back to article Smaller tech firms just aren't ready for a no-deal Brexit, MPs told

The majority of trade group TechUK's smaller members haven't begun preparing for a no-deal Brexit, while others are being forced to renegotiate entire contracts with European partners or put UK hiring on ice, MPs were told this week. As prime minister Theresa May faces fresh talks with the European Union over the Withdrawal …

  1. W.S.Gosset

    Wrong way round

    > if sterling fell, as it could, for instance, render UK cloud services uncompetitive

    If sterling falls, UK-provided services become more competitive for offshore parties.

    The downside risk for offshore parties is if sterling rises relative to their own currency (euro, in this instance).

    1. Ken 16 Silver badge

      Re: Wrong way round

      You're assuming that EU data could reside on UK cloud services and that cloud services sold in the UK won't be priced in hard currency.

      1. W.S.Gosset

        Re: Wrong way round

        > You're assuming that EU data could reside on UK cloud services

        Yes, because that was the author's assumption in her statement (ie, implicit in those UK cloud services still selling to EU post-brexit is the ability to host EU data/work).

        and that cloud services sold in the UK won't be priced in hard currency.

        No, I'm NOT assuming that.

        If the seller chooses to take on currency risk in its revenue by pricing in Euros, that will not change the post-£fall relative cost advantage for the UK seller. In which case, its profits will rise allowing hiring more sales staff etc., or, if it's sensible, it will take advantage and lower its prices in order to gain marketshare. Cf. China.

        .

        Note the chap below pointing out that Indian companies are taking the latter approach: taking advantage of their relative cost advantage to pitch lower prices to gain clients, which per him is rendering UK service companies pricing in euros less competitive.

    2. Charlie Clark Silver badge

      Re: Wrong way round

      Actually, currency risk in any direction is likely to make something uncompetitive.

    3. Zippy´s Sausage Factory

      Re: Wrong way round

      Up to a point, Lord Copper.

      You're also assuming that said cloud services don't have any imports sourced outside the UK. Like energy - a lot of the raw materials are of course imported from elsewhere (gas from Russia, for example).

      Also, if they use some white label services, say reselling particular pieces of software that have a monthly licence that's priced in Euros or dollars, that will impact on the bottom line too.

      1. Rich 11

        Re: Wrong way round

        +1 for the Scoop reference!

      2. W.S.Gosset

        Re: Wrong way round

        Foreign-denominated costs, once crossed back out to euros/the clients, will simply leave the UK company in the same competitive position as an EU company. No difference.

        However:

        ANY proportion of £-denominated cost, in the event of a £-fall, will improve a company's competitiveness. Either by increasing its profits or by reducing its prices (or allowing it to, if euro/$/other-denominated revenue; see above).

    4. Anonymous Coward
      Anonymous Coward

      Re: Wrong way round

      And as a powerful big business buyer in France I might say - you are making a packet on these Euro denominated contracts - reduce your prices or we will re-tender.....after all you are now in competition with firms in Bangalore rather than Dusseldorf....

      1. Anonymous Coward
        Anonymous Coward

        Re: Wrong way round

        You might, but, there is no competition from Bangalore - assuming of course one needs the code to work and be well tested and documented. Ukraine is where it's at.

        1. Steve Davies 3 Silver badge

          Re: Ukraine is where it is at...

          Maybe... until the Putin's heavies move in to take over the remainder of the country.

          Now Comrade what were you thinking?

          Nothing subversive I hope Comrade? There are a lot of newly refurbished Gulags in need of occupants.

          Better go back to Bangalore/Kolkata/Mumbai/Chennai. At least we know their levels of incompetancy.

  2. Anonymous Coward
    Anonymous Coward

    Inadaquacy and disagreement

    It's a good job the UK governments IT systems are ready for the flood of customs and other applications in (checks watch) 55 days and that this is only a problem for small traders, isn't it?

    As for the contracting issue, I'm an EU citizen in the UK so I'm hoping my safety chute is picking up work on the mainland that UK contractors can no longer commute to so easily.

    1. Len
      Holmes

      Re: Inadaquacy and disagreement

      I had a meeting with two HMRC VAT chaps on Tuesday and they weren't even sure if they would still have a job in case of No Deal (in two months!) as most of their work depends on intra-EU trading VAT processes.

      As for the contracting point. A friend of mine researched the effect of Brexit on staffing issues for one of her clients and created a table of least affected and most affected based on citizenship status. Quite useful for HR to know so they can adjust hiring practices etc.

      * The lucky bastards were people with Irish Citizenship as they get to keep Freedom of Movement and the Common Travel Area.

      * One level below them were non-British EU Citizens living in the UK as they get to keep their Freedom of Movement and their right to reside in the UK so can easily cross borders for work in any of the 28 countries (up to five year long stints).

      * Below those were people with only UK Citizenship living in the UK. They are about to lose their EU Citizenship and therefore lose their Freedom of Movement. They can keep working in the UK but lose the right to work in the other 27 countries.

      * At the bottom of the table were the poor bastards who live in other EU countries, are going to lose their EU Citizenship in two months and only have UK CItizenship to fall back on. In many cases they can stay were they are or move back to the UK, other routes are closed.

      So yes, if you live in the UK and will still have your EU CItizenship after Brexit then you have quite a sweet deal when contracting is concerned.

      1. Anonymous Coward
        Anonymous Coward

        Re: Inadaquacy and disagreement

        Our day will come!

      2. short a sandwich

        Re: Inadaquacy and disagreement

        <blockquote> I had a meeting with two HMRC VAT chaps on Tuesday and they weren't even sure if they would still have a job in case of No Deal (in two months!) as most of their work depends on intra-EU trading VAT processes.</blockquote>

        They'll have a job, it will be checking containers or seizing contraband. Everyone in HMRC will be trained in this.

      3. Rich 11

        Re: Inadaquacy and disagreement

        * The lucky bastards were people with Irish Citizenship as they get to keep Freedom of Movement and the Common Travel Area.

        Although you could also say they'll count themselves considerably less lucky if a hard border with Ireland should reappear and damage the peace process, giving the IRA and UVF an excuse to resume their traditional activities.

        1. Doctor Syntax Silver badge

          Re: Inadaquacy and disagreement

          What you're missing is that this gives them rights to work in the UK and the whole of the EU, not just Ireland. The Common Travel Area includes the UK. Those born in NI can have Irish (i.e. EU citizenship) and UK citizenship.

      4. Anonymous Coward
        Anonymous Coward

        Re: VAT People

        The ONLY growth industry after a No Deal BREXIT will in insolvency practitioners.

        The exodus of companies to foreign parts will seem like the retreat to Dunkirk but in reverse.

        Or Will it?

        Where's that fence I need to sit on?

        1. Doctor Syntax Silver badge

          Re: VAT People

          "Where's that fence I need to sit on?"

          Ask Corbyn to move over.

      5. Anonymous Coward
        Anonymous Coward

        Re: Inadaquacy and disagreement

        * Below those were people with only UK Citizenship living in the UK. They are about to lose their EU Citizenship and therefore lose their Freedom of Movement. They can keep working in the UK but lose the right to work in the other 27 countries.

        * At the bottom of the table were the poor bastards who live in other EU countries, are going to lose their EU Citizenship in two months and only have UK CItizenship to fall back on. In many cases they can stay were they are or move back to the UK, other routes are closed.

        Not closed at all, just requiring more paperwork. Just like for citizens of the other 170 countries not in the EU.

        1. anonymous boring coward Silver badge

          Re: Inadaquacy and disagreement

          "Not closed at all, just requiring more paperwork."

          Very often that actually does mean "closed".

          Don't fool yourself.

  3. Anonymous Coward
    Anonymous Coward

    Taking Back Control!

    Don't know about anyone else, but this is exactly what I voted for!!!!

    Let's Do This Thing!

    -- Captain Chaos

    1. Christoph

      Re: Taking Back Control!

      Absolutely!

      Let's trash the Good Friday Agreement and restart the Troubles!

      Let's have Martial Law and Curfews to control food riots!

      And Blue Passports!

      (I wonder why the brexit bus didn't say that on the side?)

      1. A.P. Veening Silver badge

        Re: Taking Back Control!

        "And French Navy Blue Passports!"

        FTFY ;)

      2. codejunky Silver badge

        Re: Taking Back Control!

        @Christoph

        "Let's trash the Good Friday Agreement and restart the Troubles!"

        The EU have admitted they will be enforcing a hard border. We done need nor seem to want to so thats the EU.

        "Let's have Martial Law and Curfews to control food riots!"

        Food prices are cheaper outside the EU. The ability to enforce martial law is a Tony Blair thing. Not really known as a leave supporter.

        "And Blue Passports!"

        Considering how much this irks remainers this little insignificant thing is quite amusing.

        1. Not also known as SC

          Re: Taking Back Control!

          @codejunky

          "And Blue Passports!"

          Considering how much this irks remainers this little insignificant thing is quite amusing.

          Insignificant? It seems to have been a cornerstone achievement according to the government. You and I maybe couldn't care less about the passport colour but apparently it is very important to a lot of people as representing their national identity.

          https://www.gov.uk/government/news/blue-uk-passport-to-return-after-eu-exit

          Immigration Minister Brandon Lewis said:

          Leaving the EU gives us a unique opportunity to restore our national identity and forge a new path for ourselves in the world.

          That is why I am delighted to announce that the British passport will be returning to the iconic blue and gold design after we have left the European Union in 2019.

          1. BinkyTheMagicPaperclip Silver badge

            Re: Taking Back Control!

            You do remember that the maroon EU passports are not in fact dictated by EU law, it's merely the default? Polish passports are navy blue.

        2. Rich 11

          Re: Taking Back Control!

          We done need nor seem to want to so thats the EU.

          So you're quite happy for anyone who can make it to Ireland to wander across the border and start a new life for themselves in the UK? I mean, once we've got all these wonderful new free trade deals we've been promised with the rest of the world, the streets will be paved with gold and the UK will become much more attractive to illegal immigrants and bogus asylum seekers than the failin' EUSSR.

          1. codejunky Silver badge

            Re: Taking Back Control!

            @Rich 11

            "So you're quite happy for anyone who can make it to Ireland to wander across the border and start a new life for themselves in the UK?"

            Hang on is that what is currently happening! OMG the EU do need to go get shafted then dont they! But more seriously the Irish of either side dont seem to want a border so who cares? The answer to that question is the EU who want to make a border.

            You cant have it both ways. No border cant be both what you want and not what you want.

            "I mean, once we've got all these wonderful new free trade deals we've been promised with the rest of the world, the streets will be paved with gold and the UK will become much more attractive to illegal immigrants and bogus asylum seekers than the failin' EUSSR."

            You are realising the failure of the EU? You are noticing migrants in France just waiting to get here instead of staying in the lovely EU they practically walk through to get here!

            1. Rich 11

              Re: Taking Back Control!

              You cant have it both ways.

              I don't want it both ways. It's all the bloody Brexiters who are banging on about regaining control of our borders who don't seem to understand that saying there needn't be a hard border in Ireland directly contradicts their own desires.

              1. codejunky Silver badge

                Re: Taking Back Control!

                @Rich 11

                "It's all the bloody Brexiters who are banging on about regaining control of our borders who don't seem to understand that saying there needn't be a hard border in Ireland directly contradicts their own desires."

                That you think there is a contradiction might be why you are so against brexit, because you are mistaken. If you have control of something it means you choose. Choice is part of freedom, an important part. If you think having control over our border means we have no choice but a hard border then I understand why your against it, but lucky for us you are wrong.

              2. John Mangan

                Re: Taking Back Control!

                @Rich 11

                Never argue with an idiot. They'll drag you down to their level and beat you with experience.

                1. codejunky Silver badge

                  Re: Taking Back Control!

                  @John Mangan

                  "Never argue with an idiot. They'll drag you down to their level and beat you with experience."

                  I find that does apply in some cases, in others it is just people so misinformed. If you provide people facts they have a choice- either to debate the fact and maybe learn something or to carry on spouting the same baseless rubbish they are used to and comforts them.

                  If you think you are in possession of the facts then you could try debating them with the 'idiot' because it is always possible your facts dont stand to scrutiny or that they could learn something. And if not you havnt lost anything from trying and then walking away. Sometimes you really are just playing chess with a pigeon.

          2. EvilDrSmith Silver badge

            Re: Taking Back Control!

            An open border allows people across it, but doesn't mean that they can legally work, obtain an NI number, access medical or educational services etc. Yes, they can disappear into they 'black economy', but that doesn't mean they won't be caught.

            So anyone wandering across the border is liable to be picked up by immigration services sooner or later.

            And anyone crossing the inter-Ireland border into the UK has to get into the Republic somehow first, which means passing through some form of passport control, unless you are suggesting that migrants from North Africa will start sailing out into the Atlantic then up to Ireland.

            The easiest route for illegal migration into the UK at the moment appears to be Calais to Dover (whether covertly on an HGV, or the newer reported trend of small boats). An open border between NI and the Republic is not likely to change that. So the numbers of people that would try a Republic to NI route are going to be small.

            So from a logical (rather than emotional) assessment of the possibility of an open border between NI and the Republic, it's not at all a problem (for the UK).

            1. Rich 11

              Re: Taking Back Control!

              So anyone wandering across the border is liable to be picked up by immigration services sooner or later.

              Didn't the government announce a plan, a year or so ago, to recruit volunteers to help staff the UK Border Agency and the Immigration Enforcement division? That's a pretty big admission that the service is already underfunded.

          3. Phil O'Sophical Silver badge

            Re: Taking Back Control!

            So you're quite happy for anyone who can make it to Ireland to wander across the border and start a new life for themselves in the UK?

            Isn't that how it's been for the 100 years that there's been a border, even before the EC existed?

            It would be more of a problem if Ireland had been in the Schengen area, but anyone crossing the border in either direction still won't be able to get in or out of the rest of the EU without a passport check.

        3. anonymous boring coward Silver badge

          Re: Taking Back Control!

          "Food prices are cheaper outside the EU."

          Where?

          Where do we live?

          1. codejunky Silver badge

            Re: Taking Back Control!

            @anonymous boring coward

            "Where?

            Where do we live?"

            I need you to make what might be a scary assumption- that the world does not end at the EU border! Now please sit down for this- that assumption is actually correct! There is a world beyond the EU border!

        4. Yes Me Silver badge

          Re: Taking Back Control!

          "The EU have admitted they will be enforcing a hard border. We done need nor seem to want to so thats the EU."

          They didn't 'admit' anything (they are not in the dock, after all). They stated the obvious: when people or goods enter or leave the EU, that's crossing a border and of course checks will need to be applied, unless there is an international agreement in place. You don't just drive between France and Switzerland: you drive past a customs post in both countries. The agreements (including Schengen) are such that you probably won't be stopped if your car has EU or Swiss plates on. But there's a border. There is (and will be) such a border between France and the UK, with passport and visa checks because the UK is not in Schengen. Why would it be any different at the border between Ireland and the UK, after Brexit? Only because an agreement has been reached - an agreement which the House of Commons barfed over.

          (And: Why isn't Ireland in Schengen? Because the UK isn't. If Ireland had joined Schengen, we'd already have passport and visa checks at the Ireland/Northern Ireland border.)

          1. codejunky Silver badge

            Re: Taking Back Control!

            @Yes Me

            "They stated the obvious"

            I have to take issue with that statement but wish I didnt. I thought it was obvious too but apparently some people seem to think we would be breaking the good friday agreement which the point of the 'admission' is that its the EU who would be enforcing that breach not us.

            "Why would it be any different at the border between Ireland and the UK, after Brexit?"

            Both sides of ireland dont want a border, the UK doesnt want one and the EU does. I have been saying this (which matches your statement) throughout but as obvious as it is some people insist its the UK's fault or problem.

            Good comment, hopefully it will help some of the remainers understand

      3. Rich 11

        Re: Taking Back Control!

        (I wonder why the brexit bus didn't say that on the side?)

        Because Boris thinks that Martial Law is a Roman satirical poet.

        1. Anonymous Coward
          Anonymous Coward

          Re: Taking Back Control!

          "Because Boris thinks that Martial Law is a Roman satirical poet."

          Fule. Everyone knows Sammo Hung was Martial Law.

    2. EricM

      Re: Taking Back Control!

      yeah, true.

      UK government takes back contol, but - based on what I see in the live stream from british parliarment- doesn't know how or where to drive the country any longer.

      Without a deal EU companies are no longer automatically allowed to host data and services in the UK starting April 2019.

      Likewise, UK IT staff is no longer automatically allowed to work remotely on EU data.

      Hosting data/apps in the UK will be comparable to hosting them in the US or in northern Africa - regulation-wise. The potential legal problems will be enough for most companies to re-locate data and services inside the EU and staff it purely with EU citizens.

      I guess there's not much individual businesses can do to prepare for that scanario. They will simply be excluded from what is currently a sizeable portion of their market.

    3. fajensen
      Facepalm

      Re: Taking Back Control!

      I didn't get to vote, however, watching the UK government drive their little clown-car right off the cliffs of Dover to prove some point with Brussels, which point to prove they don't even agree on, has been rather interesting to watch.

      When someone makes a movie about Brexit, Internet rules must apply: No horizontal filming, Use a tripod dammit, and, Aftermath please! Oh, and no Potato Cam! I want my gore in 4K!

      1. Anonymous Coward
        Anonymous Coward

        Re: Taking Back Control!

        "watching the UK government drive their little clown-car right off the cliffs of Dover "

        I prefer to think of the red brexit bus balancing on the edge, with Theresa May and the cabinet trying to balance the bus and stop it tipping over. I can even hear what she's saying...

        "Nobody move, I've got no ideas"

        1. MJB7
          Headmaster

          Re: Taking Back Control!

          "Nobody move, I've got no ideas"

          Surely that should be:

          "Hang on a minute, lads – I've got no ideas"

          Icon: 'cos I'm pedantic about film quotes

        2. John G Imrie

          Re: Taking Back Control!

          I like that image, however I'd personally go with the young ones and Phew that was close

        3. AndrueC Silver badge
          Joke

          Re: Taking Back Control!

          "You were only supposed to take the bloody country out of the EU"

  4. Anonymous Coward
    Anonymous Coward

    I hope any fallback systems have been tested for their interconnections ...

    A friend works for a major bank who were wargaming having their EU feeds withdrawn ... all seemed well until someone noticed that a substitute service was drawing on the same feeds ...

    It's not that there's no contract in the event of a no deal. It just that no one yet knows if it's enforceable, which is making suppliers jittery.

    1. Len
      Mushroom

      Re: I hope any fallback systems have been tested for their interconnections ...

      I am currently dealing with the headache of intra EU contracts.

      What happens if you sell a good tomorrow to a customer in Sweden and it comes with a two year warranty? The good can be shipped this week without any issue. What if that customer wants to make a warranty claim six months after a No Deal? It's not a Good any more, it's a Service. Even the hardest fall back option of WTO trading doesn't deal with services at all.

      What happens if a customer in Austria decides to stop paying their instalments after a No Deal? Just finding out which court would be appropriate is something nobody has had to think about until now.

      Currently a B2B business doesn't have to charge VAT on intra EU invoices. That will probably change in case of No Deal, I have not found a definitive answer to that yet. Will I need to reopen all contracts to change pricing?

      I have found a needle in a haystack the other day, someone who is dual qualified as a lawyer for English law and Dutch law. He is raking it in at the moment. Now on to find someone dual qualified in English and Portuguese law...

      1. A.P. Veening Silver badge

        Re: I hope any fallback systems have been tested for their interconnections ...

        "I have found a needle in a haystack the other day, someone who is dual qualified as a lawyer for English law and Dutch law."

        Congratulations on finding that person. Now for the next question: Is that person competent? And how can you judge his competence in Dutch law? Can you read Dutch? How about Dutch legalese?

        And good luck finding that chap with the Portugese qualifications, for whom similar questions apply.

        1. Rich 11

          Re: I hope any fallback systems have been tested for their interconnections ...

          And how can you judge his competence in Dutch law?

          Presumably by checking with the Dutch equivalent of the Law Society. Isn't that what you'd do with a British lawyer?

      2. H in The Hague

        Re: I hope any fallback systems have been tested for their interconnections ...

        "Currently a B2B business doesn't have to charge VAT on intra EU invoices. That will probably change in case of No Deal, I have not found a definitive answer to that yet. Will I need to reopen all contracts to change pricing?"

        I'm not an expert, but I don't think that's going to lead to any real changes - I think those exports will continue to be outside the scope of the UK VAT system. (You will still have to mention them on your VAT form, but in a different box.) On import the business customer will be charged/charge themselves VAT, and then deduct that as input tax on the next page of their VAT return.

        It's more of a problem if you supply goods to consumers in EU countries as they will now have to pay VAT on imports (as they currently do when buying stuff from Canada, China, etc.). So that's going to make you a less attractive supplier to them than one in another EU country. But no doubt this will be easily offset by the increased exports of unicorn jam to keen consumers in Argentina.

        However, providers of financial services, such as my professional indemnity insurance, will be totally stuffed. Mine have already informed me they will give me a refund if they can no longer operate under passporting. The one used by some of my colleagues has found a more straightforward solution: they've simply moved these activities from the UK to Germany (so the UK exchequer loses the insurance premium tax + tax levied on the insurance company's profit and their employees' salaries).

        1. H in The Hague

          Re: I hope any fallback systems have been tested for their interconnections ...

          "Currently a B2B business doesn't have to charge VAT on intra EU invoices. That will probably change in case of No Deal, I have not found a definitive answer to that yet. Will I need to reopen all contracts to change pricing?"

          Just realised VAT is the least of our problems, we're familiar with that and can deal with the changes.

          But if you're shipping goods from the UK after a hard Brexit that means importing into the EU and, at best, having to comply with the WTO rules Brexiteers seem so fond of. And figuring out what rules, tariffs and non-tariff measures apply is going to be a bit of a nightmare for a small business not familiar with this stuff:

          General info https://www.wto.org/english/tratop_e/tratop_e.htm

          Tariffs https://www.wto.org/english/tratop_e/tariffs_e/tariff_data_e.htm

          Even just figuring out which Harmonized System code applies to your product is quite a job. It's not just the tariffs as such but also the added hassle.

      3. EvilDrSmith Silver badge

        Re: I hope any fallback systems have been tested for their interconnections ...

        >What happens if a customer in Austria decides to stop paying their instalments after a No Deal? Just finding out which court would be appropriate is something nobody has had to think about until now.

        Well, step 1 is to read the contract and see if it says something to the effect that 'this contract is governed by English (or Austrian, or whatever) law and subject to the jurisdiction of the English courts', which tend to be a fairly common clause in my (limited but not zero) experience of international contracts.

        1. Len
          Meh

          Re: I hope any fallback systems have been tested for their interconnections ...

          "...subject to the jurisdiction of the English courts."

          You're right of course, that's what it currently says. The problem is that, until there is a new agreement on how to solve cross border legal matters with the other 27, the English courts have lost a lot of the powers they currently have over people not residing in England and Wales. No Deal means that English courts are no longer automatically recognised in the other 27 countries.

          For instance, we always have the "...subject to the jurisdiction of the English courts." in our contracts, even if the counterparty lives on the other side of the planet. We just have to hope that it looks impressive enough because taking a Cambodian client to an English court is not worth it.

          1. EvilDrSmith Silver badge

            Re: I hope any fallback systems have been tested for their interconnections ...

            You seem to be implying that the basics of contract law don't apply in Cambodia (I couldn't comment; no experience in that matter), and that post BREXIT, it won't apply in the EU either (that is, that the EU27 will now act like some allegedly dubious less developed nation).

            I on the other hand expect that the EU 27 will continue to operate like civilised nations where the rule of law is actually respected. Contracts stating under which legal jurisdiction they operate have been standard for many more years than the EU (/EC/EEC) has existed. Suggesting that in some way such clauses will be disregarded by the EU27 is not realistic or credible.

            1. Len

              Re: I hope any fallback systems have been tested for their interconnections ...

              Of course the basics of contract law will still apply. The other 27 countries have had contract law for centuries and will still have contract law after Brexit. They are not the ones changing, we are.

              At the moment there is a whole host of agreements such as the 'Lugano Convention', the 'Brussels Regime', the 'Rome I Regulation' and the 'Rome II regulation' that deal with how the EU members, the EEA and Switzerland recognise each other's jurisdictions and courts, how to settle cross border legal disputes etc. Most of these would at some point during the transition be negotiated by the UK to limit the disruption to UK businesses. They will, however, most certainly not all be done and dusted before 29 March. That is why business worry about a No Deal crash out. The disruption is real.

              An English court can say that an Austrian debtor is liable for a breach of contract but unless there are agreements between the UK and Austria (as there are now under EU law) that debtor might just decide to shrug their shoulders about the ruling of some foreign court. Austria is not going to extradite one of their citizens to the UK for a missed payment and for a UK business the cost of pursuing someone abroad may not add up.

              1. EvilDrSmith Silver badge

                Re: I hope any fallback systems have been tested for their interconnections ...

                Fair points, but potentially this makes the problem one for EU27 companies, not the UK companies. The EU trades with countries world wide, and my understanding (admittedly very, very limited) is that the current version of 'Lugano' sets down that choice of jurisdiction is permissible (and enforceable), wherever it is in the world.

                So in the hypothetical case of UK and Austrian firm, the Austrian firm would be bound by the EU's rules on contract, even in regard to a UK firm and a contract that stated English law applies, since EU contract law (strictly Austrian law compliant with EU agreements etc, etc) applies to the Austrian company, which says you must respect choice of jurisdiction.

                The English firm would be bound only by English law, and would (in theory) not be subjected to these agreements. In theory, since the expressed intention by the government is that 'Lucarno' continues to apply.

                And none of this alters the fact that long before Lucarno or the original Brussels agreement, contracts were written with jurisdiction specified, and somehow business worked ok.

  5. Warm Braw

    SMEs in other EU countries have the same problem

    Rather than invest in lawyers, they'll take the safe choice of ensuring their services are withdrawn from UK infrastructure.

    1. Charlie Clark Silver badge

      Re: SMEs in other EU countries have the same problem

      In lieu of any clue as to what will happen, and due to contractual and legal constraints this is starting to happen.

      BTW "no-deal" should be replaced by disorderly as there is now simply not enough time (to pass the necessary legislation, make provisions, hire and train staff, etc.) to make it orderly.

    2. Steve Davies 3 Silver badge

      Re: SMEs in other EU countries have the same problem

      Indeed.

      Look out for a lot of things to carry words like...

      "Not For Sale or Use in the UK"

      Another fine mess we have gotten ourselves into...

      Where's Farage in all this? Sunning himeself on some tropical island (using his MEP salary perhaps)?

      It was all going to be so easy wasn't it?

      1. Phil O'Sophical Silver badge

        Re: SMEs in other EU countries have the same problem

        Look out for a lot of things to carry words like...

        "Not For Sale or Use in the UK"

        Already happens. Have you ever tried to buy equipment fitted with a Schuko mains plug from a continental Amazon website for delivery to the UK?

      2. Doctor Syntax Silver badge

        Re: SMEs in other EU countries have the same problem

        "Where's Farage in all this?"

        I heard he was looking for a new party to join in case Brexit gets postponed beyond the EU elections and he can get another chance for and EU Parliamentary salary.

  6. devTrail

    What are we talking about?

    What are we talking about? Real tech companies or those small agencies that act as a legal screen between the contractor and the real "employer"?

    The second ones will probably suffer, but I won't shed a tear for them.

  7. Dr Scrum Master

    Incompetence

    Any business worth its salt should have been planning for a no-deal Brexit over 2 years ago.

    (The Civil Service should have been planning at least 3 years ago...)

    1. Gonzo_the_Geek

      Re: Incompetence

      That's easy to say, but is somewhat unfair on small businesses who have had no clear guidance on what exactly to prepare for, and who do not have the resources to prepare for everything just in case...

    2. Anonymous Coward
      Anonymous Coward

      Re: Incompetence where incompetence is due

      Any Government worth its salt should have agreed a deal a year ago, rather than cowering in their trench in case Nigel Farage snuck up and shouted 'Boo'. This is all down to the Conservatives spending 2 years claiming they had a plan, but it was too secret to tell anyone (including the EU or, it appears, themselves).

      And Civil Servants do what the government tells them to do.

      1. Len
        FAIL

        Re: Incompetence where incompetence is due

        Any government worth its salt wouldn't have triggered Art. 50 until it had decided what country it wanted to be in ten year's time and gotten three quarters of the country behind that vision. Even Nigel Farage called Art 50 a trap that would lead to a vassal state, and that was years before the word Brexit was invented. That was a major strategic blunder.

        It took the UK Government 22 months to present the EU27 with their first proposal. And that proposal, "Chequers", was disliked by a large part of the population within a day. By playing their cards close to their chest the Government never showed their workings. They didn't show the people the touch choices, the options that were discussed but found inadequate, the downsides to certain options, the impact reports.

        And now, with just weeks to go on the clock, we are still debating options that should have been debated and discarded as too damaging a year ago.

        1. Boris the Cockroach Silver badge
          Flame

          Re: Incompetence where incompetence is due

          Quote

          Any government worth its salt wouldn't have triggered Art. 50

          _--

          Actually as a leave voter (stop throwing stuff at me), I'm looking at this whole process with the belief that the tory party fucked it up completely , and even as a firm believer in democracy and one man one vote, I think I'd support the Queen if she marched in parliment at the head of a guards division , arrested all the MPs and threw them in the tower.

          Then called the EU up and said "Right , the adults are in charge now... lets do this leave deal properly"

          In reality, what should have happened in Camermoron should had the balls to say "Ok I lost... lets get everyone together, see what we want in terms of a future relationship with the EU. then informally sent those ideas to the EU, come up jointly with a deal that benefits both sides, signed/passed it and then activated A50.

          1. Phil O'Sophical Silver badge

            Re: Incompetence where incompetence is due

            ... lets get everyone together, see what we want in terms of a future relationship with the EU. then informally sent those ideas to the EU, come up jointly with a deal that benefits both sides,

            Absolutely agreed. Unfortunately the EU reaction was "let's agree how much you've willing to pay us first, then we'll talk about the terms for letting you go ". A win-win deal was never on the cards, the EU wouldn't even negotiate informal terms until Art.50 was invoked. Now we're heading for lose-lose.

            1. Roland6 Silver badge

              Re: Incompetence where incompetence is due

              ...the EU wouldn't even negotiate informal terms until Art.50 was invoked. Now we're heading for lose-lose.

              Agree, but what got me was that the EU were public in their stance, yet the UK government/Conservative party, even knowing what it did about negotiating with the EU, went ahead regardless and invoked Art.50 without any real thought or preparation...

          2. Doctor Syntax Silver badge

            Re: Incompetence where incompetence is due

            Camermoron should had the balls to say "Ok I lost... lets get everyone together, see what we want in terms of a future relationship with the EU. then informally sent those ideas to the EU, come up jointly with a deal that benefits both sides, signed/passed it and then activated A50.

            What he should have done was a feasibility study. It was about the most that an advisory vote would have justified in the first instance. It should have been his plan B before the vote. If he'd had any plan B at all he wouldn't have panicked and quit.

          3. Charlie Clark Silver badge

            Re: Incompetence where incompetence is due

            Actually as a leave voter (stop throwing stuff at me), I'm looking at this whole process with the belief that the tory party fucked it up completely

            What did you think would happen? We did tell you so.

            then informally sent those ideas to the EU, come up jointly with a deal that benefits both sides

            That was never going to happen, apart from the fact the EU could only really negotiate once Article 50 was invoked and had previously already negotiated with the UK, the genie was out of the bottle and the loons were screaming: let's just leave without any kind of agreement. It'll be alright, Dunkirk spirit and all that.*

            * Dunkirk was, of course, basically a disaster, so we've form on this.

          4. Anonymous Coward
            Anonymous Coward

            Re: Incompetence where incompetence is due

            "In reality, what should have happened in Camermoron should had the balls to say "Ok I lost... lets get everyone together, see what we want in terms of a future relationship with the EU. then informally sent those ideas to the EU, come up jointly with a deal that benefits both sides, signed/passed it and then activated A50.”

            Anyone suggesting such a course of action would have been vilified as a TRAITOR and an ENEMY OF THE PEOPLE.

            But I suppose at least Hameron would have had police protection from the Mob Of The People that the Brextremist press would have whipped up ...

      2. Ken 16 Silver badge

        Re: Incompetence where incompetence is due

        unfortunately all the governments been telling them is a combination of "Don't Panic!" and "They don't like it up 'em".

    3. devTrail

      Re: Incompetence

      Might be incompetence, but it could also be unwillingness in order to cry foul.

      1. Flocke Kroes Silver badge

        Re: Incompetence

        It is tempting to think our politicians are acting stupid because stupidity is more easily forgiven than malice but after decades of them consistently 'acting' stupid I am convinced they are incapable of anything else.

        1. devTrail

          Re: Incompetence

          after decades of them consistently 'acting' stupid I am convinced they are incapable of anything else.

          I beg to disagree. Stupidity is random. Consistency can only be achieved through well planned malice.

    4. Doctor Syntax Silver badge

      Re: Incompetence

      "Any business worth its salt should have been planning for a no-deal Brexit over 2 years ago."

      Some politician tried telling that to the farmers in the Irish border region a few months back. It was explained that this would involve spending a few million on a new processing plant just on spec.

  8. Potemkine! Silver badge

    Piece of cake (and eat it)

    Don't worry; companies still have two months to be ready.

    Where's the "ironic" icon when you need it?

    1. Yet Another Anonymous coward Silver badge

      Re: Piece of cake (and eat it)

      March 29 is a friday, you have the whole weekend to re-engineer your business to the new rules.

      1. Charlie Clark Silver badge

        Re: Piece of cake (and eat it)

        And Monday ist April 1st… Maybe Theresa May does have a sense of humour after all?

  9. Anonymous Coward
    Anonymous Coward

    I'm sure every thing will work out. No country would just implement some thing like this haphazardly and with out a plan. If you guys need help you can ask out glorious leader Donald trump. The an is a fucking genus and fix any thing with approval from Putin.

  10. AndrueC Silver badge
    Joke

    I suppose general uncertainty is better than general failure. Of course neither are as serious as corporal punishment.

    1. Phil O'Sophical Silver badge

      I suppose general uncertainty is better than general failure. Of course neither are as serious as corporal punishment.

      Unfortunately our old chum Major Cockup trumps them all.

  11. SVV

    If there is no deal

    and the chaos is so severe, then small tech firms will be well down the list of government priorities.

    I myself have been preparing for the no deal scenario by forming a new startup company selling magic tech solutions for seamless border controls and customs checks so that the government will come running to me and throw hundreds of millions of pounds in my direction once they start panicking. We don't actually have any staff or software or hardware yet, but it won't really matter as the startup companies contracted to provide ships to bring in the emergency rations haven't got any ships yet, so they won't notice that the systems don't exist.

  12. Carazow

    i do like the sense of british humor! starting with the headline...

    1. Rich 11

      We have to make jokes about it else we'd all end up in the psych wards with severe depression. As a last resort we might try rioting in the streets, but that's generally considered rude.

  13. Anonymous Coward
    Anonymous Coward

    London has fallen

    You have bigger issues when your Government answers to foreigners demanding you Sovereignty.

    Get out as fast as you can and dominate those who have plundered you.

    1. Tom 35

      Re: London has fallen

      Better to make Putin happy by shooting yourself in the foot with a no-deal Brexit.

  14. Anonymous Coward
    Anonymous Coward

    Readiness, you say

    Today I discovered I'm looking at north of £1,500.- for the privilege of keeping my pilot licence and ratings valid and recognised across the EEA after March. Until recently the CAA were saying "don't worry, nothing will change". Nothing will bollocks!

    1. Anonymous Coward
      Anonymous Coward

      Re: Readiness, you say

      And you believed them?!?

      Just wait a few years until the Home Office tells all the EU citizens they are suggesting can stay are sent packing to placate the next wave of austerity fuelled malcontents.

      You can't trust what these orgs say because they don't actually know.

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