The UK government has been busy negotiating Free Trade Agreements (FTA) after Brexit, with the latest being the UK–Gulf Cooperation Council (GCC) FTA. Negotiations are concluded as of 20 May 2026 but a number of steps are still to follow before entry into force. Given that this is not a bilateral agreement but requires ratification by the UK and 6 GCC States, namely the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar, the Kingdom of Saudi Arabia, and the United Arab Emirates (UAE), entry into force is unlikely in the short term. 

While the agreement does not seem transformative to the GCC States’ IP systems, especially in view of harmonisation and scope of protection, it will include a comprehensive IP chapter, expected to be closely aligned to modern FTA standards, with improvements in enforcement and predictability. 

The FTA covers all main areas of IP Law, namely trade marks, designs, copyright, patents and data protection, trade secrets and geographical indications, and includes a number of cooperation and enforcement provisions. 

The FTA includes WTO Trade-Related Aspects of Intellectual Property Rights (TRIPS)-Plus commitments, i.e. obligations that go beyond the minimum standards of the TRIPS Agreement. The government specifically mentions provisions on patent extension for pharmaceuticals, which compensate patent holders for the time they lose waiting for market authorisation, which currently exist in the UK but not in all GCC States. Considering the difficulty of updating multinational agreements, FTAs have become an important mechanism for raising IP standards. 

According to the UK government, the FTA will further include 32 enforcement articles, covering civil, criminal, border and digital enforcement, in particular enabling action against online infringement. Together with the agreed dispute settlement mechanism, this makes the IP obligations enforceable and lifts IP infringement to a trade issue. 

The legal text is still being finalised and it will be interesting to see the finer details. However, it seems that, after initially preserving EU standards, the UK government has now found its own approach of a more strategic and flexible model that incorporates explicit TRIPS‑plus commitments and integrates IP with digital trade and innovation policy.