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At a Glance
Authorities in most EU Member States have published details on post-Brexit residence permits or residence registration options (‘Article 50 residence permits’) for UK nationals residing on their territory before December 31, 2020, and their non-EU national family members.
Application timeframes vary considerably between countries.
As expected, UK nationals arriving and starting work in an EU country after January 1, 2021 require work authorization as other non-EU nationals, and can now apply.
The published details on post-Brexit residence permits or residence registration options for current UK national residents are highlighted below:
Applications must be filed before December 31, 2021, or by the current EU Residence Certificate expiry date; whichever is sooner.
EU Residence Certificates and family member residence permits expiring March 13-October 31, 2020 were automatically extended by six months under pandemic-related concessions.
Until the new permit is issued, individuals can demonstrate their status by their current EU Residence Certificate or family member residence permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until December 31, 2021 or their permit’s expiry date; whichever is sooner.
Applications must be filed in person.
UK nationals can demonstrate residence before December 31, 2020 with an EU Residence Certificate or EU Residence Permit for dependents.
The government fee is BGN 18 for a 30-day processing time or BGN 36 for three-day processing time.
UK nationals with residence over five years can apply for a permanent residence certificate, or can renew their current certificate no later than three days before the expiration date of the current one, or by December 31, 2021, whichever is earlier.
There are no specific provisions for cross-border workers.
Applications must be filed before December 31, 2021. Eligible residents will receive an information letter to apply by email or the online system, e-boks. Applications should be filed per month based on the applicant's year of birth; families are invited to apply together in the eldest family member's slot.
UK nationals holding a permanent residence permit based on EU free movement must also apply for a new Article 50 permit. These individuals similarly apply in slots as detailed in an information letter.
Applications can be filed online or submitted on paper. The application process includes submitting biometric data.
Applicants demonstrate residence before December 31, 2020 by submitting an EU Registration Certificate; or lease agreement, utility bills and/or employment agreement if an EU Registration Certificate is not yet available.
Government filing fees are not yet confirmed.
Until the new permit is issued, individuals can demonstrate their status by their EU Registration Certificate or family member residence permit.
UK nationals with at least five years’ residence as of December 31, 2020 may apply for a permanent residence permit, which grants a corresponding 10-year card. UK nationals with less than five years’ residence will receive a temporary, five-year Article 50 permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until December 31, 2021. Their application window corresponds to the UK national's application window, as confirmed in the invitation letter.
Cross-border workers with an established status before December 31, 2020, confirmed through employment- and travel-related supporting documents, would be able to continue similar activities. These individuals apply at their own initiative throughout 2021 (but are advised to apply early) and receive a cross-border worker card to confirm their status. UK national cross-border workers do not need to be under a local contract after December 31, 2020 but must provide proper documentation to continue their position, such as an employment contract, supporting letter from the employer or an assignment letter mentioning the commuting arrangement.
Further information is available on this site.
UK nationals seeking residence in Estonia can continue to register their residence as an EU national until March 31, 2021.
Applications for Article 50 permits must be filed before expiry of the current EU national identification (ID) card or family member residence permit.
Current EU national ID cards and family member residence permits remain valid, including in case of travel and re-entry into Estonia.
Applicants demonstrate residence before December 31, 2020 by submitting their ID card. No other proof of residence is accepted.
Government fees are EUR 35 for Article 50 residence card applications (EUR 7 for pensioners or those with a disability; EUR 64 for expedited processing; additional EUR 20 for collection at a consular post).
UK nationals holding an Article 50 permit and family members holding a corresponding permit continue to accrue residence towards permanent residence.
Cross-border and posted workers who are not seeking residence in Estonia can continue their activities until March 31, 2021, but may require work authorization starting April 1, 2021.
Applications can be filed until September 30, 2021 via a prescheduled in-person appointment.
Applicants already registered under the EU scheme need not demonstrate residence before December 31, 2020 as immigration authorities have direct access to population records. Individuals who registered very recently can submit alternative proof of residence registration, such as a lease agreement, utility bills and/or proof of residence registration filing.
Government fees are EUR 48.
Until the new permit is issued, individuals can demonstrate their status by their EU residence registration or family member permit.
UK nationals with at least five years’ residence as of December 31, 2020 apply for a long-term permanent residence permit free of charge.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until September 30, 3021.
The proposal does not include any specific arrangement for cross-border workers.
UK nationals without a residence document must apply for status under the Withdrawal Agreement by June 30, 2021. The application process is now open and varies considerably between immigration offices. Applicants are advised to check with their immigration office.
Individuals with urgent travel needs can apply to receive an interim document prior to residence card issuance.
Applications require an in-person visit to submit biometric data.
Applicants demonstrate residence before December 31, 2020 by submitting an EU Registration Certificate. No alternative documents are accepted.
Government filing fees are not yet confirmed.
Until the new permit is issued, individuals can demonstrate their status with their confirmation of registration of residential address.
UK nationals with at least five years’ residence as of December 31, 2020 may apply for a permanent residence permit. UK nationals with less than five years’ residence will receive a temporary permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until June 30, 2021.
Cross-border workers with an established status before December 31, 2020 similarly apply at their local immigration office to obtain a special type of residence/work permission for cross-border workers confirming their right to continue similar work activities.
A government FAQ is available here, and information on the responsible foreigners authority is available here.
Applications must be filed before June 30, 2021. Applications require a prescheduled in-person appointment at the police authorities to submit biometric data.
Applicants demonstrate residence before December 31, 2020 via proof of their EU residence registration, pay slips and/or a lease agreement.
Government fees are EUR 16, both for UK nationals and their non-EU family members.
Until the new permit is issued, individuals can demonstrate their status by their EU residence registration, plus proof of application filing once available.
UK nationals with at least five years’ residence as of December 31, 2020 may apply for a 10-year residence permit.
Non-EU family members of UK nationals holding a corresponding residence permit apply for a specific permit for family members of UK nationals at the Migration authorities between January 1 and June 30, 2021.
The proposal does not include any specific arrangement for cross-border workers.
UK nationals residing in Hungary before December 31, 2020 were required to collect an EU Residence Registration card from the Immigration Office before January 1, 2021 to maintain their rights.
UK nationals who missed this application deadline may still be eligible for a National Permanent Residence Permit, but their non-EU family members may have to submit additional supporting documents.
UK nationals holding EU Residence Registration remain authorized to stay and work in Hungary with no additional permit until December 31, 2021.
UK nationals and their non-EU family members may apply for a National Permanent Residence Permit by December 31, 2021. This permit is available to all non-EU national applicants, but UK nationals and their non-EU family members, registered in Hungary before December 31, 2020 will benefit from reduced document requirements and expedited 30-day processing.
Through this unique approach, Hungary funnels UK nationals and their non-EU family members, registered in Hungary before December 31, 2020, into the National Permanent Residence Permit category.
Applications require a prescheduled in-person appointment to submit biometric data.
No government fees apply.
UK national cross-border or posted workers who habitually stayed in Hungary before December 31, 2020, demonstrated by a Hungarian employment contract or statement on income from regular work activity in Hungary, may qualify for a National Permanent Residence Permit.
UK national cross-border or posted workers without habitual stay in Hungary require work and residence authorization as other non-EU nationals to continue their activities after January 1, 2021.
Unlike in the rest of the EU, Brexit has no impact on UK nationals seeking to travel, reside, or work in Ireland after January 1, 2021. UK nationals will continue to benefit from favourable treatment under the Common Travel Area agreement. There will be an impact, however, for UK nationals' family members if they themselves are not nationals of European Economic Area (EEA) member states.
Any non-EEA national who (1) currently resides in Ireland with a UK national family member and (2) holds a valid EUFAM residence card will retain their residence and work rights after January 1, 2021. However, they must exchange their current EUFAM residence card for a new one that states their residence rights derive from the Withdrawal Agreement by applying online, regardless of county or city of residence. The application deadline is December 31, 2021.
Non-EEA family members of UK nationals not yet resident in Ireland require pre-clearance. Details on the pre-clearance scheme are published on this site. Processing times are up to six months.
Applications must be filed by June 30, 2021.
Applications are filed by post. Applicants are invited to submit biometric data and can collect their Article 50 permit approximately a week later.
Applicants demonstrate residence before December 31, 2020 by submitting proof of their EU residence registration. No other proof of residence before December 31, 2020 is accepted.
No government fees apply.
Until the new permit is issued, individuals can demonstrate their status by their EU registration certificate or family member permit.
UK nationals with at least five years’ residence as of December 31, 2020 may apply for a permanent Article 50 residence permit. UK nationals with less than five years’ residence will receive a five-year temporary Article 50 permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for an Article 50 (dependent) permit until June 30, 2021.
Cross-border workers with an established status before December 31, 2020 apply for a 10-year cross-border worker permit. Applicants must be employed in Luxembourg, or have regular employment in Luxembourg (listed on their EU-based employment contract) to be eligible. Applications are free of charge and require proof of residence in the European Union or United Kingdom and a recent social security certificate, among limited other documents. Applicants submit biometric data during the application process. Non-EU national family members of UK national cross-border workers are no longer work permit exempt after January 1, 2021.
UK nationals on a foreign employment contract, posted to Luxembourg under free movement of services, require work authorization as other EU nationals to continue their assignment after January 1, 2021. Luxembourg did not establish a specific exemption for posted workers who did not establish residence in 2020; and who are not eligible cross-border workers. These individuals require work authorization unless work permit exempt under a general exemption for non-EU nationals (e.g., eligible 90-day intracompany secondments, Vander Elst service providers).
Applications must be filed before June 30, 2021. UK national residents receive invitation letters to apply. Individuals arriving before December 31, 2020 can apply after three months’ residence in Malta, until June 30, 2021. Applications are filed at a pre-scheduled in-person appointment.
Until the new permit is issued, individuals can demonstrate their status by their EU residence registration or family member permit.
No government fees apply to the change of status. This is subject to change.
UK national residents and their family members will receive a 10-year permit, regardless of their duration of prior residence.
Non-EU family members of UK nationals holding a corresponding residence permit, and those who fall under the provisions of the Withdrawal Agreement may similarly apply for a national residence permit until June 30, 2021. However, family members (other than children) will only be covered by these provisions if their relationship commenced before December 31, 2020.
UK nationals who commute to Malta must file a Posted Worker Notification every time they travel to Malta. The situation after January 1, 2021 remains uncertain.
The following documents can be submitted to demonstrate residence before December 31, 2020:
Applications can be filed online until June 30, 2021.
Applicants demonstrate residence before December 31, 2020 by submitting their Citizen Service Number (BSN).
Government fees are EUR 58, or EUR 31 for children.
Until the new permit is issued, individuals can demonstrate their status by their EU registration certificate or family member permit, combined with proof of filing their Article 50 permit once available.
UK nationals with at least five years’ residence as of December 31, 2020 may apply for a permanent residence permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until June 30, 2021.
Cross-border workers with an established status before December 31, 2020, holding a local employment contract and a Dutch registration number (BSN), are required to apply for a ‘Frontier worker document’ as soon as possible. Individuals on foreign employment contract may still be eligible for a 'Frontier worker document' if they can demonstrate that they are not working in the Netherlands temporarily as a (seconded) posted worker, but that their activities are more durable. Other cross-border workers require a work permit. Frontier worker document holders must limit their activities to 90 days in a 180-day period under Schengen-wide limitations on allowable stay for non-EU nationals.
Applications must be filed before December 31, 2021. UK nationals may face travel restrictions without an Article 50 permit or proof of filing, depending on Border Guard practice. Fragomen will report relevant updates.
Applications are filed in person at local voivodeship offices. Applicants over six years old apply in person and submit fingerprints.
Applicants demonstrate residence before December 31, 2020 by submitting their EU residence registration or family member permit. Applicants who do not yet hold such a document can instead provide confirmation of their submission of the EU residence registration application or address registration by city hall, a signed labor contract, payment of social security or submission of a Posted Worker Notification.
No government fees apply.
Until the new permit is issued, individuals can demonstrate their status by submitting proof of their EU registration or family member residence card and proof of the Article 50 application filing, once available. Proof of filing will be valid for one year and is renewable once, if needed.
UK nationals with at least five years’ residence, either before or after the end of the transition period, will receive permanent residence permits. UK nationals with less than five years’ residence will receive an Article 50 residence permit. Current Permanent Residence Permit holders are not required to apply for a new permit document but may replace their existing Permanent Residence Card with Residence Card with Annotation “Withdrawal Agreement”.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until December 31, 2021.
UK cross-border workers who worked in Poland before December 31, 2020 can apply for a Frontier Permit. These individuals do not require a Polish employment contract to continue working after December 31, 2020. Those with an employment contract from a foreign company that has a Polish work address qualify for a Frontier Permit. Those with an assignment letter from a foreign entity which lists a Polish work address qualify as posted workers but not for the Frontier Worker permit and will have to apply for the special residence for posted workers in Poland. Since the legislation is not clear on such working arrangements, this is subject to change.
Applications are open. UK nationals and their family members who reside in Romania and wish to remain in Romania after the end of the transition period should register for the new residence status as beneficiaries of the Withdrawal Agreement by December 31, 2021.
UK nationals and their family members with a Withdrawal Agreement Residence permit can enter Romania without a visa based on a valid travel document and their residence permit during the validity period of their respective permit. Until they obtain their Article 50 residence permit, they can enter Romania without a visa or other formalities, based on valid documents issued by Romanian authorities.
UK nationals not entitled to rights under the Withdrawal Agreement can enter Romania without a visa and can stay for up to 90 days in a 180-day period. Those who enter for work must obtain Romanian work authorization.
Residence documents issued by the General Inspectorate for Immigration in Romania will be recognized until December 31, 2021.
Government fees are not yet confirmed.
It is not yet known if there is a more favorable status for individuals with residence over 5 years.
It is not yet known if there are there any provisions for cross-border workers.
Applications for Third-Country National Residence Cards must be filed before June 30, 2021. UK nationals living in Slovakia can already file their application for the non-EU type Residence Permit and must do so by June 30, 2021.
Until the new permit is issued, individuals can demonstrate their status with their EU Residence Registration or their family member permit.
Non-EU family members of UK nationals who arrive in Slovakia and started their residency before 2021 who hold a corresponding residence permit may similarly apply for a national residence permit until June 30, 2021. Those whose relationship existed before December 31, 2020 can apply for residence status in Slovakia at any time.
In-person application submission is required (biometric data is scanned since new Residence Cards are issued). Applicants can schedule an appointment online.
Documents that are accepted to demonstrate residence before December 31, 2020 include EU registration documents. It is not clear whether lease agreement/utility bills will be accepted.
The fee for a new Residence Card for UK nationals who are only changing their status is EUR 4.50 (or EUR 24.50 for expedited issuance).
UK nationals living in Slovakia for five years or longer will receive a Long-Term Residence Permit, which is granted for an unlimited period. The Residence Card is valid for 10 years.
Cross-border workers should register their residence and obtain their respective Residence Card (with a permanent residence status). Non-EU cross-border workers with permanent residence status do not require any additional work authorization.
Employers of UK nationals must notify the Labour Office by January 13, 2021 of UK nationals starting employment before December 31, 2020 if not yet completed. As a reminder, employers must store a copy of UK nationals’ Article 50 residence permits in their personnel files once available.
Applications must be filed before December 31, 2021, or before the expiry date of the current residence documents, whichever occurs sooner. Individuals without an EU residence registration certificate must apply for an Article 50 permit within 90 days of entry.
Applications are filed in person with an Administrative Unit (Upravne Enote) to submit biometric data, with another in-person visit to collect the permit.
Applicants demonstrate residence before December 31, 2020 by submitting proof of their EU residence registration.
Government fees are EUR 17 for a five-year temporary permit or EUR 22 for a permanent residence permit.
Until the new permit is issued, individuals can demonstrate their status by their EU residence registration or family member permit, plus the Article 50 certificate of application once available.
UK nationals with at least five years’ uninterrupted residence as of December 31, 2020 may be eligible for permanent residence, which is valid indefinitely if granted. Other applicants will receive a five-year Article 50 permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit until December 31, 2021 or the expiry date of their current permit, whichever is sooner.
Cross-border workers on a Slovenian employment contract with an established status before December 31, 2020 would be able to continue similar activities. Individuals are advised to contact the Administrative Unit to confirm the applicable process.
No specific exemptions are implemented for posted workers or other non-resident workers on foreign employment contracts. These individuals are required to obtain work authorization starting January 1, 2021.
UK nationals residing in Spain before December 31, 2020 are advised to apply within 90 days of arrival, or promptly if residing in Spain before September 2020. No fixed Article 50 application deadline has been confirmed yet.
Current registered residents apply at the police station in person to exchange their EU certificate of registration for a residence card (TIE). Individuals without a residence document apply at the Immigration Office online or in person to check compliance with Withdrawal Agreement conditions. Upon receiving preliminary approval, these individuals request a residence card (TIE) in person at the police station. Applicants do not require an invitation to apply.
Applicants demonstrate residence before December 31, 2020 by an EU certificate of registration. Individuals who established residency after July 6, 2020, can submit e.g., Town Hall registration certificate, utility bills, bank statements from a Spanish bank, children's local school attendance certificate, among other accepted documents.
Government fees are EUR 12.
Until the new permit is issued, individuals can demonstrate their status by their current residence document, or by proof of application filing.
UK nationals with at least five years' residence as of December 31, 2020 will receive a 10-year residence permit card.
Non-EU family members of UK nationals holding a corresponding residence permit apply for a national residence permit before expiry of their current permit.
UK nationals posted in Spain before December 31, 2020 can keep providing their services in Spain during the validity of their status. They will have to apply for a residence document/card and maintain their social security coverage, among other labor requirements, during their posting.
Applications should be filed before September 30, 2021.
Applications require a prescheduled in-person appointment to submit biometric data.
Applicants demonstrate residence before December 31, 2020 by submitting their employment contract. Applicants must demonstrate their residential address for local/tax registration (applicants visit the tax office for this step).
No government fees apply.
Until the new permit is issued, individuals can demonstrate their status by proof of EU registration or a family member permit.
Non-EU family members of UK nationals holding a corresponding residence permit may similarly apply for a national residence permit, however the deadline has not yet been confirmed by the Swedish Migration agency.
There are currently no special provisions for cross-border workers.
UK nationals seeking to continue working and residing in their current EU country of residence, and UK national cross-border workers (also called commuters or frontier workers), should apply for immigration status promptly.
The UK government is publishing detailed Brexit related information and offering resources to UK nationals living in the European Union on their official website available here.
The EU-wide Brexit transition period ended on December 31, 2020. UK nationals residing or working in EU Member States by December 31, 2020 now require a new proof of status, based on Article 50 of the Withdrawal Agreement. UK nationals seeking to start work in EU Member States after January 1, 2021 require work authorization unless exempt.
Fragomen will provide updates on the situation as they become available.
Please contact a Fragomen immigration professional for assistance in planning contingency arrangements in a single project.
For more information, please visit Fragomen's dedicated Brexit site, which contains news, FAQs, and analysis/commentary in the form of blogs, videos, webcasts and events.
This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].