Reports in the international press last week suggested that after discussions with NATO leaders, US President Donald Trump may be considering the establishment of American military bases in Greenland similar to those the United Kingdom has in Cyprus.
These media reports brought renewed attention to a unique arrangement that has existed in Cyprus since 1960, when the country gained independence from the UK following decades of colonial rule and a four-year armed struggle.
Independence from UK in 1960
Although the declaration of independence on August 16, 1960 formally marked the end of British colonial rule, it did not lead to the UK's complete withdrawal from the island.
On the contrary, the Treaty of Establishment of the Republic of Cyprus included an explicit provision stating that "the territory of the Republic shall comprise the island of Cyprus (…) with the exception of two areas specified in an annex to the Treaty, which shall remain under the sovereignty of the United Kingdom."
What are the SBAs?
These areas — known as Sovereign Base Areas, or SBAs — are Akrotiri and Dhekelia, which are located in the south and east of the island.
To this day, they cover a total area of 254 square kilometers (98 square miles) — approximately 3% of the territory of the Republic of Cyprus.
Does the UK pay to use the SBAs?
Under the Treaty of Establishment, the UK was not obliged to pay for the use of these areas, although a clause provided for financial assistance to the Republic of Cyprus in the form of a grant.
According to Cypriot state archives, however, this grant was paid for only five years, as the UK unilaterally suspended payments in 1965, citing the changed circumstances following intercommunal violence.
After almost a decade of bi-communal violence, a Greek-backed coup and a Turkish military intervention in 1974, the island was divided into the Republic of Cyprus, which is a member of the EU, and the self-declared Turkish Republic of Northern Cyprus (TRNC), which is not recognized by the international community.
Who controls the SBAs?
More than 65 years after independence, the SBAs of Akrotiri and Dhekelia remain under full British control. They have their own administration, legislation and judicial system.
Administration is exercised by the British Forces Cyprus, which function as a local authority reporting directly to the UK Ministry of Defence. As a result, the Administrator of the Bases has the power to enact laws "for the peace, order and good governance" of the SBAs.
Are the bases part of the EU?
The status of the British bases did not change with Cyprus's accession to the European Union in 2004.
The country's Accession Treaty included Protocol No. 3, which excludes the SBAs from the application of the EU acquis communautaire, the body of legislation, rights and obligations in place in all EU member states.
Can the SBAs be used for non-military purposes?
Kostas Paraskevas, professor of Public Law and Human Rights and president of the Law Department at the University of Cyprus, told DW that "sovereignty over the British bases is not absolute, as under the Treaty of Establishment, the United Kingdom assumed specific and explicit obligations not to undertake certain actions within the bases."
Paraskevas explained that the treaty stipulates that the bases "shall not be developed for purposes other than military ones; that no customs barriers shall be established between the Republic of Cyprus and the bases; that commercial or industrial enterprises shall not be permitted; and that civilian ports or airports shall not be constructed."
As a result, there is no border control between the bases and the Republic of Cyprus. Entry and exit remain unrestricted, and commercial development within the bases is limited.
Who lives in the SBAs?
According to recent estimates, around 18,000 people live within the Sovereign Base Areas, of whom approximately 11,000 are Cypriot citizens, while the remainder are British military personnel and their families.
All Cypriots who were living in these areas when they were designated SBAs in 1960 continued to live there after that. The absence of border controls means that their day-to-day lives are not negatively impacted.
Does Cyprus have a say in what the bases are used for?
Although British military activity conducted through Akrotiri and Dhekelia is largely shrouded in secrecy, British media outlets such as the BBC and The Guardian have in the past documented the involvement of British RAF forces or NATO allies operating out of the bases in military operations relating to Iraq, Syria, Yemen and Gaza.
On each of these occasions, the Republic of Cyprus has sought to distance itself from these activities, issuing official statements that stress the Cypriot authorities' inability to exercise any control over the SBAs.
In 2024, for example, government spokesperson Konstantinos Letymbiotis issued a statement after protests over the role of the SBAs in conflicts in the Middle East, saying that "Cyprus is not involved in military operations" and pointing out that in accordance with the Treaty of Establishment, "Britain is not obliged to inform the Cypriot authorities of activities carried out within the Bases."
How do the people of the Republic of Cyprus feel about the SBAs?
Within Cypriot society, anti-war demonstrations remain the most common form of political expression relating to the SBAs and have been the main catalyst for the revival of the long-standing post-colonial slogan "Bases out of Cyprus."
The call for the bases to be removed does not, however, feature prominently on the agenda of political parties in the Republic of Cyprus, although political figures have occasionally referred to the need to modernize their status.
In an interview with DW, Kostas Clerides, former attorney-general of the Republic of Cyprus, argued that "the status of the bases under international law is unacceptable as it constitutes a remnant of colonialism."
Clerides recently circulated a letter to political parties in the Republic of Cyprus and President Nikos Christodoulides, proposing consultations with the UK aimed at signing new agreements that would amend the status of the SBAs.
Citing the 2019 advisory opinion of the International Court of Justice in the case Mauritius v. United Kingdom and the subsequent UN General Assembly resolution obliging Britain to end its administration of the Chagos Archipelago — another matter recently addressed by President Trump — Clerides argues that a legal precedent now exists for the Republic of Cyprus to pursue similar action.
