Important Updates
Important Updates
February 19, 2026 | Saudi ArabiaSaudi Arabia: Updates to the Nitaqat Program
February 20, 2026 | 🌐Minimum Salary Changes Announced
February 20, 2026 | United KingdomUnited Kingdom: Full ETA Enforcement Commences February 25; Dual Nationals May Need to Renew Expired Passports Before Travel
February 19, 2026 | CanadaCanada: Updates to Express Entry Category-Based Selection for 2026
February 19, 2026 | BelgiumGlobal Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy
February 19, 2026 | Saudi ArabiaSaudi Arabia: Updates to the Nitaqat Program
February 20, 2026 | 🌐Minimum Salary Changes Announced
February 20, 2026 | United KingdomUnited Kingdom: Full ETA Enforcement Commences February 25; Dual Nationals May Need to Renew Expired Passports Before Travel
February 19, 2026 | CanadaCanada: Updates to Express Entry Category-Based Selection for 2026
February 19, 2026 | BelgiumGlobal Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy
February 19, 2026 | Saudi ArabiaSaudi Arabia: Updates to the Nitaqat Program
Subscribe
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
    Navigating Immigration Under the Second Trump AdministrationFragomen Consulting EuropeImmigration 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

  • Navigating Immigration Under the Second Trump Administration
  • Fragomen Consulting Europe
  • 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
  • Insights

Brexit May Impact UK Posted Workers Differently than Locally-Hired UK Nationals

December 7, 2020

insight-news-default

Country / Territory

  • European UnionEuropean Union

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • UK national posted workers may face different registration and work permit rules than UK nationals locally employed in EU countries before and after the end of the transition period on December 31, 2020.
  • This alert offers key examples of such differences. These and future differences will be posted on Fragomen’s consolidated Brexit alert page.

The situation

As a reminder, UK national posted workers are not covered by the Withdrawal Agreement. As a result, EU countries may impose different registration and work permit rules to posted workers than to locally-employed individuals before and after the end of the transition period on December 31, 2020. These and future differences will be posted on the consolidated Brexit alert page.

A closer look

Some key examples of the differing rules for posted workers include the below:

  • France. If UK national posted workers in France started their assignment before January 1, 2021, they will be able to complete the initial duration of their posting, but extensions will require a visa/work permit.
  • Czech Republic. UK national workers posted to the Czech Republic can complete postings that started before December 31, 2020. Subsequently, they require a work permit.
  • Netherlands. UK nationals posted to the Netherlands under free movement of services before December 31, 2020 cannot continue their posting after January 1, 2021. These individuals will require standard work authorization unless specific provisions are agreed in the Brexit negotiations.

 

Impact

  • UK nationals in EU countries. UK nationals seeking to continue working and residing in their current EU country of residence past December 31, 2020 should ensure that they take the necessary steps to prove their residency prior to the end of the transition period, register or apply for immigration status.
  • Special rules for cross-border workers, posted workers and self-employed.
    • Cross-border workers (also called commuters) are protected under the Withdrawal Agreement if their activities started prior to December 31, 2020. EU countries may, however, limit the scope of this protection to individuals holding a local employment contract
    • UK national posted workers in EU countries under free movement of services and their employers should anticipate special rules that may apply to them, as they will likely be required to obtain work authorization after December 31, 2020.
    • Self-employed individuals should double-check migration requirements based on where their business is registered, combined with local regulations related to self-employment.
  • Social security rules. Fragomen urges all UK nationals to take the necessary steps to ensure their social security status reflects their employment situation

 

Background

Under the EU-wide transition period, UK nationals and their family members arriving until December 31, 2020 can continue to register as EU nationals in all EU Member States.

After December 31, 2020, individuals require a new proof of status, based on Article 50 of the Withdrawal Agreement. Many EU Member States are still developing relevant application processes. 

Looking ahead

Fragomen will provide updates on the situation as they become available, on the consolidated Brexit alert page.

Please contact a Fragomen immigration professional for assistance in planning contingency arrangements in a single project.

For more information, please visit Fragomen's dedicated Brexit site, which contains news, FAQs, and analysis/commentary in the form of blogs, videos, webcasts and events. 

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].

Country / Territory

  • European UnionEuropean Union

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Venezuela’s Energy Reset: Unlocking Opportunity, Managing Risk and Deploying Talent Strategically

Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.

Learn more

Media mentions

Global Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy

Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.

Learn more

Awards

Spear's 500 Recognises Partner Julia Onslow-Cole

Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.

Learn more

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

Fragomen news

Fragomen Strengthens Canadian Practice with Partner and Counsel Hires in MontréalLearn more

Media mentions

Buffalo Toronto Public Media: IRCC faces processing hurdles as FIFA World Cup draws near

Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.

Learn more

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

Blog post

Venezuela’s Energy Reset: Unlocking Opportunity, Managing Risk and Deploying Talent Strategically

Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.

Learn more

Media mentions

Global Mobility Lawyer: EU to Leverage Visas With New “Assertive Migration Diplomacy” Strategy

Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.

Learn more

Awards

Spear's 500 Recognises Partner Julia Onslow-Cole

Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.

Learn more

Media mentions

Arabian Gulf Business Insight: Saudi Business Visa Rejections Rise as Scrutiny Tightens

Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.

Learn more

Awards

Doyle’s Guide 2026: Fragomen Leaders Recognized as Leading Immigration Lawyers

Australia and New Zealand Managing Partner  Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.

Learn more

Awards

Fragomen Ranked Band 1 in the Chambers Global 2026 Guide

Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.

Learn more

Fragomen news

Fragomen Strengthens Canadian Practice with Partner and Counsel Hires in MontréalLearn more

Media mentions

Buffalo Toronto Public Media: IRCC faces processing hurdles as FIFA World Cup draws near

Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.

Learn more

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

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
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • 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.