Living In Europe After Brexit: What You Need To Know

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Expatra has had a flood of emails from readers wanting to know about living across the Channel now Britain has formally left the European Union.

What happens now to the UK’s expats, after Brexit? 

News about what happens post-Brexit is coming thick and fast during the transition period, which began on 31 January 2020.

Current rules on trade, travel and business continue to apply for the 11-month transition period while living and working in an EU country “depends on the rules in that country”, the UK government says.

The government has launched a Get Ready For 2021 site to inform UK citizens living in the EU about the changes which will take effect from 1 January 2021.

Its Withdrawal Agreement sets out the terms and provides a deal on citizens’ rights, which remain “broadly the same” to live, work and study in the EU until 2021.

However, there is still a bewildering snowstorm of information and speculation about what happens after that, even when it comes to official pages.

Downing Street has issued a directive to the Foreign Office to stop using the term ‘Brexit’ or ‘implementation period’ to try to make matters clearer.

Here, you will find only the latest facts and confirmed news, with links to the best resources to find out more – and we’ll be sure to keep you updated.

Post-Brexit – business as usual?

The UK is now considered a ‘third country’ to the European Union and this will affect the 900,000 Britons living in the EU – around a quarter of whom are retired – as well as anyone looking to move to the EU after the transition period.

If you can officially settle in by the end of 2020 you will be treated as an EU citizen. Anyone else will be considered third-country nationals under EU law, with so-called ‘lifestyle retirees’ particularly affected.

However, Ben Noifeld, a senior wealth manager for expatriate financial advisory service Abbey Wealth, says that what will happen in 2021 is still “is becoming a little clearer” and is proving to be “not as bad as people were expecting”.

“Brexit has caused a lot of stress and worry. Many of our clients thought they could be forced back to the UK”, says Mr Noifeld, who is based in the company’s Spanish office in Puerto Banús, Andalucía. “But it is looking like business as usual as clients in Spain look to regularise their affairs in line with the Spanish tax system and legal framework.”

Living in Europe after Brexit
Ben Noifeld, our qualified expert, comments on living in the EU after Brexit

“We have noticed that there have been delays in individuals obtaining their residencia due to lockdown / social distancing measures and the number of people looking to do this before the transition period ends.”

“Our advice is if you want to live in an EU country, try and register for residency before the end of this year (2020) as if you move after 31st December 2020, different immigration requirements will apply. Things may be similar to, for example, moving to work in Dubai or retire in Thailand which will involve obtaining a work permit or retirement visa.”

“Our advice is always tailored to our clients’ requirements and objectives which will also take into consideration the tax systems / legal frameworks they are exposed to. This will remain the same with or without Brexit.”

“To date, the biggest impact of Brexit on our clients has been the GBP – EUR exchange rates. Pensioners have seen a significant reduction in their pension income (in EUR terms) that derives from the UK in GBP. This has meant careful planning to ensure shortfalls in income can be made up from other tax-efficient sources. 

“We and our strategic partners have carried out extensive research on GBP since June 2016 but clearly exchange rates are volatile, impossible to forecast over the short term with any conviction and of course there is a significant risk that sterling could fall sharply if a ‘No deal’ Brexit were confirmed at the end of this year.”

“However, there is considerable evidence that exchange rates are determined by fundamental economic relationships over the longer term. Even under an almost unthinkably adverse fallout from Brexit, the pound still looks undervalued which means that on a 3-5 year view there is more scope for sterling to appreciate than there is for it to fall. Things should, therefore, improve for our clients and other expats living in the EU who often rely on income/assets that derive from the UK.”

Urgent post-Brexit ‘to do’ list

The key things the government says you should do “as soon as possible” if you live in the EU-27 (which means these are also things to investigate immediately if you plan to move to the EU in the near- to medium-term future) are:

  • Apply to be a resident in the EU country in which you live
  • Register for local healthcare or take out health insurance
  • Check if your passport is valid for travel
  • Exchange your UK driving licence for a local one
  • Get a health certificate for your pet to replace UK pet passports

We will provide information and links to these tasks below, as well as more information on the all-important finances (including pensions, currency implications, tax and wills), plus details of other issues affecting the Briton retiring overseas, such as pet passports and mobile phone roaming costs.

Finally, in the end, you’ll find a list of useful links and some country-by-country resources for Spain, France, Portugal, Cyprus, Italy and Malta.

EU residency and registration for UK expats

From 2021, the UK’s exit from the EU could end Britons’ right to free movement within Europe.

It is therefore key to sort out residency to confirm you were already resident in the EU country you live in before 31 December 2020.

You have until “at least” 30 June 2021 to submit your application, the UK government says, and the application should be “short, simple and either free of charge or cost no more than applying for a similar document” (such as a national identity card or passport).

You may need to provide proof of identity and undergo criminal and security checks.

Close family members will be able to join you after 31 December 2020 under current EU rules. This applies to spouses or registered partners, dependent children and grandchildren or parents and grandparents, where the relationship began before the end of this Brexit transition period.

You can still move to another EU country on the same terms, too – until 31 December 2020 and there will be no changes to the rules on travelling in the EU until then.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

The government advises looking at its ‘‘Living In’ country guides’; there is further advice and country-specific links below for Spain, France, Portugal, Cyprus, Italy and Malta.

Your right to return to the UK to live, work and access benefits and services does not change and existing close family members can join you in the UK and apply to the EU Settlement Scheme up to 31 March 2022.

Your children’s rights to British citizenship “have not changed”, says the government.

Split time ‘particularly complicated’

The Migration Policy Institute (MPI) says UK pensioners are “less likely” to register for residency than other age groups, as they tend to only do so when incentivised by the need for ongoing healthcare for long-term conditions.

Younger British expats (who have never been entitled to an S1 certificate) have historically been even less likely to register.

Expats used to splitting their time between the UK and other EU countries will find it “particularly complicated” after 2021 to prove residency, maintain their second homes and access healthcare, the MPI warns, as most countries only consider someone resident if they spend more than six months a year there – yet most also require registration for residency after three or four months.

Those who already have permanent residency (such as in situ retirees) will be better placed to apply for any residency status.

From 2021, lifestyle retirees will find it harder to secure residency if the EU applies rules for retirees from outside the bloc, and may need to prove fairly high incomes (€25,560 in Spain) and private medical cover.

Healthcare in Europe for UK expats after Brexit

Rights to healthcare in your country of residence will remain the same “as long as you remain covered by the withdrawal agreement”, the UK government says.

If the NHS pays for your healthcare under the S1 scheme, this is included – but again, only for Britons who move to the EU and secure residency within the transition period.

Otherwise, they can join a public healthcare system provided in their new country of residence on the same basis as local residents.

The Department of Health and Social Care estimated that, in 2017, it was covering healthcare costs for 109,000 UK pensioners in other EU countries.

The UK government says that, if EU member states do not agree to extend existing healthcare arrangements, many EU healthcare arrangements for UK citizens will revert to those that apply to the rest of the world.

That means neither the S1 scheme nor the European Health Insurance Card (EHIC) could be used for Britons in the EU from 2021.

It is also unclear what will happen to the European Health Insurance Card scheme; the EHIC might not be valid. UK pensioners living in the EU at the end of 2020, however, will still be able to use their EHICs.

For anyone else, though, it is recommended you get travel insurance if travelling from 1 January 2021.

Time to go private

If you are a permanent or temporary resident, you should review your healthcare cover, it advises, particularly if you have a pre-existing medical condition.

In other words, check if you need private insurance.

If you return to live in the UK and meet the ordinary residence test, you will be able to use NHS services.

If you are living in an EU country on 1 January 2021 and have an S1 form or EHIC issued by the UK, you may use NHS services in England, Scotland and Wales without charge when visiting the UK. This will not change.

Post-Brexit finances for UK expats in Europe

State pensions

The Department for Work and Pensions (DWP) has pledged that British pensioners living in the EU by 31 December 2020 will continue to receive uprated annual rises after Brexit, for as long as they continue to live there, even if they only start claiming a pension on or after 1 January 2021.

Previously they had warned that they could lose the annual increase if Britain left without a deal.

However, those moving to EU countries after 2020 may not be entitled to the same benefits as the DWP says the rules on entitlement to UK benefits in the EU will “depend on the outcome of negotiations with the EU and may change”.

The state pension is uprated each year by the higher of either wage growth, inflation or 2.5 percent (the so-called triple lock).

Some half a million British pensioners live in 120 ‘frozen’ countries such as Australia, Canada or New Zealand, with their state pension fixed at the same rate as when they left the UK; the government will be under pressure to uprate in all countries if it does so for the EU from 2021.

Personal pensions and annuities

One of the biggest fears for the financial services sector during the Brexit process has been that UK pension providers will not be able to pay income to overseas retirees from 2021.

A UK insurance company, for example, paying an annuity to a UK expat in the EU would no longer hold the ‘passporting rights’ to do so.

Providing financial services without passporting rights means risking fines and penalties.

The UK government says it wants to ensure “market access” and “fair competition”, with a “predictable, transparent” environment for financial services firms.

Some UK financial firms plan to set up subsidiaries in the EU to be able to pay money into European bank accounts.

If you are retired in the EU, or in the process of retirement, and have a UK financial services company looking after your pension pot, you should ask them whether they have their Brexit solutions ready.

The UK government has said it would give temporary permission for financial firms in the EEA to pay people in the UK – so a Spanish pensioner living in the UK, or someone who has worked in Europe but returned to retire in the UK, would not have the same problem during the transition period.

There are, however, big question marks over the protection in place if any of these firms went bust.

To understand more about your pension options in the EU post-Brexit we recommend Abbey Wealth’s free Brexit review. You’ll receive a detailed explanation about setting up your finances correctly and what you need to do now that you’re no longer an EU citizen to continue to enjoy your retirement abroad.

Property

If you buy a new property, some EU countries have different property acquisition laws for EU citizens and non-EU citizens, the UK government says, so check with local authorities how these may apply to you.

Currency and money

The threat of Brexit had considerably weakened sterling, with the pound falling by 15 per cent against the euro from the referendum in 2016 until the end of 2019, based on Bank of England monthly averages.

But Jason Swan of Abbey Wealth thinks the pound-to-euro exchange rate will “pick up” again now.

British pensioners in Europe drawing their income in pounds have taken a “big hit” in recent years, he says, after the euro reached near-parity with sterling (having peaked at 1.7 back in 2000). But he is confident it will reach 1.3 in the next year or two.

It is also worth noting that you may need to declare cash of £10,000 or more if you take it from the UK to any country in the EU (although not if bringing it to the UK from the EU).

Banking

It is not yet clear if surcharges will apply when using UK bank cards abroad, or what will happen to the Financial Ombudsman Service or the Financial Services Compensation Scheme (FSCS) from 2021.

The Financial Conduct Authority also warns that fraudsters may use Brexit as an excuse.

Taxation

Tax rules for each EU country are “unlikely to change because of Brexit”, says the UK government, “as they are down to each jurisdiction to manage.”

The same goes for any double taxation treaty between the UK and another country, to ensure you are not subject to unnecessary tax in the two jurisdictions.

Find the European Commission’s full list of double taxation treaties here.

Mobile phone costs

Remember – the guarantee of free mobile phone roaming throughout the EU, Iceland, Liechtenstein and Norway will end from 2021.

The government has said there will be no requirement for providers to offer free roaming, so check your charges with your phone operator.

You are, however, protected from being charged more than £45 without opting in to spend more.

Inheritance tax and wills

The UK’s withdrawal from the UK does not change any existing UK rules for inheritance tax.

Inheritance tax will continue to be levied on transfers of worldwide assets by those domiciled in the UK and transfers of UK assets by non-domiciled people.

Wills made under UK law remain valid and property abroad continues to be subject to local rules.

Flight delay compensation

If you’re on a flight to or from an EU country delayed by more than three hours, or your flight is cancelled altogether, and it is the airline’s fault, you can continue to apply for compensation of up to £540 per person as it falls under EU rule 261/2004, which is written into UK law.

Passports and travel for the UK expat in the EU

Passports: Six-month rule

From 2021, when visiting most EU countries (plus Iceland, Lichtenstein, Norway and Switzerland) your passport will need to have at least six months left and also be less than 10 years old, even if it does have six months or more left. This does not apply for travel to Ireland.

If you do get a new passport, it will be blue, not burgundy.

Until 2021, you can continue to travel freely in the Schengen area with your UK passport.

UK nationals will not need visas for short trips to the EU but will need a £6 visa waiver.

If you hold a residence permit from an EU, European Economic Area (EEA) or European Free Trade Association (EFTA) country, you will be able to transit through other EU, EEA or EFTA countries to reach your country of residence.

Travel to Ireland will not change after Brexit.

Driving in Europe

You will need an international driving permit (IDP) to drive in some countries – and may need more than one, at a cost of £5.50 each. Check if you need any on the Post Office website.

You will need a ‘green card’, or international insurance certificate, from your car insurance company, to take an UK-registered vehicle into Europe to prove your insurance provides minimum cover – allow one month for this.

And don’t forget to buy a ‘GB’ sticker, even if you have the GB sign on your number plate.

Pet passports

If you plan to move a pet to Europe after 2021, EU pet passports issued in the UK will be invalid.

The new scheme will take four months to organise through your vet, and will require an animal health certificate (AHC), microchipping, rabies vaccinations and blood tests.

Depending on whether the UK, as a ‘third country’, is deemed an unlisted, Part 1 listed or Part 2 listed country, the regulations for pets and their passports will vary.

If you live in the EU and plan to travel with your pet using a UK-issued pet passport, you should speak to your vet to ensure you comply with with EU Pet Travel Regulations.

If you have a pet passport issued by an EU member state, you can use it to bring your pet to the UK.

Resources for UK expats living in Europe

Country-specific resources

Spain and Brexit

If you are resident in Spain at the end of the Brexit transition period, on 31 December 2020, you will be covered by the Withdrawal Agreement’s UK-EU deal on citizen rights – plus your rights will be protected for as long as you remain resident in Spain.

Meanwhile, you must register as a resident in Spain, register for healthcare in Spain and exchange your UK driving licence for a Spanish one.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

The UK government website have released official information for UK nationals moving to or living in Spain, including guidance on residency, healthcare, passports and the Withdrawal Agreement. It confirms:

‘If you are resident in Spain at the end of the transition period, you will be covered by the Withdrawal Agreement, and your rights will be protected for as long as you remain resident in Spain’.

‘If you are legally resident in Spain before the transition period ends on 31 December 2020, you will be able to stay. You must register as a Spanish resident if you want to stay in Spain for more than 3 months’.

‘If you are living in Spain before 1 January 2021 and register as a resident after 6 July 2020, you will be issued with a biometric residence card called a Tarjeta de Identidad de Extranjero (TIE). This card will prove your rights under the Withdrawal Agreement.’

‘If you registered as a resident before 6 July 2020, you will have a green A4 certificate or credit card-sized piece of paper from Extranjeria or the police. This is still a valid document and will prove your rights under the Withdrawal Agreement, including after the transition period ends. You can exchange your paper residence document for the new TIE but you do not need to.’

‘The green paper residence certificate and the new biometric TIE card are equally valid in proving your residence status and rights in Spain`.

France and Brexit

If you are resident in France at the end of the Brexit transition period, on 31 December 2020, you will be covered by the Withdrawal Agreement’s UK-EU deal on citizen rights – plus your rights will be protected for as long as you remain resident in France.

Meanwhile, you must register as a resident in France, even if you have a European carte de séjour marked “permanent” or without an expiry date, before 1 July 2021.

You must register for healthcare in France (and can apply for the mutuelle top-up health insurance).

You must also, eventually, exchange your UK driving licence for a French one – although the UK government recommends waiting because of large delays at present, unless yours has been lost, stolen, expires in the next few months or needs changes.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

It is likely only those Britons officially resident at the end of 2020 will have a legal right to stay. Otherwise, Britons who want to move to France after 2021 as third-country nationals will need to successfully apply for a long-stay visa from the UK and have it validated as a residency permit.

Portugal and Brexit

If you are resident in Portugal at the end of the Brexit transition period, on 31 December 2020, you will be covered by the Withdrawal Agreement’s UK-EU deal on citizen rights – plus your rights will be protected for as long as you remain resident in Portugal.

Meanwhile, you must register as a resident in Portugal, register for healthcare in Portugal and exchange your UK driving licence for a Portuguese one.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

It is likely only those Britons officially resident at the end of 2020 will have a legal right to stay. Portugal otherwise has a Golden Visa programme for third-country nationals (as Britons will become) with a minimum investment of 350,000, which provides an EU resident permit.

Cyprus and Brexit

If you are resident in Cyprus at the end of the Brexit transition period, on 31 December 2020, you will be covered by the Withdrawal Agreement’s UK-EU deal on citizen rights – plus your rights will be protected for as long as you remain resident in Cyprus.

Meanwhile, you must register as a resident in Cyprus by getting a registration certificate from the Ministry of the Interior, Civil Registry and Migration Department.

If you are living in Cyprus before 31 December 2020, you will have life-long healthcare rights in Cyprus (under Geysy) as you do now, provided you remain legally resident.

You should also exchange your UK driving licence for a Cypriot one.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

It is likely only those Britons officially resident at the end of 2020 will have a legal right to stay. Cyprus has a fast-track Golden Visa programme for third-country nationals (as Britons will become), which only takes six months but requires a €2 million investment, plus €150,000 in donations – as well as purchasing a Cypriot residence.

Italy and Brexit

Malta and Brexit

With close ties to the UK, Malta has offered UK citizens resident in Malta by the end of 2020 (the end of the Brexit transition period) full residency rights lasting 10 years, as a new ‘special’ category of EU nationals who moved to Malta.

The application for the permit will be free of charge and the permit will carry all the same rights previously enjoyed, as Malta says it wants to be the most “British-friendly country in Europe”.

Britons who move to Malta from 2021 would also be able to receive a 10-year residence permit, but their rights will be like other third-country nationals and the permit will have a nominal fee.

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

The EEA EFTA and Brexit

The UK reached an agreement with the European Economic Area European Free Trade Area (EEA EFTA) states of Norway, Iceland and Lichtenstein in 2018, which protects citizen’s rights. Read more about the EEA EFTA settlement agreement on the UK government site.

Bulgaria and Brexit

If you are resident in Bulgaria at the end of the Brexit transition period, on 31 December 2020, you will be covered by the Withdrawal Agreement’s UK-EU deal on citizen rights – plus your rights will be protected for as long as you remain resident in Bulgaria.

Meanwhile, you must register as a resident in Bulgaria, register for healthcare in Bulgaria and exchange your UK driving licence for a Bulgarian one (although you must wait at least six months after you register for residency before you do so).

The European Commission has also announced an EU-wide biometric residence document for all British nationals living in the EU by the end of 2020.

It is likely only those Britons officially resident at the end of 2020 will have a legal right to stay.

New Bulgarian rules require immigrants from third-country nationals (as Britons will become) to demonstrate they can support themselves financially, although the Bulgarian prime minister has publicly welcomed British migrants.

Once you have been resident in Bulgaria for five years, you can apply for permanent residency and then, after another five, citizenship. If you apply for Bulgarian citizenship after 31 January 2020, you may have to renounce your UK citizenship.

Switzerland and Brexit

The UK-Swiss Citizens´ Rights Agreement will protect UK nationals resident in Switzerland at the end of the transition period on 31 December 2020. If you are in the scope of the Agreement, you will not need to take any special action to benefit from it.

If you move to Switzerland, you must register at your local office of resident services (Einwohnerdienste or Centre du contrôle des habitants) within 14 days of arriving. Read the guidance by the Swiss government on notification of departure and registration.

International permits (cartes de légitimation) will not be affected and special provisions will continue to apply to international permit holders who retire in Switzerland. 

Ireland and Brexit

The rights of UK and Irish nationals in the Common Travel Area will not be affected by the UK leaving the EU.

You might find useful:

  • The Expat Guide To UK Pensions Abroad – detailed information about your state, workplace and private pensions when you retire abroad; your options, tax implications and opportunities if you transfer your pension pot abroad or leave it in the UK;
  • Banking, Saving, & Investments Abroad – a simple guide to your bank accounts and investment options when you become an expat;
  • Visit our homepage for a comprehensive range of Living Abroad guides.
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