Guidance for UK Residents in the European Union Under Article 50 Residence Permits

Applications must be filed before December 31, 2021, or by the current EU Residence Certificate expiry date; whichever is sooner.  

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. No government fees apply. 

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.  

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. 

Posted workers can continue their posting throughout 2021 without additional process steps. These individuals should carry an assignment letter confirming their travel purpose and a start date before December 31, 2020. Posted workers whose posting will continue after 2021 are eligible for and must apply for an Article 50 permit. These individuals should submit proof of work in Denmark before December 31, 2020; proof of their UK address; and an assignment letter listing an assignment end date. Employers must file posted worker notifications for all non-exempt workers.

Further information is available on this site.

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 require work authorization.

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. Fragomen recommends posted and cross-border workers to obtain work authorization unless exempt. 

DEADLINE PASSED – individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

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. 

DEADLINE PASSED – individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

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.

DEADLINE PASSED – individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

UK nationals who missed this application deadline are advised to apply promptly. They can still obtain an Article 50 permit based on clear evidence of residence and an intent to settle. 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. 

DEADLINE PASSED - individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

UK nationals and their family members, resident before December 31, 2020, obtain an ‘attestazione di iscrizione anagrafica’ via an in-person visit.

Once they have obtained the “attestazione”, UK nationals and their family members apply for a “carta di soggiorno” (valid for up to 5 years) or “carta di soggiorno permanente” (valid for up to 10 years). The document will be issued in an electronic format.

Applications are filed at the local Questura (Police Headquarters / Immigration Police) via an in-person visit. Applicants submit the “attestazione”, among other documents, and fingerprints for the residence permit card. Successful applicants visit the Questura once again to collect the permit once available. 

Government fees are EUR 30.46 per application. 

Employed or self-employed frontier workers (as defined under the EU-UK trade and cooperation agreement) may request a five-year electronic document certifying their status. Applications are filed at the Questura of the province of work, and require proof of eligible (self-)employed activity in Italy before December 31, 2020. 

UK national students holding an electronic residence permit, issued by the Questura of the province of residence, may continue to renew their permit until the end of the course of study.

UK nationals arriving and starting work after January 1, 2021 require work authorization as other non-EU nationals.

Applications must be filed by December 31, 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 December 31, 2021.  

Cross-border workers with an established status before December 31, 2020 apply for a 10-year cross-border worker permit. These permits are currently being issued. 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).

DEADLINE PASSED – individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

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: 

• boarding pass/es; 
• bank statements showing local transactions; 
• record of employment/self employment (as applicable) 
• proof of rental of property; and 
• any such document which Identity Malta Agency deems to be proof of date of settlement in Malta. 

Applications can be filed online until October 1, 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 October 1, 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.

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 national posted workers, active in Poland before January 1, 2021, may be eligible for a posted worker permit. Applicants must hold an assignment letter from a foreign entity which lists a Polish work address to be eligible. The posted worker permit is a five-year Residence Permit allowing UK national posted workers and their accompanying family members to continue to work and stay in Poland through 2021. The permit contributes towards permanent residency depending on duration and continuity of stay. No government fees apply to the UK national posted worker, but family members are subject to a PLN 50 fee for the new card. 

UK national residents and their family members 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. 

DEADLINE PASSED – individuals are urged to apply promptly and/or seek counsel on leniency policies. Late applicants may not be granted status and may risk penalties.

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. 

No fixed Article 50 application deadline has been confirmed yet.  

UK nationals resident on or before December 31, 2020 apply at the police station in person to exchange their EU certificate of registration for a residence card (TIE). Applicants do not require an invitation to apply.  

Applicants demonstrate residence before December 31, 2020 by an EU certificate of registration.  

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.