Still some friction for trade in supplies and work across the Irish border

UK stays in European market and system for medicines, devices, data, clinical trials, procurement and probably working time

Free movement of labour almost guaranteed

Checks and requirements for trade in supplies and work over the Irish border

NHS and life science companies no longer have same level of access to EU market

No guarantee of open migration

Trade in physical supplies and movement across Irish border continue much as today

UK stays in bigger EU market for medical supplies. Trials and surveillance may be impeded. Room to change procurement and working time possible but may be ruled out

Likely to go alongside free or close to free movement of labour

Checks, requirements and tariffs for trade in some supplies and work over the Irish border

Some health care products can still be bought, sold and approved in single market, but not all. Procurement regulations still aligned but not working time

Precedent suggests link to commitments on open migration

Some level of friction for trade and border, depending on specifics

UK will diverge and lose access for some things, not others: what these would be is unclear and must be negotiated

 Unclear