• 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

Media mentions

Biometric Update: Fragomen and SICPA Form JV to Join Digital Identity Market With End-to-End Platform

Fragomen and SICPA have launched a global joint venture to develop an end-to-end digital identity platform that enables secure identity verification, document authentication and verifiable credential management.

Learn more

Media mentions

Times of India: Trump Administration Eyes Tighter H-1B, Green Card and Student Visa Rules; Indians Could Be Among Most Affected

Senior Counsel Mitch Wexler discusses how potential changes to H-1B visas, employment-based green cards and OPT could impact employers’ workforce planning and compliance obligations.

Learn more

Media mentions

World Business Travel Forum: Leaders in Motion - Middle East Mobility and Travel Resilience

In a Leaders in Motion interview with World Business Travel Forum, Partner Ali Haider and Nomadic CEO Carsten Østberg discuss recent travel and mobility developments across the Middle East and practical considerations for employers managing cross-border talent in the region.

Learn more

Media mentions

Global Mobility Lawyer: Dairy Industry Gains Clarity on H-2A Guest Worker Eligibility

Partner Rachel Beardsley explains how new DHS guidance clarifies that dairy employers may use the H-2A program when they can demonstrate a temporary or seasonal labor need.

Learn more

Media mentions

Times of India: US Finalises Alien Registration Rule: H-1B Holders Need Not Register AgainLearn more

Fragomen news

Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions

Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.

Learn more

Blog post

Immigration + Tax: A Strategic Duo in Global Mobility

Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.

Learn more

Podcast

Summer Travel Considerations for Foreign Nationals

In this episode of The Immigration Conversation, Senior Associates Sarah Melnick and Kimberly Elmazi discuss key considerations for foreign nationals planning international summer travel, including visa appointment planning, document preparation, consular interviews, port-of-entry procedures and I-94 review.

Learn more

Podcast

A New PM for the UK: What Will This Mean for Immigration Policy?

UK Government Affairs Strategy Director Shuyeb Muquit is joined by Jonathan Thomas of the Social Market Foundation, Dr. Ben Brindle of the Migration Observatory, University of Oxford and Steve McCauley of the University of Cambridge to discuss what a new UK Prime Minister could mean for immigration policy, employers and workforce mobility.

Learn more

Fragomen news

2026年6月 アメリカ移民法ダイジェスト Learn more

Media mentions

NRC: Iedereen met een Canadese voorouder kan nu staatsburgerschap aanvragen – vooral Amerikanen doen dat

Partner Rick Lamanna said Canada’s expanded citizenship rules could make hundreds of thousands if not millions of people eligible while moving against a global trend of tighter citizenship laws.

Learn more

Media mentions

SBS News: The Overlooked Factor in Australia's Migration Debate That's Keeping Figures High

Senior Counsel Dr. Anna Boucher shares insights on the factors influencing Australia's migration trends.

Learn more

Media mentions

Biometric Update: Fragomen and SICPA Form JV to Join Digital Identity Market With End-to-End Platform

Fragomen and SICPA have launched a global joint venture to develop an end-to-end digital identity platform that enables secure identity verification, document authentication and verifiable credential management.

Learn more

Media mentions

Times of India: Trump Administration Eyes Tighter H-1B, Green Card and Student Visa Rules; Indians Could Be Among Most Affected

Senior Counsel Mitch Wexler discusses how potential changes to H-1B visas, employment-based green cards and OPT could impact employers’ workforce planning and compliance obligations.

Learn more

Media mentions

World Business Travel Forum: Leaders in Motion - Middle East Mobility and Travel Resilience

In a Leaders in Motion interview with World Business Travel Forum, Partner Ali Haider and Nomadic CEO Carsten Østberg discuss recent travel and mobility developments across the Middle East and practical considerations for employers managing cross-border talent in the region.

Learn more

Media mentions

Global Mobility Lawyer: Dairy Industry Gains Clarity on H-2A Guest Worker Eligibility

Partner Rachel Beardsley explains how new DHS guidance clarifies that dairy employers may use the H-2A program when they can demonstrate a temporary or seasonal labor need.

Learn more

Media mentions

Times of India: US Finalises Alien Registration Rule: H-1B Holders Need Not Register AgainLearn more

Fragomen news

Fragomen and SICPA Launch a Global Strategic Joint Venture to Advance Global Digital Identity Solutions

Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.

Learn more

Blog post

Immigration + Tax: A Strategic Duo in Global Mobility

Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.

Learn more

Podcast

Summer Travel Considerations for Foreign Nationals

In this episode of The Immigration Conversation, Senior Associates Sarah Melnick and Kimberly Elmazi discuss key considerations for foreign nationals planning international summer travel, including visa appointment planning, document preparation, consular interviews, port-of-entry procedures and I-94 review.

Learn more

Podcast

A New PM for the UK: What Will This Mean for Immigration Policy?

UK Government Affairs Strategy Director Shuyeb Muquit is joined by Jonathan Thomas of the Social Market Foundation, Dr. Ben Brindle of the Migration Observatory, University of Oxford and Steve McCauley of the University of Cambridge to discuss what a new UK Prime Minister could mean for immigration policy, employers and workforce mobility.

Learn more

Fragomen news

2026年6月 アメリカ移民法ダイジェスト Learn more

Media mentions

NRC: Iedereen met een Canadese voorouder kan nu staatsburgerschap aanvragen – vooral Amerikanen doen dat

Partner Rick Lamanna said Canada’s expanded citizenship rules could make hundreds of thousands if not millions of people eligible while moving against a global trend of tighter citizenship laws.

Learn more

Media mentions

SBS News: The Overlooked Factor in Australia's Migration Debate That's Keeping Figures High

Senior Counsel Dr. Anna Boucher shares insights on the factors influencing Australia's migration trends.

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
July 10, 2026 | United StatesUnited States: TPS Employment Authorization Again Extended Briefly for Several Countries
July 10, 2026 | 🌐Biometric Update: Fragomen and SICPA Form JV to Join Digital Identity Market With End-to-End Platform
July 10, 2026 | Saudi ArabiaSaudi Arabia: Extended Grace Period for Foreign Workers in Irregular Status
July 10, 2026 | South AfricaSouth Africa: Medical Report Requirement Waived for Certain Visa Types
July 10, 2026 | United StatesTimes of India: Trump Administration Eyes Tighter H-1B, Green Card and Student Visa Rules; Indians Could Be Among Most Affected
July 10, 2026 | United StatesUnited States: TPS Employment Authorization Again Extended Briefly for Several Countries
July 10, 2026 | 🌐Biometric Update: Fragomen and SICPA Form JV to Join Digital Identity Market With End-to-End Platform
July 10, 2026 | Saudi ArabiaSaudi Arabia: Extended Grace Period for Foreign Workers in Irregular Status
July 10, 2026 | South AfricaSouth Africa: Medical Report Requirement Waived for Certain Visa Types
July 10, 2026 | United StatesTimes of India: Trump Administration Eyes Tighter H-1B, Green Card and Student Visa Rules; Indians Could Be Among Most Affected
July 10, 2026 | United StatesUnited States: TPS Employment Authorization Again Extended Briefly for Several Countries
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.