How Does Brexit Affect UK Citizens Living in the EU?

Brexit — the United Kingdom’s departure from the European Union — brought major changes to how the UK and EU interact. While much of the public discussion has focused on trade, travel and business, one of the most deeply personal effects touches people with lives split between the UK and EU countries: UK citizens who live, work, study or have families in the EU. For these individuals, Brexit introduced new rules and realities. This article explains how Brexit affects UK citizens living in the EU, including residence rights, work and social security, healthcare, travel, family life, and long-term planning.

1. What Changed and Why?

Before Brexit, UK citizens were EU citizens by virtue of the UK being a member state. This meant they had the right to:

• live anywhere in the EU,

• work without a permit,

• access healthcare and social services under the same terms as locals,

• bring family members with minimal restrictions.

After Brexit, UK citizens are no longer EU citizens. The transition period ended on 31 December 2020, and the new EU-UK Trade and Cooperation Agreement (TCA) sets out how UK citizens are treated in EU states. In most cases, the automatic rights that came with EU citizenship no longer apply. Instead, UK citizens must follow the immigration and residency laws of the specific EU country where they live.

2. Residence Rights and Permits

UK Citizens Who Were Already Living in the EU

If a UK citizen was legally living in an EU country before the end of the Brexit transition (31 December 2020), they usually have protected status under special arrangements. This typically means they must:

• apply for a residence permit or register under the local Brexit implementation rules,

• show proof of continuous residence before the deadline,

• meet deadlines set by the local government.

The exact process and documents required vary by country, but in most cases these permits allow UK citizens to continue living, working and studying in their host EU country similarly to how they did before Brexit. Some countries charge fees or require biometric data.

UK Citizens Moving to the EU After Brexit

For UK citizens who moved after 31 December 2020, the situation is different. They are treated like non-EU nationals, meaning:

• they must apply for the relevant visa or residence permit before moving,

• eligibility depends on the purpose of stay (work, study, family reunification, retirement),

• they may need language or financial requirements depending on the country.

There is no universal EU-wide permit for UK citizens — each EU state has its own rules and procedures. This means moving to Spain, France or Germany can involve very different requirements.

3. Work and Employment Rights

Before Brexit

UK citizens could work in any EU country without needing a work permit or visa.

After Brexit

Work rights depend on residence status:

• If living in the EU before Brexit and holding valid post-Brexit residency status, many UK citizens can continue working as before.

• If moving after Brexit, UK citizens generally need a work permit or appropriate visa to take up employment.

Most EU countries now assess job offers based on local immigration rules, which may include:

• employer sponsorship,

• minimum salary thresholds,

• proof that no suitable local/EU candidate is available (in some cases),

• language or qualification checks.

Some countries are more flexible for high-skilled workers or students who graduate locally, but the process is no longer automatic.

4. Healthcare and Social Security

Healthcare and social benefits are another area where Brexit brought change.

UK Citizens Already in the EU Before Brexit

In many countries, UK citizens who were covered by the EU’s free movement healthcare arrangements (e.g., through local social security systems) have been able to maintain their healthcare rights through special bilateral or national provisions. This usually involves:

• transfer from UK healthcare coverage to the host country’s system,

• proof of residency and insurance enrollment,

• possible waiting periods depending on local rules.

UK Citizens Moving After Brexit

For new arrivals, access to public healthcare depends on the local immigration category:

• Work visas often include mandatory social security enrollment, giving access to public healthcare.

• Retirement or long-term stay visas may require private health insurance.

• Students usually need health coverage either through the local system or private insurance.

It is crucial for UK citizens to check the exact requirements in their destination country, as costs and eligibility can vary widely.

5. Travel Within the EU

Brexit also affected short-term travel rights:

• UK citizens can travel visa-free for up to 90 days within any 180-day period across the Schengen Area of Europe for tourism or short visits.

• Time limits are counted cumulatively across countries (e.g., France, Germany, Italy).

• If UK citizens stay longer than 90 days without the right residency permit, they can face fines, entry bans or deportation.

This is a big change from before Brexit, when UK citizens could live and move freely in the EU.

6. Family and Personal Relationships

Brexit also affects family lives, especially where family members are not EU citizens:

Spouses and Children

• If a UK citizen lives in an EU country with a non-EU family member, that relative’s right to stay may now be governed by local immigration law rather than EU free movement rights.

• Many EU countries have provisions for family reunification, but requirements and processing times can be strict.

• Some countries accelerate or simplify procedures for long-term partners and children, but the rules are not uniform.

Dual Nationality and Citizenship

Some UK citizens have or seek dual nationality (UK and an EU member state). Dual citizens retain the rights of EU citizenship and are not affected by the loss of free movement. However:

• The eligibility for citizenship depends on the host country’s laws.

• There is no automatic right based on residency alone.

7. Pensions, Taxes and Banking

Brexit also changed financial and administrative arrangements:

Pensions

State pensions for UK citizens living in the EU generally continue, but:

• Annual increases may differ (some EU countries apply uprating; some don’t),

• Taxation of pensions may be governed by double taxation agreements between the UK and the host country.

Taxes

UK citizens living in the EU must follow local tax rules on income, property, capital gains and inheritance. Tax treatment depends on:

• residence status,

• local tax laws,

• double taxation treaties between the UK and the EU country.

Banking

Cross-border banking became more complex post-Brexit:

• Some UK banks changed the services they offer to EU residents.

• UK citizens may need local bank accounts or adapt to transfer limits and fees.

8. Ongoing Challenges and Practical Tips

Challenges

• Complex bureaucracy: Every country’s system is different.

• Cost: Residence and work permits may involve fees and legal costs.

• Uncertainty: Rules can change over time as agreements evolve.

Practical Tips

1. Check deadlines: Most countries had set deadlines to register post-Brexit; if you missed them, contact immigration authorities quickly.

2. Gather documents: Proof of residency, employment, and identity are essential.

3. Understand local rules: Each EU country publishes specific guidance — use official government resources.

4. Plan travel carefully: Respect the 90-day rule for short trips.

5. Seek professional advice: For complex cases (tax, family reunification, legal status), a local immigration lawyer or advisor can help.

9. Looking Ahead

Brexit redefined how UK citizens interact with the EU. For many people with deep personal and professional ties to European countries, adapting to these changes has been challenging. At the same time, most EU countries worked to minimize disruption for UK citizens already living there before Brexit. Over time, established UK residents have generally secured stable status, though newcomers must follow standard immigration pathways.

The long-term impact of Brexit on UK citizens in the EU will continue to unfold as laws and bilateral agreements evolve. Staying informed and proactive is key.