• 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

AIP: Trump Administration Proposes New Six-Figure H-1B Fee

Partner Bo Cooper discusses the potential impact of the proposed $103,265 fee for cap-subject H-1B petitions on US employers and international talent in AIP.

Learn more
Generic Insights

Blog post

Luxury Retail’s Evolving Talent Needs: When Business-Critical Skills Don’t Fit Traditional Immigration Categories

In our latest blog, Canada Managing Partner Cosmina Morariu explores how aligning mobility with talent planning can help brands deploy critical expertise where it is needed.

Learn more

Podcast

Moving HQ to the Middle East: A Success Perspective with VEON - Beyond Borders Series | The Immigration Conversation

Partner Ali Haider and Director Shoaib Khaleeli speak with VEON Chief People Officer Jameel Asghar about leadership, future-ready talent, organisational resilience and VEON’s decision to relocate its headquarters to Dubai.

Learn more

Media mentions

Financial Times: Trump Administration Pauses Immigrant Visa Applications

Senior US Consular Manager Brian Simmons discusses the impact of the Trump administration’s worldwide pause on immigrant visa applications and the disruption caused by last-minute interview cancellations in the Financial Times.

Learn more

Blog post

Latin America’s Evolving Mobility Landscape: Opportunity and Complexity Advancing Together

Latin America and the Caribbean Managing Partner Leonor Echeverria explores how stronger compliance expectations, processing constraints and increasingly fragmented immigration policies are reshaping workforce mobility across the region—and where new pathways for specialized talent are emerging.

Learn more

Media mentions

Proposed $103,265 H-1B Fee: Fragomen Attorneys Examine the Potential Impact

Partners Bo Cooper and K. Edward Raleigh and Senior Counsel Mitchell Wexler discuss the potential impact of a proposed $103,265 fee for cap-subject H-1B petitions on employers and foreign talent.

Learn more
Generic Insights

Blog post

2026 Immigration Regulatory Changes: What Academic Medical Centers Need to Know

In this blog, Counsel Christopher Wendt examines four developments AMCs should have on their radar and why preparing for them may require coordination across immigration, GME, research administration, HR, benefits, finance and more.

Learn more

Blog post

Five Questions to Consider Before Seeking Residence or Citizenship in Europe

Senior Manager Andreia Florina Ghimis and Manager Pierangelo D’Errico outline five key questions to ask before seeking residency in Europe.

Learn more

Awards

Fragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development

Fragomen received a Brandon Hall Group™ Gold HCM Excellence Award® in the Best Leadership Development Program category for our Leadership Lifecycle initiative.

Learn more

Media mentions

People Management: Unpacking the New Overseas Talent ‘Concierge’ Service

Partner Charlotte Wills and Senior Manager Harry Goldstraw discuss the UK’s new overseas talent “concierge” service and what it means for high-growth businesses recruiting international talent.

Learn more

Blog post

A1-Bescheinigung oder Certificate of Coverage (CoC): Welches Dokument wird wann benötigt?

In this blog, Senior Manager Katharina Vorländer explains when A1 certificates and Certificates of Coverage (CoCs) may be required, the key differences between the two documents and what employers should consider before managing international assignments.

Learn more

Awards

Fragomen Attorneys Recognized in the 2027 Edition of The Best Lawyers in America™

Fragomen attorneys are recognized in the 2027 editions of The Best Lawyers in America™ and Best Lawyers: Ones to Watch® in America, including Partner Matthew Phillips and Senior Counsel Mitch Wexler as Lawyer of the Year recipients.

Learn more

Media mentions

AIP: Trump Administration Proposes New Six-Figure H-1B Fee

Partner Bo Cooper discusses the potential impact of the proposed $103,265 fee for cap-subject H-1B petitions on US employers and international talent in AIP.

Learn more
Generic Insights

Blog post

Luxury Retail’s Evolving Talent Needs: When Business-Critical Skills Don’t Fit Traditional Immigration Categories

In our latest blog, Canada Managing Partner Cosmina Morariu explores how aligning mobility with talent planning can help brands deploy critical expertise where it is needed.

Learn more

Podcast

Moving HQ to the Middle East: A Success Perspective with VEON - Beyond Borders Series | The Immigration Conversation

Partner Ali Haider and Director Shoaib Khaleeli speak with VEON Chief People Officer Jameel Asghar about leadership, future-ready talent, organisational resilience and VEON’s decision to relocate its headquarters to Dubai.

Learn more

Media mentions

Financial Times: Trump Administration Pauses Immigrant Visa Applications

Senior US Consular Manager Brian Simmons discusses the impact of the Trump administration’s worldwide pause on immigrant visa applications and the disruption caused by last-minute interview cancellations in the Financial Times.

Learn more

Blog post

Latin America’s Evolving Mobility Landscape: Opportunity and Complexity Advancing Together

Latin America and the Caribbean Managing Partner Leonor Echeverria explores how stronger compliance expectations, processing constraints and increasingly fragmented immigration policies are reshaping workforce mobility across the region—and where new pathways for specialized talent are emerging.

Learn more

Media mentions

Proposed $103,265 H-1B Fee: Fragomen Attorneys Examine the Potential Impact

Partners Bo Cooper and K. Edward Raleigh and Senior Counsel Mitchell Wexler discuss the potential impact of a proposed $103,265 fee for cap-subject H-1B petitions on employers and foreign talent.

Learn more
Generic Insights

Blog post

2026 Immigration Regulatory Changes: What Academic Medical Centers Need to Know

In this blog, Counsel Christopher Wendt examines four developments AMCs should have on their radar and why preparing for them may require coordination across immigration, GME, research administration, HR, benefits, finance and more.

Learn more

Blog post

Five Questions to Consider Before Seeking Residence or Citizenship in Europe

Senior Manager Andreia Florina Ghimis and Manager Pierangelo D’Errico outline five key questions to ask before seeking residency in Europe.

Learn more

Awards

Fragomen Receives Brandon Hall Group™ Gold HCM Excellence Award® for Leadership Development

Fragomen received a Brandon Hall Group™ Gold HCM Excellence Award® in the Best Leadership Development Program category for our Leadership Lifecycle initiative.

Learn more

Media mentions

People Management: Unpacking the New Overseas Talent ‘Concierge’ Service

Partner Charlotte Wills and Senior Manager Harry Goldstraw discuss the UK’s new overseas talent “concierge” service and what it means for high-growth businesses recruiting international talent.

Learn more

Blog post

A1-Bescheinigung oder Certificate of Coverage (CoC): Welches Dokument wird wann benötigt?

In this blog, Senior Manager Katharina Vorländer explains when A1 certificates and Certificates of Coverage (CoCs) may be required, the key differences between the two documents and what employers should consider before managing international assignments.

Learn more

Awards

Fragomen Attorneys Recognized in the 2027 Edition of The Best Lawyers in America™

Fragomen attorneys are recognized in the 2027 editions of The Best Lawyers in America™ and Best Lawyers: Ones to Watch® in America, including Partner Matthew Phillips and Senior Counsel Mitch Wexler as Lawyer of the Year recipients.

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
August 27, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
August 28, 2026 | MalaysiaMalaysia: New Photograph Verification Processes
August 28, 2026 | United StatesUnited States: DHS Proposal to Eliminate 60-Day Nonimmigrant Grace Period Clears Federal Review
August 28, 2026 | 🌐Worldwide: Temporary Ebola-Related Entry Restrictions Introduced
August 27, 2026 | United StatesAIP: Trump Administration Proposes New Six-Figure H-1B Fee
August 27, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
August 28, 2026 | MalaysiaMalaysia: New Photograph Verification Processes
August 28, 2026 | United StatesUnited States: DHS Proposal to Eliminate 60-Day Nonimmigrant Grace Period Clears Federal Review
August 28, 2026 | 🌐Worldwide: Temporary Ebola-Related Entry Restrictions Introduced
August 27, 2026 | United StatesAIP: Trump Administration Proposes New Six-Figure H-1B Fee
August 27, 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.