• Insights

No Deal Brexit: Social Security Cost Implications

June 6, 2019

Countries / Territories

  • 🌐

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Siobhan Owers, George Koureas

As a ‘No Deal’ Brexit remains a distinct possibility, companies need to understand the potential implications, especially with regard to short and long term mobility of their employees. An area of major significance which is often not sufficiently headlined is the significant impact a hard Brexit may have on the salary cost and the social security cost of the employees travelling to and from the UK, for both employer and the individual.

In principle, a worker is subject to social security contributions in the country in which they work. An important exception to this is in the case of a ‘posting’, i.e. when a worker carries out duties on a temporary basis in another country, in the interest of his/her employer, and when the worker is not replacing another ‘posted’ worker to the same entity. In such a case, a worker could maintain social security coverage in their Home country for a limited period of time, without becoming liable for additional social security costs in their Host country.

These exceptions are laid down in international social security agreements, such as the EU Regulations on the coordination of social security systems, which currently apply to all EU and EEA member states (including the UK) and Switzerland. As of Brexit day, in case of ‘No Deal’, the EU Regulations, allowing the ‘posting’ exception, would cease to apply to the UK. Therefore, the risk of an employee going between the UK and the EU becoming liable to social security in both the EU and the UK is very real.

 ‘Old’ Bilateral Social Security Agreements

In principle, one solution to the social security challenges post ‘No Deal’ Brexit could be reviving the existing ‘old’ social security agreements that the UK concluded with a number of  EU  member states in the past. The legal validity of their revival is a legal question, which is still being debated in many countries. However, even if such agreements were deemed still valid, consideration must be given as to whether they can be easily adapted to reflect the dynamics and characteristics of the modern day mobile workforce.

Domestic Social Security Legislation

In the absence of any ‘old’ bilateral social security agreements, and unless new ones are made, the UK will be treated as a non-EU country from a social security perspective by the EU member states. This means that the social security implications in a cross border work situation would need to be addressed by looking at both the domestic legislation of the sending country as well as the domestic legislation of the receiving country.

For example, a UK worker ‘posted’ to  France for a temporary period of time could become liable to French high-cost social security contributions, in addition to having continuing liability in the UK. Moreover, depending on the individual circumstances of the actual cross-border employment set-up, the posted worker may also not reach minimum social contributions to qualify for future pension benefits in the UK or France. In most jurisdictions, the social security contributions paid into the system during a period of work cannot be refunded at the moment of departure from the country at the end of the posting period.

Next Steps

With informed advance planning, companies can put strategies in place to avoid a ‘No Deal’ or hard Brexit becoming an overwhelming experience. A solid strategy can also help to manage the impact and expectations of their workers in relation to social security and protect salaries (and salary costs) from being impacted by a change in social security costs.

To minimize the significant cost impact of a ‘No Deal’ or hard Brexit on the social security cost of a mobile workforce, and the potential need to compensate for the loss of social security entitlements (e.g. pension rights, protection of access to medical care), companies need to assess the implications, plan in advance and inform internal stakeholders appropriately:

  • Assess: Conduct an in-depth internal analysis of the posting status quo to understand potential negative social security implications such as double liability costs could be mitigated by adjusting the contractual arrangements and assignment structures.
  • Plan: Prepare hypothetical cost projections reflecting the most frequently occurring cross-border traveller profiles and patterns.
  • Inform: Continuous communication with internal stakeholders, line managers, HR, global mobility, finance, and frequent business travellers is critical in creating awareness around the impact of Brexit on social security and to budget for increased costs, stricter compliance and increased reporting.
Fragomen can help your company through the integration of our contingency ‘No Deal’ Brexit planning initiatives in the area of both Immigration and Social Security. 
 
For more information, please reach out to us at [email protected].
 

 

 

Countries / Territories

  • 🌐

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Paris
  • Fragomen in Sheffield, United Kingdom

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Article

EU Inc. Signals a Shift: Why Immigration Will Matter to Europe’s New Corporate Agenda 

Knowledge Management Director Ana Sofia Walsh and Senior Client Engagement Manager Soraya Driessen examine the European Commission’s EU Inc. proposal and its potential to reshape corporate structures across the EU, highlighting the resulting complexities and unresolved questions for immigration, work authorization and cross-border workforce mobility.

Learn more

Media mentions

The National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages

Partner Ali Haider discussed how flexible residency pathways, strong infrastructure and access to healthcare are continuing to drive interest among retirees looking to relocate to the UAE.

Learn more

Fragomen on immigration

Business Immigration After the Midterms (Part 1): What to Expect No Matter What

Partner K. Edward Raleigh analyzes how post‑midterm US business immigration will shift toward heightened enforcement, worker‑protection scrutiny and cross‑agency oversight, urging employers to align hiring practices, sponsorship decisions and documentation with consistent, defensible workforce strategies.

Learn more

Media mentions

Business Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.

Counsel Brian Hunt said employers quickly sought clarity after a USCIS memo on green card adjustment of status raised questions about immigration timelines, work continuity and travel planning.

Learn more

Awards

Fragomen named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia

Fragomen is named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia and receives National and Regional Tier 1 rankings in Immigration Law.

Learn more

Media mentions

USA Today: USCIS Green Card Announcement Spurs Confusion. What to Know

Partner Parisa Karaahmet discusses the broad application of a USCIS memo to adjustment of status applicants and notes that H- and L-visa holders may have a somewhat easier burden in demonstrating factors that support favorable discretion.

Learn more

Article

Commonwealth Games 2026 Travel Planning: UK ETA Rules for Teams and Fans

Senior Manager Alice Spaull and Associate Stephanie Fitton examine the evolving UK immigration and Electronic Travel Authorisation (ETA) requirements for athletes, their support teams and associated guests attending the Commonwealth Games 2026, highlighting key compliance risks and the importance of early travel planning.

Learn more

Media mentions

The Associated Press: Trump’s Latest Immigration Move Clouds the Path to Green Cards

Partner Kevin Miner discusses the expected impact of new USCIS green card guidance on employment-based immigration, noting dual-intent visa cases would likely continue under business as usual with no significant impact.

Learn more

Media mentions

The Wall Street Journal: What to Know About the Trump Administration’s New Green Card Policy

Partner K. Edward Raleigh discusses a recent USCIS memo that appears to signal greater caution in how adjudicators assess adjustment of status cases rather than establishing a new legal standard.

Learn more

Fragomen news

2026年5月 アメリカ移民法ダイジェストLearn more

Video

Germany Health Insurance Requirements for Visas: What You Need to Know

Senior Manager Sumejja Handzo outlines Germany’s health insurance requirements for visas and residence permits, including coverage options, documentation considerations and key compliance requirements for foreign nationals relocating to Germany.

Learn more

Media mentions

ABA Journal: Will US Immigration Policies Create ‘Chilling Effect’ on World Cup?

Partner Daniel Schwarz highlights how US visa appointment backlogs and limited availability for B visas are shaping international travel planning for the upcoming World Cup.

Learn more

Article

EU Inc. Signals a Shift: Why Immigration Will Matter to Europe’s New Corporate Agenda 

Knowledge Management Director Ana Sofia Walsh and Senior Client Engagement Manager Soraya Driessen examine the European Commission’s EU Inc. proposal and its potential to reshape corporate structures across the EU, highlighting the resulting complexities and unresolved questions for immigration, work authorization and cross-border workforce mobility.

Learn more

Media mentions

The National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages

Partner Ali Haider discussed how flexible residency pathways, strong infrastructure and access to healthcare are continuing to drive interest among retirees looking to relocate to the UAE.

Learn more

Fragomen on immigration

Business Immigration After the Midterms (Part 1): What to Expect No Matter What

Partner K. Edward Raleigh analyzes how post‑midterm US business immigration will shift toward heightened enforcement, worker‑protection scrutiny and cross‑agency oversight, urging employers to align hiring practices, sponsorship decisions and documentation with consistent, defensible workforce strategies.

Learn more

Media mentions

Business Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.

Counsel Brian Hunt said employers quickly sought clarity after a USCIS memo on green card adjustment of status raised questions about immigration timelines, work continuity and travel planning.

Learn more

Awards

Fragomen named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia

Fragomen is named “Law Firm of the Year” for Immigration Law by Best Law Firms™ - Australia and receives National and Regional Tier 1 rankings in Immigration Law.

Learn more

Media mentions

USA Today: USCIS Green Card Announcement Spurs Confusion. What to Know

Partner Parisa Karaahmet discusses the broad application of a USCIS memo to adjustment of status applicants and notes that H- and L-visa holders may have a somewhat easier burden in demonstrating factors that support favorable discretion.

Learn more

Article

Commonwealth Games 2026 Travel Planning: UK ETA Rules for Teams and Fans

Senior Manager Alice Spaull and Associate Stephanie Fitton examine the evolving UK immigration and Electronic Travel Authorisation (ETA) requirements for athletes, their support teams and associated guests attending the Commonwealth Games 2026, highlighting key compliance risks and the importance of early travel planning.

Learn more

Media mentions

The Associated Press: Trump’s Latest Immigration Move Clouds the Path to Green Cards

Partner Kevin Miner discusses the expected impact of new USCIS green card guidance on employment-based immigration, noting dual-intent visa cases would likely continue under business as usual with no significant impact.

Learn more

Media mentions

The Wall Street Journal: What to Know About the Trump Administration’s New Green Card Policy

Partner K. Edward Raleigh discusses a recent USCIS memo that appears to signal greater caution in how adjudicators assess adjustment of status cases rather than establishing a new legal standard.

Learn more

Fragomen news

2026年5月 アメリカ移民法ダイジェストLearn more

Video

Germany Health Insurance Requirements for Visas: What You Need to Know

Senior Manager Sumejja Handzo outlines Germany’s health insurance requirements for visas and residence permits, including coverage options, documentation considerations and key compliance requirements for foreign nationals relocating to Germany.

Learn more

Media mentions

ABA Journal: Will US Immigration Policies Create ‘Chilling Effect’ on World Cup?

Partner Daniel Schwarz highlights how US visa appointment backlogs and limited availability for B visas are shaping international travel planning for the upcoming World Cup.

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 InsightsVietnamese ImmigrationView 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
  • Vietnamese Immigration
  • 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
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
May 29, 2026 | BermudaBermuda: New Work Permit Policy to Prolong Processing Times
May 29, 2026 | FranceFrance: EU Blue Card Rules Relaxed
May 29, 2026 | IrelandIreland: Occupation Lists Changes Published,“50:50” Rule Modification Proposed
May 29, 2026 | United Arab EmiratesThe National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
May 29, 2026 | BermudaBermuda: New Work Permit Policy to Prolong Processing Times
May 29, 2026 | FranceFrance: EU Blue Card Rules Relaxed
May 29, 2026 | IrelandIreland: Occupation Lists Changes Published,“50:50” Rule Modification Proposed
May 29, 2026 | United Arab EmiratesThe National: Companionship Scheme Addresses Loneliness Among Elderly as UAE Population Ages
May 28, 2026 | United StatesBusiness Insider: Trump’s Green Card Memo Dropped Before a Holiday Weekend. Immigration Lawyers Say Clients Panicked.
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.