BREXIT: Getting ready for the end of transition period

On 1 February 2020, the United Kingdom of Great Britain and Northern Ireland left the European Union and became a so-called third country. The Withdrawal Agreement set a transition period ending on 31 December 2020. During the transition period, the EU law shall fully apply to and in the United Kingdom.

Whether the agreement on future relations is concluded or not, new transport rules will apply between EU and the United Kingdom (hereinafter referred to as “the UK”) as of 2021. Below, you can find an overview of those directly related to the transport. Nevertheless, due the ongoing negotiations, the final form can change.

Generally, as of 1 January 2021, air carriers holding operating licences granted by the UK licensing authority for the commercial carrying by air of passengers, mail and/or cargo, will no longer be able to provide air transport services within the EU. EU air carriers and holders of aviation safety certificates will need to ensure, and uphold compliance with Union requirements, including airlines’ requirements on principal place of business and EU majority ownership and control, as well as the Union aviation safety acquis.

With regard to the ongoing negotiations, the European Union adopted contingency measures to mitigate possible disruption of connectivity between the EU and the UK from 1 January 2021. These will apply if the UK offers same options for the EU carriers in the absence of an agreement. The measures concern the following areas:

Regulations will be published in the Official Journal of the EU on 28 December. You can find more information in the Council Press Release.

Practical information for passenger: When flying to the UK, you will be checked in at Terminal 1–Prague Airport. However, holders of British passports can no longer benefit from fast passport control via e-Gates.

Protection of passenger rights provided by the EU law will continue to apply for intra-EU flights as well as flights from the EU to a third country operated by a British carrier. The British government decided to preserve high level of protection of passenger rights for flights outside the UK and all flights to the EU (from anywhere) operated by a British carrier even after withdrawal from the EU.

Notice from the Commission

As of 1 January 2021, road transport operators that are established in the UK will no longer hold a Community licence. They will therefore no longer benefit from the automatic access rights to the Single Market that such a licence entails, and namely the right of EU operators to conduct journeys and carry goods across the Union. The access rights that EU operators and UK operators will have to each other’s respective markets will depend on the outcome of the negotiations between the EU and the UK. In the absence of an agreement, the limited quotas already available under the mechanism of the European Conference of Ministers of Transport (ECMT) will be available for EU operators to conduct journeys to the UK, and for UK operators to conduct journeys to the EU.

The EU adopted contingency measures also for road transport to ensure basic connectivity for freight as well as passenger transport. The regulation allows UK carriers to transport goods to the EU under the condition that the UK offers same conditions to the EU carriers. Publication in the Official Journal of the EU is also planned for 28 December. The document is already available here.

However, the transport of goods can be significantly affected by a new regime at borders. For more information, please visit the following links:

Notice from the Commission on the road transport and type approval of vehicles.

During the transition period, Union law on the recognition of driving licenses across the EU applies. Therefore, currently, holders of UK-issued driving licences can continue to drive in the EU without additional documentation. As of 1 January 2021, driving licenses issued by the UK will no longer benefit from mutual recognition under Union law. The recognition of driving licences issued by the UK will be regulated at Member State level. Driving licences issued by the UK that comply with the 1949 Geneva Convention on Road Traffic (i.e. plastic photo-card format issued ca. from 2000) will be accepted for driving in the Czech Republic. Otherwise, a holder of an older driving licence or a driving licence issue by the Isle of Man shall have an international driving licence.

You can find more information on exchanging a driving licence for British citizens living in the Czech Republic here.

Notice from the Commission on the maritime transport and inland waterways.

As of 1 January 2021, licences issued to railway undertakings by the UK will no longer be valid in the EU, and certificates or licences issued in the UK to train drivers will no longer be valid for the operation of locomotives and trains on the EU’s railway system. Railway undertakings from the EU or the UK that provide cross border services between the UK and the EU will have to comply with the legal requirements applicable both in the EU and the UK. This relates to the license and safety certificate for the railway undertaking, the rolling stock authorisations and personnel (train drivers) licenses. Stakeholders concerned therefore have to ensure that they have valid licences in the EU for the sections of the cross border services located in the territory of the EU, and valid licences in the UK for the sections of the cross border services located in the territory of the UK.

Notice from the Commission