measures relevant to TCA implementation.
In the area of subsidy control, the government continued to refine the framework established under the Subsidy Control Act 2022. The Subsidy Control (Subsidies and Schemes of Interest or Particular Interest) (Amendment) Regulations 2025, effective from August 2025, increased the financial threshold for mandatory referral of subsidies and schemes in non-sensitive sectors to the Competition and Markets Authority from GBP 10 million to GBP 25 million. As a result, the Competition and Markets Authority estimated a 28% reduction in the number of subsidies scrutinised by Subsidy Advice Unit.
In the field of labour and social standards, the Employment Rights Act 2025 introduced employment law reforms in England, Scotland and Wales. Key provisions, welcomed by the EU, include updates to redundancy procedures, equality duties for employers, trade union functions and enforcement of labour market legislation. In particular, this Act seeks to end zero-hour contracts by granting rights to guaranteed hours and to modernise trade union legislation, including by repealing the controversial Strikes (Minimum Service Levels) Act 2023, highlighted by the Commission in its 2023 TCA implementation report.
As regards climate and environmental legislation, the Great British Energy Act 2025 establishes Great British Energy (GBE), a publicly owned energy company tasked with accelerating the development of clean domestic energy. This Act grants GBE the authority to invest in and manage energy generation infrastructure, thereby promoting environmental sustainability and energy security. With more than GBP 8.3 billion to be invested, the Commission is carefully overseeing implementation to ensure that it aligns with the United Kingdom’s TCA commitments.
Furthermore, the Planning and Infrastructure Act 2025 seeks to streamline the delivery of critical infrastructure by introducing strategic spatial planning across England and fast-tracking major projects to support economic growth and environmental sustainability. This Act overhauls the planning and infrastructure rules, replacing environmental planning obligations with a levy on developers paid into the Nature Restoration Fund to finance restoration projects. It also streamlines approvals for ‘nationally significant infrastructure projects’ and electricity infrastructure. It is a major development in the area and the Commission is actively monitoring its impact on trade, investment and potential non-compliance with the non-regression obligations under the TCA.
In the area of product regulation, the Product Regulation and Metrology Act 2025 represents a comprehensive reform of the United Kingdom’s product safety, metrology, and consumer protection framework. It empowers the Secretary of State to introduce regulations governing product safety, efficiency and accuracy, including for weighing and measuring devices, and extends to product installers. It also enables standardisation of measurement units, sets out procedures for regulatory oversight and provides for coordination with devolved administrations. While certain sectors, such as food, medicines, military equipment, aircraft and some agricultural products, are excluded, this Act lays the foundations for future secondary legislation, including rules targeting online marketplaces and digital trade. Monitoring the Act’s implementation is vital to enable the Commission to maintain TCA compliance and anticipate regulatory changes affecting cross-border trade.
In the area of data protection, the Data (Use and Access) Act 2025, enacted in June 2025 and entering into force progressively between June 2025 and June 2026, reforms the United Kingdom’s data protection framework for digital verification and data sharing. This Act amends the General Data Protection Regulation and Data Protection Act 2018, establishing new legal grounds for processing personal data in certain public interest areas, enabling Smart Data schemes for secure data sharing, creating a legal framework for digital identity services, and setting up a National Underground Asset Register.
In June 2025, the European Commission adopted a six-month technical extension of the two 2021 adequacy decisions in order to assess the implications of the Data (Use and Access) Act 2025. In July 2025, it concluded that the United Kingdom's legal framework provides data protection safeguards, including those amended by the Data (Use and Access) Act 2025, essentially equivalent to those of the EU, and subsequently launched the process for the Council to adopt new adequacy decisions. On 19 December 2025, these adequacy decisions were adopted. The adequacy decisions will be periodically reviewed after four years and will expire on 27 December 2031, unless they are extended.
6.Conclusions
After five years of implementation, the TCA has proven to be a robust and effective foundation for EU–United Kingdom relations, the implementation of which has progressed well overall. The issues identified in this report represent exceptions, considering the breadth and depth of cooperation established under the TCA.
As reaffirmed in the Common Understanding adopted at the first EU–United Kingdom summit on 19 May 2025, the TCA remains a cornerstone for developing the new strategic partnership between the EU and the United Kingdom and continues to serve as the principal instrument for deepening cooperation in a changing geopolitical context.
The Commission’s assessment confirms that, five years on, the TCA provides a stable, predictable and mutually beneficial framework that will be further strengthened by the new agreements envisaged under the Common Understanding.
Annex 1: Meetings of the joint bodies and other structures established by the TCA
|
Date
|
Joint body/structure
|
|
28 January
|
Energy Security of Supply (Working Group): 1st meeting
|
|
4 February
|
Dialogue on Counter-Terrorism – Article 768 TCA: 2nd meeting
|
|
10 February
|
Cooperation by supervisors (environment/climate) – Article 395 TCA: 1st meeting
|
|
12 February
|
EU – UK Financial Regulatory Forum: 3rd meeting
|
|
26 February
|
Fisheries (Working Group): 9th meeting
|
|
17-18 March
|
Parliamentary Partnership Assembly: 5th meeting
|
|
25 March
|
EU Domestic Advisory Group: 14th meeting
|
|
14 May
|
Fisheries (Specialised Committee): 10th meeting
|
|
22 May
|
Energy Security of Supply (Working Group): 2nd meting
|
|
4 June
|
Organic products (Working Group): 2nd meeting
|
|
5 June
|
Medicinal Products (Working Group): 2nd meeting
|
|
11 June
|
Air transport (Specialised Committee): 5th meeting
|
|
12 June
|
Motor vehicles and parts (Working Group): 2nd meeting
|
|
13 June
|
EU Domestic Advisory Group: 15th meeting
|
|
18 June
|
Energy (Specialised Committee): 6th meeting
|
|
24 June
|
Civil Society Forum: 4th meeting
|
|
16 July
|
Fisheries (Working Group): 10th meeting
|
|
17 September
|
Fisheries (Specialised Committee): 11th meeting
|
|
29 September
|
Sanitary and Phytosanitary Measures (Trade Specialised Committee): 5th meeting
|
|
1 October
|
EU-UK Financial Regulatory Forum: 4th meeting
|
|
2 October
|
Administrative Cooperation in VAT and Recovery of Taxes and Duties (Trade Specialised Committee): 5th meeting
|
|
8 October
|
Public Procurement (Trade Specialised Committee): 5th meeting
|
|
9 October
|
Intellectual Property (Trade Specialised Committee): 5th meeting
|
|
15 October
|
Level Playing Field for Open and Fair Competition and Sustainable Development (Trade Specialised Committee): 5th meeting
|
|
16 October
|
Customs Cooperation and Rules of Origin (Trade Specialised Committee): 5th meeting
|
|
22 October
|
Technical Barriers to Trade (Trade Specialised Committee): 5th meeting
|
|
23 October
|
Services, Investment and Digital Trade (Trade Specialised Committee): 5th meeting
|
|
30 October
|
Road Transport (Specialised Committee): 5th meeting
|
|
6 November
|
Goods (Trade Specialised Committee): 5th meeting
|
|
7 November
|
Energy (Specialised Committee): 7th meeting
|
|
12 November
|
Regulatory Cooperation (Trade Specialised Committee): 5th meeting
|
|
18 – 19 November
|
Parliamentary Partnership Assembly: 6th meeting
|
|
21 November
|
Dialogue on Harmful Tax Regimes: 2nd meeting
|
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26 November
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Aviation Safety (Specialised Committee): 5th meeting
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1 December
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Social security coordination (Specialised Committee): 5th meeting
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4 December
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Trade Partnership Committee: 5th meeting
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4 December
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Law Enforcement and Judicial Cooperation (Specialised Committee): 5th meeting
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9 – 10 December
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Dialogue on Cyber issues – Article 703 TCA: 3rd meeting
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15 December
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Participation in Union Programmes (Specialised Committee): 5th meeting
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Annex 2: Decisions, recommendations and declarations adopted by the Partnership Council and Committees established by the TCA
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Date
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Decision or Recommendation
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18 June 2025
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Decision No 1/2025 of the Partnership Council issuing an interpretation of Article 508(2)(d) of the Trade and Cooperation Agreement
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19 June 2025
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Decision No 2/2025 of the Partnership Council issuing an interpretation of Article 331(2) and extending the application of Part Two, Heading One, Title VIII on energy, of the Trade and Cooperation Agreement
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19 June 2025
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Joint Declaration 1/2025 of the Union and the United Kingdom in the Partnership Council established by the Trade and Cooperation Agreement
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19 June 2025
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Decision No 1/2025 of the Specialised Committee on Fisheries as regards the arrangements on the level and conditions of access granted by each Party to vessels of the other Party to fish in its waters from 1 July 2026 to 30 June 2038
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31 July 2025
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Decision No 1/2025 of the Trade Specialised Committee on Administrative Cooperation in VAT and Recovery of Taxes and Duties of 31 July 2025 amending Decision No 4/2023 on standard forms for the communication of information and statistical data, the transmission of information via the common communication network and the practical arrangements for the organisation of contacts between central liaison offices and liaison departments
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30 October 2025
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Decision No 1/2025 of the Specialised Committee on Road Transport on a list of categories, types and degrees of seriousness of serious infringements which may lead to the loss of good repute for a road haulage operator
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30 October 2025
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Decision No 2/2025 of the Specialised Committee on Road Transport on the national electronic registers of road transport undertakings and the modalities of the exchange of information contained in those registers
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30 October 2025
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Decision No 3/2025 of the Specialised Committee on Road Transport on the amount and modalities of the United Kingdom’s financial contribution to certain road transport information systems managed by the Union and the amendment to Decision No 1/2022 of the Specialised Committee on Road Transport
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Annex 3: Overview of the implementation of the TCA-related actions agreed in the Common Understanding
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Action/area of cooperation
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State of play
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Full reciprocal access to fishing waters until 30 June 2038
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Decision No. 1/2025 of the Partnership Council of 18 June 2025 and Decision No. 1/2025 of the Specialised Committee on Fisheries of 1 July 2025 provide for full and reciprocal access to waters beyond 30 June 2026 until 30 June 2038.
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Extension of energy cooperation
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Declaration No 1/2025 and Decision No 2/2025 of the Partnership Council of 19 June 2025 provide for the continued application of the TCA’s energy provisions. The first extension will apply until 31 March 2027, with further extensions to follow on an annual basis.
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Working towards linking both parties’ emissions trading systems
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Following the adoption of the Council’s negotiating mandate on 17 November 2025, negotiations began.
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Association of the United Kingdom to Erasmus+
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Negotiations for the United Kingdom’s association as of 1 January 2027 were concluded by the Commission in December 2025.
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Enhancing the provision of services
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Dedicated dialogues on the implementation of the TCA as regards entry and temporary stay of natural persons for business purposes, including the sponsorship scheme, and the recognition of professional qualifications, reporting to the TCA joint bodies
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Maximising cooperation on health security
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Exploratory talks continue.
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Strengthening judicial cooperation in criminal matters and law enforcement
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Exploratory talks continue.
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Competition cooperation agreement
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The Competition Cooperation Agreement between the EU and the United Kingdom was agreed in 2025 and signed in February 2026.
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