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Why Scotland’s Move Towards Independence May Prove More Difficult Than Brexit

Ian Bremmer is a foreign affairs columnist and editor-at-large at TIME. He is the president of Eurasia Group, a political-risk consultancy, and GZERO Media, a company dedicated to providing intelligent and engaging coverage of international affairs. He teaches applied geopolitics at Columbia University’s School of International and Public Affairs, and his most recent book is The Power of Crisis.

Fresh off a solid victory in elections, the Scottish National Party’s Nicola Sturgeon says another independence referendum for Scotland is now a matter of “when, not if.” Her party fell one seat short of a majority in Scotland’s parliament, but an alliance with pro–independence Greens will extend her run as Scotland’s First Minister and sets up another vote on exiting the U.K.

Yet nothing is simple. First, though the U.K. looks to be turning a corner on COVID-19, there’s still much to do to get people vaccinated, reopen Scotland and get the economy back on track. Throughout the campaign, Sturgeon insisted the pandemic would remain her priority until it was over, and the SNP’s victory hasn’t changed that. A referendum can’t be staged until next spring at the very earliest.

Next complication: British law appears to require approval from Westminster, which depends on permission from U.K. Prime Minister Boris Johnson, to hold a binding independence vote, and Johnson isn’t keen to become the man who lost Scotland. This is a question that’s headed for court. The politics and timing are complex. For now, Scots appear evenly split on the question of independence. (They voted in 2014 to remain within the U.K. by a 10-point margin, but Brexit has shifted the landscape.) A majority of lawmakers recently elected in Scotland support independence; a slim majority of raw votes cast went to candidates who oppose it.

If Johnson insists that Scotland can’t vote, the anger he’ll arouse could shift support sharply in favor of breakaway. Whatever the law says, constitutional union depends on the consent of the governed. It might be wiser for Johnson to give the green light and hope for the best.

Then there’s the question of Scotland’s re-entering the European Union as an -independent nation. On this point, at least, it’s clear what Scots want: in 2016, they voted 62% to 38% in favor of the U.K.’s remaining within the E.U. Nothing that’s happened since then has dimmed the desire of most Scots for E.U. membership, which would be crucial for the economic well-being of a country of fewer than 6 million people. Scotland now sends 60% of its goods to the rest of the U.K. Regaining direct access to the E.U.’s 450 million consumers is a huge deal.

Read more: Scotland’s Nationalists Won a Big Election Victory. Could Scottish Independence Now Be on the Cards?

An independent Scotland would have big advantages in its membership bid. The most obvious is that Scotland was a member of the E.U. for decades as part of the U.K. Legal and regulatory alignment would be far easier for Scotland than for candidates forced into major political and economic reforms. There’s also at least one major roadblock. E.U. accession requires a unanimous vote of current members, and Spain, fighting Catalan separatism, has reason to make things difficult for Scotland to avoid setting a dangerous precedent. That’s probably a surmountable obstacle, but it would slow the E.U. approval process.

The biggest fight ahead for Scotland might be the process of divorcing the U.K. Think Brexit was complicated? The U.K. was part of the E.U. for 47 years. Scotland has been part of Britain for 314. There is no cut that will quickly set Scotland free, and the U.K. government, fearful of similar trends in Northern Ireland, has no incentive to make things easy.

All that said, Brexit taught us that secession votes aren’t decided by careful cost–benefit analysis and close study of legal and regulatory implications. They are votes of the heart and declarations of identity. If a majority of Scots want to leave the U.K., independence will probably follow. It might be messy and take a decade or more, but this is the destination to which Scotland now appears headed.

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