• Insights

Beyond Brexit: Social Security Implications

February 14, 2020

Brexit

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Harry Goldstraw

Upon the UK and EU’s ratification of the Withdrawal Agreement (WA), the UK left the EU with a Deal on 31 January 2020.

The WA introduced a transition period, confirming that there will be no practical changes to the UK and EU’s relationship until 31 December 2020.

But what does WA mean, from a social security perspective, for cross-border workers moving between the UK and the EU?

During the transition period

For the next 11 months, the coordination of social security continues to operate in the same way for workers who find themselves in a cross-border situation between the UK and one or more EU Member States. 

An employee currently on a temporary assignment from the UK to an EU Member State, which began before Brexit, can continue to rely on their existing A1 Certificate to maintain home country social security coverage in the UK.

Additionally, employees who travel for business from the EU to the UK between 1 February 2020 and 31 December 2020, will be able to apply for an A1 Certificate in their EU home country. They will also be able to apply for an extension of their A1 Certificate for up to 24 months from its start date.

Less certain are scenarios where a UK employee has to extend beyond this 24-month period and the extension request requires the agreement of the EU host country where the employee is working. Each EU Member State may take a different approach in this situation.

For an individual starting cross-border work before 31 December 2020, the aggregation of insurance, work or residence periods also continue to operate in its current form. This allows the individual with a cross-border working record to obtain entitlement to cash benefits in their country of residence (either the UK or the EU).

After the transition period

After 31 December 2020, a distinction will have to be made between “new” cross-border situations and “existing” situations.

It will depend on the negotiations during the next 11 months, whether “new” cross-border moves, starting from 1 January 2021, will be ruled by new social security rules between the UK and the EU.

If new social security rules between the UK and the EU as a whole cannot be concluded by 31 December 2020, the impact on cross-border workers will be same as a “No Deal” Brexit scenario.

Alternatively, we could be in a scenario where some individual EU Member States have negotiated separate social security rules with the UK, while others have not. This could give rise to very complex situations for business travellers and multi-state workers with compliance requirements differing from country to country, and a high risk of double contribution costs.

The WA offers some form of protection for “existing” cross-border workers. It states that individuals in existing cross-border scenarios by the end of the transition period shall remain covered by current EU social security rules; as long as their cross-border work situation continues “without interruption.” However, this is not a fully defined term, and so it will have to be seen how the UK and EU Member States will interpret this transition rule.

For example, it’s possible that some Member States will accept that a cross-border worker, who started work before 31 December 2020 and who will continue to work cross-borders beyond this period of time, could even change employers or countries in which they work and still be considered to be working cross-borders “without interruption,” They would then be eligible to apply for an A1 Certificate under the current EU social security rules.

Further clarification on the interpretation of cross-border work “without interruption” is expected from the competent authorities in the coming months. 

With respect to the totalization of insurance, work or residence periods, it is confirmed that periods completed both before and after the end of the transition period shall be considered.

Way forward for the business

Although the transition period under the WA seems to offer companies some extra time to relax, it is important that employers start thinking about effective strategies for post-Brexit management of social security compliance, until 31 December 2020 and beyond. This includes budgeting for potentially higher contribution costs and devising strategies to deal with differing social security rules across the EU Member States.

Fragomen can assist with your preparation by partnering with you to monitor the approach taken by social security authorities and outlining the impact on your business. Our government strategies approach means we can help you through the Brexit transition period both from an immigration and a social security perspective. We can review your current social security compliance processes and help plan how your employees can still benefit from EU social security rules once the transition period ends.

For more information on the above-discussed topic, please contact Wim Cocquyt or Harry Goldstraw or visit our microsite for timely updates.

 

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Brussels
  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Fragomen news

Fragomen Appoints Timo Heck as Managing Partner of DACH Region

Fragomen has appointed Timo Heck as Managing Partner of the DACH region, encompassing Germany, Austria and Switzerland.

Learn more

Awards

Fragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™

Eight professionals in Fragomen’s Mexico City office have been recognized in the 2027 edition of The Best Lawyers in Mexico™ for Immigration Law.

Learn more

Blog post

How Employers Can Support Integration and Retain International Talent in Germany

Senior Manager Katharina Vorländer explores how employers in Germany can look beyond the initial immigration process to support integration, long-term stability and the retention of international talent.

Learn more

Media mentions

Scottish Legal News: Scotland’s Investment Ambitions Depend on Workforce Readiness

Director Kelly Hardman explores why workforce planning is essential to Scotland’s investment ambitions and long-term economic growth.

Learn more

Fragomen news

Comment on DHS Proposal to Eliminate the 60-day Grace PeriodLearn more

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Media mentions

Prawo: Pracodawca na pierwszej linii: jak reforma zatrudniania cudzoziemców przesuwa odpowiedzialność na firmy

Partner Karolina Schiffter examines how Poland’s proposed foreign employment reforms could increase employers’ administrative and compliance responsibilities.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more

Fragomen news

Fragomen Appoints Timo Heck as Managing Partner of DACH Region

Fragomen has appointed Timo Heck as Managing Partner of the DACH region, encompassing Germany, Austria and Switzerland.

Learn more

Awards

Fragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™

Eight professionals in Fragomen’s Mexico City office have been recognized in the 2027 edition of The Best Lawyers in Mexico™ for Immigration Law.

Learn more

Blog post

How Employers Can Support Integration and Retain International Talent in Germany

Senior Manager Katharina Vorländer explores how employers in Germany can look beyond the initial immigration process to support integration, long-term stability and the retention of international talent.

Learn more

Media mentions

Scottish Legal News: Scotland’s Investment Ambitions Depend on Workforce Readiness

Director Kelly Hardman explores why workforce planning is essential to Scotland’s investment ambitions and long-term economic growth.

Learn more

Fragomen news

Comment on DHS Proposal to Eliminate the 60-day Grace PeriodLearn more

Fragomen news

Comment on DHS proposal to impose up to $100,000 in Optional Practical Training FeesLearn more

Media mentions

Human Resources Director: Fixed-Term Contract Limits Squeeze Visa Sponsorship, Research Warns

Co-authors Partner Charles Johanes, Senior Counsel Anna Boucher and Allens Partner Tarsha Gavin explore the intersection of Australia’s migration and employment laws and the implications for employers sponsoring temporary visa holders.

Learn more

Media mentions

Prawo: Pracodawca na pierwszej linii: jak reforma zatrudniania cudzoziemców przesuwa odpowiedzialność na firmy

Partner Karolina Schiffter examines how Poland’s proposed foreign employment reforms could increase employers’ administrative and compliance responsibilities.

Learn more

Blog post

Trusted Digital Identity Is Critical Infrastructure for Global Mobility

In the first blog in a new series, Managing Director, Digital Identity Amit Sharma explores why trusted digital identity is becoming increasingly important to global mobility, how reusable digital credentials could work and why interoperability across systems and jurisdictions will be critical.

Learn more

Blog post

UK Global Talent Visa vs Innovator Founder Visa: A Guide for Tech Professionals, Researchers and Founders

Senior Associate Amelia Haynes compares the UK’s Global Talent and Innovator Founder visa routes, examining who each route may suit, the evidence required, professional flexibility and potential pathways to settlement.

Learn more

Blog post

Polish Citizenship by Descent: Finding Family Records and Navigating Polish Archives

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek explain how applicants pursuing Polish citizenship by descent can locate family records, navigate archives and obtain documentary evidence that can be used in citizenship proceedings.

Learn more
Generic Insights

Fragomen news

2026年10月 米国移民法ダイジェストLearn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
November 12, 2026 | Austria, Germany, SwitzerlandFragomen Appoints Timo Heck as Managing Partner of DACH Region
November 12, 2026 | MexicoFragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™
November 12, 2026 | IndiaIndia: Simplification of Visa Categories and Reduction in Application Information Requirements
November 12, 2026 | IrelandIreland: New Seasonal Employment Permit Program Launched for Horticultural Sector Workers
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
November 12, 2026 | Austria, Germany, SwitzerlandFragomen Appoints Timo Heck as Managing Partner of DACH Region
November 12, 2026 | MexicoFragomen Professionals Recognized in the 2027 Edition of The Best Lawyers in Mexico™
November 12, 2026 | IndiaIndia: Simplification of Visa Categories and Reduction in Application Information Requirements
November 12, 2026 | IrelandIreland: New Seasonal Employment Permit Program Launched for Horticultural Sector Workers
November 12, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.