• Insights

No Deal Brexit: Social Security Cost Implications

June 6, 2019

Countries / Territories

  • 🌐

Related contacts

siobhan_owers

Siobhan Owers

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

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

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

siobhan_owers

Siobhan Owers

Partner

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9132

George-Koureas

George Koureas

Managing Partner, Europe

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9227

Related offices

  • Brussels
  • Frankfurt
  • London
  • Paris
  • Sheffield

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Media mentions

Australian Broadcasting Corporation: Overnights

Senior Counsel Dr. Anna Boucher discusses Australia’s net migration figures and recent changes to the country’s migration policies.

Learn more

Blog post

Can International Graduates in the Netherlands Qualify for the 30% Ruling? Eligibility Rules Explained

Tiemen Peters, Silvia Norte Mercade and Soraya Driessen outline when international graduates who studied in the Netherlands may qualify for the 30% ruling and the key eligibility, timing and compliance considerations for graduates and employers.

Learn more

Blog post

The Narrowing Talent Pipeline: From International Student to Corporate America

Counsel Susan Steger discusses how recent immigration developments may affect the pathway from F-1 study and practical training through H-1B sponsorship and permanent residence for U.S. employers recruiting and retaining early-career international talent.

Learn more

Blog post

Right to Work Changes: What Do They Mean for Employers in Northern England?

Manager Ko Ito, Senior Immigration Consultant Danielle Barks, Associate Naureen Malik and Trainee Solicitor Amna Ali outline how the expanded UK Right to Work Scheme could affect employers in Northern England and the practical steps businesses can take ahead of the 1 October 2026 changes.

Learn more

Media mentions

Business Traveller: Six Months in, the EU’s Entry/Exit System Isn’t Working

Partner Christine Sullivan discusses the implementation of the EU’s Entry/Exit System (EES) across member states and at border crossing points.

Learn more

Blog post

Polish Citizenship by Descent: A Practical Guide for 2026

Poland Immigration Strategy Director Tomasz Rogala, Senior Associate Tomasz Rdzanek and Senior Immigration Consultant Paulina Fołta-Cisak discuss who may qualify for Polish citizenship by descent, how historical events can affect a claim and what applicants should expect from the 2026 confirmation process.

Learn more

Media mentions

ABC News: What Australia can learn from 165 years of migration data

Senior Counsel Anna Boucher is quoted in ABC News regarding Australia's migration debate and what more than 165 years of migration data reveals about long-term immigration trends.

Learn more

Blog post

Swiss Immigration Quotas 2026: Are Work Permit Quotas Likely to Run Out Before Year-End?

Senior Immigration Consultant Alessandra Rüede discusses Switzerland’s 2026 work permit quota utilisation and what current availability, canton-level allocation practices and processing considerations mean for employers planning international hiring and mobility.

Learn more

Blog post

From Investment to Merit: Malta’s Citizenship Reset

Director Isobel Neilson and Manager Sophie Jo Wasson discuss Malta’s shift from citizenship by investment to merit-based naturalisation and outline what may contribute to a compelling application based on exceptional merit and national interest.

Learn more

Fragomen news

Letter to ICE/Student and Exchange Visitor Program on Curricular Practical TrainingLearn more

Blog post

Right to Work Changes from 1 October 2026: Why Employers Need to Act Now

Partner Naomi Goldshtein discusses the UK Right to Work changes taking effect from 1 October 2026 and what employers should do now to strengthen identity verification, workforce oversight and compliance across direct and extended worker populations.

Learn more

Awards

Senior Associate Tuğba Özyakup Appointed to Dutch Bar Legislative Committee on Immigration Law

Senior Associate Tuğba Özyakup has been appointed to the Dutch Bar’s Legislative Committee on Immigration Law, where she will contribute input and advice on proposed and existing immigration legislation.

Learn more

Media mentions

Australian Broadcasting Corporation: Overnights

Senior Counsel Dr. Anna Boucher discusses Australia’s net migration figures and recent changes to the country’s migration policies.

Learn more

Blog post

Can International Graduates in the Netherlands Qualify for the 30% Ruling? Eligibility Rules Explained

Tiemen Peters, Silvia Norte Mercade and Soraya Driessen outline when international graduates who studied in the Netherlands may qualify for the 30% ruling and the key eligibility, timing and compliance considerations for graduates and employers.

Learn more

Blog post

The Narrowing Talent Pipeline: From International Student to Corporate America

Counsel Susan Steger discusses how recent immigration developments may affect the pathway from F-1 study and practical training through H-1B sponsorship and permanent residence for U.S. employers recruiting and retaining early-career international talent.

Learn more

Blog post

Right to Work Changes: What Do They Mean for Employers in Northern England?

Manager Ko Ito, Senior Immigration Consultant Danielle Barks, Associate Naureen Malik and Trainee Solicitor Amna Ali outline how the expanded UK Right to Work Scheme could affect employers in Northern England and the practical steps businesses can take ahead of the 1 October 2026 changes.

Learn more

Media mentions

Business Traveller: Six Months in, the EU’s Entry/Exit System Isn’t Working

Partner Christine Sullivan discusses the implementation of the EU’s Entry/Exit System (EES) across member states and at border crossing points.

Learn more

Blog post

Polish Citizenship by Descent: A Practical Guide for 2026

Poland Immigration Strategy Director Tomasz Rogala, Senior Associate Tomasz Rdzanek and Senior Immigration Consultant Paulina Fołta-Cisak discuss who may qualify for Polish citizenship by descent, how historical events can affect a claim and what applicants should expect from the 2026 confirmation process.

Learn more

Media mentions

ABC News: What Australia can learn from 165 years of migration data

Senior Counsel Anna Boucher is quoted in ABC News regarding Australia's migration debate and what more than 165 years of migration data reveals about long-term immigration trends.

Learn more

Blog post

Swiss Immigration Quotas 2026: Are Work Permit Quotas Likely to Run Out Before Year-End?

Senior Immigration Consultant Alessandra Rüede discusses Switzerland’s 2026 work permit quota utilisation and what current availability, canton-level allocation practices and processing considerations mean for employers planning international hiring and mobility.

Learn more

Blog post

From Investment to Merit: Malta’s Citizenship Reset

Director Isobel Neilson and Manager Sophie Jo Wasson discuss Malta’s shift from citizenship by investment to merit-based naturalisation and outline what may contribute to a compelling application based on exceptional merit and national interest.

Learn more

Fragomen news

Letter to ICE/Student and Exchange Visitor Program on Curricular Practical TrainingLearn more

Blog post

Right to Work Changes from 1 October 2026: Why Employers Need to Act Now

Partner Naomi Goldshtein discusses the UK Right to Work changes taking effect from 1 October 2026 and what employers should do now to strengthen identity verification, workforce oversight and compliance across direct and extended worker populations.

Learn more

Awards

Senior Associate Tuğba Özyakup Appointed to Dutch Bar Legislative Committee on Immigration Law

Senior Associate Tuğba Özyakup has been appointed to the Dutch Bar’s Legislative Committee on Immigration Law, where she will contribute input and advice on proposed and existing immigration legislation.

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
September 18, 2026 | United StatesUnited States: New Executive Order Directs Federal Agencies to Consider Layoff Activity and Labor Market Data in H-1B Adjudications
September 18, 2026 | AustraliaAustralia: Further Migration Reforms to Reduce Net Overseas Migration Announced
September 18, 2026 | AustraliaAustralia: Skilled Visa Processing Priorities Revised
September 18, 2026 | AustraliaAustralian Broadcasting Corporation: Overnights
September 18, 2026 | ThailandThailand: Reduction in Visa-Exempt Stay Duration Forthcoming
September 18, 2026 | United StatesUnited States: New Executive Order Directs Federal Agencies to Consider Layoff Activity and Labor Market Data in H-1B Adjudications
September 18, 2026 | AustraliaAustralia: Further Migration Reforms to Reduce Net Overseas Migration Announced
September 18, 2026 | AustraliaAustralia: Skilled Visa Processing Priorities Revised
September 18, 2026 | AustraliaAustralian Broadcasting Corporation: Overnights
September 18, 2026 | ThailandThailand: Reduction in Visa-Exempt Stay Duration Forthcoming
September 18, 2026 | United StatesUnited States: New Executive Order Directs Federal Agencies to Consider Layoff Activity and Labor Market Data in H-1B Adjudications
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.