Both nations are reorienting from the same southern shock – Brexit for Scotland, Trump for Canada – and the European answer is being written in two capitals at once.
Scotland voted 62% to stay in Europe and was taken out anyway. Canada built its economy and its defence beside the United States and is now turning away from it. Two nations, one direction of travel.
The shock came from the south
For Scotland, the break was Brexit. In the 2016 referendum, Scotland voted 62% to remain in the European Union, with a majority for Remain in every council area. The United Kingdom as a whole voted 52% to leave. Because sovereignty over international relations is reserved to Westminster, Scotland left the EU, the single market, and the customs union on the same terms as England – taken out of Europe on a vote it did not return. Six years of lost freedom of movement, lost single-market access, and lost research and student programmes followed the United Kingdom’s eventual departure in 2020, none of it chosen at the Scottish ballot box.
For Canada, the break is Trump. Within weeks of returning to office he placed tariffs on Canadian autos, steel, aluminium, and lumber, and repeatedly floated absorbing the country as a 51st state. On 27 March 2025, the day after a 25% tariff on automobiles, Prime Minister Mark Carney told reporters that the old relationship with the United States – built on deepening economic integration and tight security cooperation – “is over”, and that the United States was no longer a reliable partner. He later described the change as a rupture, not a transition.
Two nations. Two southern powers. The orientation that had organised each economy and each defence broke from the same compass point – for Scotland through Westminster’s referendum, for Canada through Washington’s tariffs.
Ottawa signed; London reset
Carney made the turn first, and made it physical. His first foreign trip as prime minister went to Paris and London rather than Washington, where he called Canada “the most European of non-European countries”.
The phrase became instrumental. At the 20th EU–Canada summit in Brussels on 23 June 2025, Canada and the EU signed a Security and Defence Partnership and opened negotiations across trade, defence, digital, and climate. Canada looks first to the EU, Carney said, to build a better world. By 1 December, Ottawa had concluded negotiations to join the EU’s €150bn Security Action for Europe defence-financing instrument, and EU member states endorsed the agreement on 19 December. Ottawa expects to be the only country outside Europe with preferential access to the fund. Beneath the new partnership sits CETA, the trade agreement that has run provisionally since 2017.
Five weeks before the Brussels summit, the United Kingdom made a smaller turn of its own. On 19 May 2025 it held its first summit with the EU since leaving, signing its own non-binding Security and Defence Partnership, extending EU fishing access to British waters to 2038 as the price of the deal, committing to a food-standards agreement, and opening the door to British participation in the same SAFE fund Canada was about to enter. The reset runs within the existing post-Brexit trade agreement; it eases the rupture without reopening the question of membership.
The structural picture is exact. Two Westminster-descended nations, five weeks apart, signed the same kind of non-binding defence partnership with Brussels and queued for the same European defence fund – one that had never been in the EU, one that had just left it.
The lever each holds
The difference between them is not their appetite for Europe. It is sovereignty.
Canada turns to Europe holding its own foreign policy. It can sign a partnership, deepen it across four policy fields, and join a European defence fund as a sovereign state, because the authority to do so sits in Ottawa and nowhere else. The reorientation is Canada’s to make, and within two years of the shock it has made it. The turn is industrial as well as diplomatic: SAFE opens European defence-procurement markets to Canadian manufacturers and is built to draw European investment into Canadian production.
Scotland’s European relationship is not Scotland’s to hold. As diagnosed before on this masthead, foreign affairs and the EU relationship are reserved to Westminster under the devolution settlement. The UK’s reset is a reset, not a return – a partial easing of the rupture, negotiated by the government that holds the lever, on terms that stop well short of rejoining the single market. The fishing access traded away to secure it was decided in London. Scotland cannot re-enter the Europe it voted to stay in, because the relationship is administered by the parliament that took it out.
The southern shock is shared. The instrument to answer it is not.
The mandate and the missing instrument
What Scotland holds is a mandate. The Holyrood election of 7 May 2026 returned the SNP as the largest party on 57 seats, with Labour and Reform UK tied on 17 apiece and no party near a majority. The chamber nonetheless carries a pro-independence majority of 73 seats between the SNP and the Greens – even with Reform UK entering Holyrood for the first time. The pro-European direction the 62% set in 2016 remains the parliamentary majority a decade on.
What Scotland lacks is the means. The Scottish Government’s own European prospectus states the aim without hedging: an independent Scotland would apply to re-join the EU as soon as possible. The same paper records that no other country has been removed from the EU and its single market against its will. It also names what Scotland would bring to the table – its renewable-energy capacity chief among them, the same seabed wealth now being licensed under devolved control. The asset is real. The return is fully written. Neither can be lodged while the constitutional question stays shut.
Canada has the mandate and the instrument. Scotland has the mandate and not the instrument. That gap – between a country that can act on its reorientation and a country that can only resolve to – is the whole distance between a reset and a return.
The nearer continent
Canada is Scotland’s mirror, not its model. It shows what reorientation looks like when a nation holds its own foreign policy: a partnership signed, a fund joined, a relationship deepened on its own authority inside two years. Scotland shows what reorientation looks like when the centre holds the lever: a mandate renewed, a prospectus written, a return deferred to a constitutional question the holder of the lever declines to open.
Both nations are turning to the nearer, steadier continent. Both are drafting the European answer in the same season, against the same southern shock. One of them can sign it.
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