Instead of rehashing old Brexit debates, the UK and EU should collaborate on mutual recognition and adopt the best elements of each other’s private market frameworks to help start-ups raise capital more efficiently, says Kieron O’Brien
“Come back to the EU anytime”, French minister Roland Lescure said last week, adding that if Britain wanted to rejoin the bloc, it would be pushing at an open door. It came as Andy Burnham held talks in Berlin with Friedrich Merz on greater European unity. Today our new PM will tell MPs it will be a “dereliction of duty” to turn down closer ties to the European Union if they can be negotiated. Ahead of the November EU-UK Summit, and a possible general election next year, debate will escalate.
One assumes the Prime Minister knew what he was doing at his Labour conference when he refused to rule out going into the next election with a pledge to hold a second Brexit referendum. It was always going to reignite old debates. But we need to tread carefully, not least to avoid getting sidetracked by rehashing old divisions instead of seizing the opportunities in front of us.
When it comes to how our brilliant young European companies raise money and how we operate private markets, the smartest thing our Prime Minister can push is taking the best rules and systems from both markets. Certainly not the UK becoming a passive rule taker. In the UK we are first in the world for mature private market frameworks and a straightforward, highly respected legal system.
Based in Dublin, I work with founders across Europe through Republic Europe, an online platform where start-ups and growing companies raise money from the public, via crowdfunding and secondary markets. £209 was committed to campaigns via Republic in 2025 across the UK and EU.
Chasing excellence
Innovation is the cornerstone of any growth economy, and Europe and the UK are in a global race. Many founders I meet are at the forefront of groundbreaking technologies that will not only drive better outcomes for humanity but the potential to create jobs, solve our energy problems and act as a boon to industry. They work in medtech, climate tech, clean energy and fintech. Everywhere I go, they tell me they want the same outcome; to raise as much money as they can, as seamlessly as they can, on the least onerous terms.
There is no need for a referendum or to rejoin the Customs Union to make it easier for founders to raise capital now. But we do need to work together, chasing excellence in the systems we set up. Republic has run EU-regulated crowdfunding campaigns since 2023 and UK-regulated crowdfunding campaigns for even longer; we see both sides every day.
What could the EU borrow from us? Well, for example, The UK EIS and SEIS schemes, which offer investors upfront relief and potential Capital Gains Tax exemption and reliefs. The UK has just raised the limits a company can raise under EIS schemes: the annual amount a company has doubled to £10m (£20m for knowledge-intensive companies), and lifetime limits rose to £24m (and £40m for knowledge-intensive companies). The EU has multiple schemes that seek to achieve the same for investors, but they are painful for a cross-border investor to navigate
The UK regime already offers something close to what EU Inc is trying to develop. The FCA’s regulatory sandbox, new private-market trading venues (Pisces), and newly regulated gateways through which platforms can increase their offer of investment opportunities in early stage companies (Public Offering Platforms) – are making it easier in the UK for early-stage companies to raise equity investment and for investors to find opportunities to invest in those companies. EU Inc is their attempt to catch up with us.
Capital is one export that does not need a lorry, and there are better options for founders that EU inc. and the UK could explore right now. Tax relief, for one. We should negotiate a founder capital corridor and let SEIS and EIS tax relief follow investors across the Channel (and vice versa).
Mutual recognition schemes like this are easy to create and boost enterprise and innovation for everyone. We don’t need to wait a decade for another referendum. We should act like entrepreneurs and find opportunities today.
Kieron O’Brien is managing director of Republic EU