The new UK internal market, as embodied in the UK Internal Market Act 2020 and the common frameworks, is the latest example of market integration, but it is far from being the only one. A myriad of composite market structures exists across the world, including in Australia, Canada, Germany, Spain, Switzerland, the US and the EU. This article investigates how the UK internal market compares to other internal markets: to what extent does it follow pre-existing paths, to what extent does it depart from them? It is argued that the UK has diverged from international blueprints in several important aspects. Despite drawing on methods that are frequently employed for achieving economic integration, it reinterprets and combines these in a unique way. The result is an internal market which is defined by an unusual degree of centralisation, strong trade rights and a high potential for deregulation.
