
Country / Territory
Related contacts
Related content
Related contacts
Related content
Related contacts
Related content
By: Siobhan Owers, Iskra Nikolic Uskokovic
A ‘No Deal’ Brexit scenario would have significant and far-reaching consequences for the social security entitlement of EU citizens who have worked or lived in the UK, and British citizens who have worked or lived in another EU member state.
On 4 February 2019, the UK Government agreed on a deal to protect social security rights of UK and Irish citizens living and working in each other’s state.
Key Points
One of the major principles of the Social Security coordination rules set out in EU Regulation 883/2004, is to ensure people receive the full benefit of contributions they have made.
If Brexit ends in ‘No Deal’, EU workers in the UK and British workers in an EU member state could lose their existing Social Security protections under the current reciprocal agreements, essentially becoming third country nationals overnight not eligible to benefit from free movement.
In a continued bid to honour the rights associated with the Common Travel Area, which pre-dates Irish and UK membership of the EU, the UK government has announced an agreement on social security with Ireland, guaranteeing continued access to State Pension and benefits for UK and Irish citizens and their qualifying family members when in the other’s state.
The agreement ensures that the rights of UK and Irish citizens living and working in each other’s state are protected after the UK leaves the EU. The aim of the agreement is to eliminating double social security taxation and ensure that workers pay into one social security scheme at a time.
It will also help by filling the gaps in benefit protection for workers who have divided careers between the UK and Ireland and that social security contributions paid by UK and Irish citizens can be used to meet entitlement criteria for accessing benefits in each other’s state.
A provision of the agreement will also allow workers who are making social security contributions under each country’s regime, to export certain benefits between the UK and Ireland.
Outcome
Following Brexit, with this agreement the UK and Irish citizens will have access to each country ’s state benefits, providing for aggregation of the contributions required for entitlement of the benefits and being able to export these in the UK and Ireland.
For any social security related questions, please contact us: [email protected] or Siobhan Owers at [email protected] or Iskra Nikolic Uskokovic at [email protected]
Country / Territory
Related contacts
Related content
Related contacts
Related content
Related contacts
Related content
Explore more at Fragomen
Blog post
Counsel Susan Steger examines how wage-driven selection mechanisms in programs such as the H-1B lottery and PERM can create incentives for artificial wage inflation and introduce new compliance and workforce planning challenges for employers.
Media mentions
Director Gemma Hyslop examines how collaboration across the global mobility sector can help strengthen legal pathways and support for migrant women experiencing abuse.
Media mentions
Partner Abeer Al Husseini discussed immigration and duty-of-care challenges for employers amid Middle East travel disruptions.
Awards
Partner Sarah K. Peterson is recognized by the Minneapolis/St. Paul Business Journal as a 2026 Women in Business honoree for her professional achievements and contributions to the Twin Cities business community.
Media mentions
Immigration Manager Alice Heron explains how HR teams can navigate Irish immigration law and manage international talent effectively.
Media mentions
Associate Ilaria Iovieno and Immigration Consultant Devina Sanghera outline what the proposed expansion of the UK Right to Work Scheme means for housebuilders.
Awards
Partner Cynthia Shearn is recognized by Crain’s Chicago Business in its 2026 Notable Women in Law list, honoring her leadership in immigration and global mobility and her impact within the legal community.
Media mentions
Partner Emily Allen says the new H-1B lottery is driving earlier planning and more detailed preparation.
Blog post
Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.
Media mentions
Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
Fragomen news
The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.
Blog post
Counsel Susan Steger examines how wage-driven selection mechanisms in programs such as the H-1B lottery and PERM can create incentives for artificial wage inflation and introduce new compliance and workforce planning challenges for employers.
Media mentions
Director Gemma Hyslop examines how collaboration across the global mobility sector can help strengthen legal pathways and support for migrant women experiencing abuse.
Media mentions
Partner Abeer Al Husseini discussed immigration and duty-of-care challenges for employers amid Middle East travel disruptions.
Awards
Partner Sarah K. Peterson is recognized by the Minneapolis/St. Paul Business Journal as a 2026 Women in Business honoree for her professional achievements and contributions to the Twin Cities business community.
Media mentions
Immigration Manager Alice Heron explains how HR teams can navigate Irish immigration law and manage international talent effectively.
Media mentions
Associate Ilaria Iovieno and Immigration Consultant Devina Sanghera outline what the proposed expansion of the UK Right to Work Scheme means for housebuilders.
Awards
Partner Cynthia Shearn is recognized by Crain’s Chicago Business in its 2026 Notable Women in Law list, honoring her leadership in immigration and global mobility and her impact within the legal community.
Media mentions
Partner Emily Allen says the new H-1B lottery is driving earlier planning and more detailed preparation.
Blog post
Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.
Media mentions
Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
Fragomen news
The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.

