Post-Brexit, two paths that no longer converge.
| EU Inc. | UK Ltd | |
|---|---|---|
| Minimum capital | €0 | £0 (no minimum) |
| Registration | 48 hours | 24 hours |
| Cross-border EU | 27 EU states | None (third country) |
| Legal system | Civil law (27 courts) | English common law |
| Employee equity | EU-ESO | EMI scheme (UK only) |
| Investor familiarity | New | Established (UK/US VCs) |
Before Brexit, the UK Ltd was a popular choice for European founders. Post-Brexit, EU single market recognition is gone. A UK company operating in the EU is now a foreign entity.
EU Inc. does what the UK Ltd used to do: a single registration giving recognition across multiple countries. But it is limited to the EU 27.
For founders who value common law predictability and are focused on the UK or US market, the UK Ltd retains its strengths. For founders building in the EU, EU Inc. provides what the UK Ltd no longer can.
EU market focus, EU investors, EU team across multiple countries
UK market focus, UK/US institutional capital, English law preference
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