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Brexit: what consequences for moving and working in the EU or the UK?

As of 1 January 2021, Brexit put an end to the free movement of persons between the EU and the United Kingdom. If you are in a cross-border situation involving the EU and the UK, you certainly have many questions, especially on your residence and working rights. Here is a quick recap of the impact of Brexit depending on your situation.

EU and British flags © European Communities, 2008

 

  • I am an EU citizen legally residing in the UK before 1 January 2021 and still living there

The Withdrawal Agreement protects your right to remain or work, ensures non-discrimination, and protects your social security rights. You need to apply to the EU Settlement Scheme to stay in the UK.  Find more information on Your Europe

 

  • I am a UK national legally residing in the EU27 before 1 January 2021 and still living there

The Withdrawal Agreement protects your right to remain or work, ensures non-discrimination, and protects your social security rights. You may need to apply for a new residence status in the EU country where you are living. Find more information on Your Europe

 

  • I am an EU citizens arriving to the UK after 31 December 2020

To visit, study or work in the UK you need to comply with the UK's existing immigration legislation applicable to all third country nationals. Find out if you need a visa on the UK government website.

 

  • I am a UK national arriving in the EU after 31 December 2020

To visit, study or work in the EU, you need to comply with the EU and national rules on migration from third countries. Among other things, you will need a work permit. Find more information on the EU immigration portal.

 

  • I was a frontier worker before 1 January 2021 and continue being one

The Withdrawal Agreement protects your rights in the countries where you work.

EU citizens who work in the UK but do not reside there can still enter the UK with their passport or national identity card. As from 1 July 2021, you will need a Frontier Worker permit (except Irish citizens).

UK nationals who work in the EU but do not reside there have the right to obtain a frontier worker document recognising their rights. Some EU countries require applying for a frontier worker document.       

  • I am a posted worker

The Agreement does not include rules for the posting of UK workers in the EU, or vice-versa. This means that, for example, a worker sent by the UK to the EU to work will have to pay social security contributions in the EU Member State and will be subject to the legislation of that country, unless the EU country decides to continue the posting system as it exists now. Find more information on DG Employment, Social Affairs & Inclusion website.

 

Useful links

Citizens’ rights in the EU-UK Withdrawal Agreement

The EU-UK Trade and Cooperation Agreement

Brexit and the free movement of persons, social security coordination, healthcare and posted workers