Important Updates
Important Updates
November 13, 2025 | United StatesUnited States: President Trump Signs Government Funding Bill Through January 30
November 13, 2025 | AustraliaAustralia: Skilled Migration Invitation Round and Allocations Announced
November 13, 2025 | Australia, IndiaAustralia/India: Agreement Signed to Promote Mobility of Students, Graduates, Academic Researchers and Professionals
November 13, 2025 | Costa RicaCosta Rica: Fast-Track Immigration Process for Accredited Companies Launched
November 13, 2025 | MexicoFragomen Attorneys Recognized in the 2026 Edition of The Best Lawyers in Mexico™
November 13, 2025 | United StatesUnited States: President Trump Signs Government Funding Bill Through January 30
November 13, 2025 | AustraliaAustralia: Skilled Migration Invitation Round and Allocations Announced
November 13, 2025 | Australia, IndiaAustralia/India: Agreement Signed to Promote Mobility of Students, Graduates, Academic Researchers and Professionals
November 13, 2025 | Costa RicaCosta Rica: Fast-Track Immigration Process for Accredited Companies Launched
November 13, 2025 | MexicoFragomen Attorneys Recognized in the 2026 Edition of The Best Lawyers in Mexico™
November 13, 2025 | United StatesUnited States: President Trump Signs Government Funding Bill Through January 30
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

Awards

Fragomen Attorneys Recognized in the 2026 Edition of The Best Lawyers in Mexico™

Eight Fragomen professionals in Mexico City recognized in The Best Lawyers in Mexico™ 2026 edition for excellence in Immigration Law.

Learn more

Fragomen news

Global Mobility Lawyer: DHS proposes sweeping expansion of biometric data collection

Partner Blake Chisam discusses DHS’s proposed rule expanding biometric data collection and continuous vetting, outlining key privacy and compliance implications for employers.

Learn more

Fragomen news

Global Mobility Lawyer: GCC to launch unified multi-entry visa for regional travel

Partner Abeer Al Husseini discusses the Gulf Cooperation Council’s new unified multi-entry visa and its implications for business travel and compliance across the region.

Learn more

Awards

Fragomen Ranked in 2026 Edition of "Best Law Firms in the United States" by The Best Lawyers

Fragomen is recognized at the National Tier 1 level for Immigration Law in the 2026 edition of The Best Law Firms – United States, with 15 offices across the country also recognized for their excellence in immigration law.

Learn more

Awards

Fragomen Wins Altair Global’s 2025 Super Star Award for Humanitarian Commitment

Fragomen receives Altair Global’s 2025 Super Star Award for Humanitarian Commitment, honoring the firm’s leadership in advancing humanitarian mobility initiatives.

Learn more

Media mentions

The Toronto Star: Canada will reduce international student permits by more than half, budget reveals

Partner Rick Lamanna discusses Canada’s 2025 federal budget and its significant shift in immigration policy including new limits on international student permits and temporary residents.

Learn more

Fragomen news

2025年10月 アメリカ移民法ダイジェスト Learn more

Fragomen news

Fragomen Cited in House of Lords Report on the Future of the UK Space Economy

Fragomen is cited in the UK House of Lords’ landmark report, “The Space Economy: Act Now or Lose Out,” published on 4 November by the UK Engagement with Space Committee.

Learn more

Blog post

Georgia Immigration Reform 2025: New Work Permit Rules for Foreign Nationals

Manager Zaur Gasimov discusses Georgia’s new immigration and labour-migration reforms introducing mandatory work permits, stricter employer compliance requirements and increased penalties for non-compliance.

Learn more

Awards

Senior Associate Agata Richardson Honored with Casa Cornelia Law Center Pro Bono Publico Award

Senior Associate Agata Danuta Richardson is recognized with a prestigious Pro Bono Publico Award by the Casa Cornelia Law Center.

Learn more

Media mentions

European Security & Technology Magazine: Die kritische Wachstumsbremse der europäischen Verteidigungsindustrie

Frankfurt Managing Partner Dr. Axel Boysen highlights the growing skilled labor gap as Europe’s defense industry expands.

Learn more

Media mentions

Games Industry: US H-1B Visas: Alternatives to a $100,000 Fee

Senior Manager William Diaz outlines the US visa options available to the games industry for bringing international talent to the United States, including O-1, L-1 and E-2.

Learn more

Awards

Fragomen Attorneys Recognized in the 2026 Edition of The Best Lawyers in Mexico™

Eight Fragomen professionals in Mexico City recognized in The Best Lawyers in Mexico™ 2026 edition for excellence in Immigration Law.

Learn more

Fragomen news

Global Mobility Lawyer: DHS proposes sweeping expansion of biometric data collection

Partner Blake Chisam discusses DHS’s proposed rule expanding biometric data collection and continuous vetting, outlining key privacy and compliance implications for employers.

Learn more

Fragomen news

Global Mobility Lawyer: GCC to launch unified multi-entry visa for regional travel

Partner Abeer Al Husseini discusses the Gulf Cooperation Council’s new unified multi-entry visa and its implications for business travel and compliance across the region.

Learn more

Awards

Fragomen Ranked in 2026 Edition of "Best Law Firms in the United States" by The Best Lawyers

Fragomen is recognized at the National Tier 1 level for Immigration Law in the 2026 edition of The Best Law Firms – United States, with 15 offices across the country also recognized for their excellence in immigration law.

Learn more

Awards

Fragomen Wins Altair Global’s 2025 Super Star Award for Humanitarian Commitment

Fragomen receives Altair Global’s 2025 Super Star Award for Humanitarian Commitment, honoring the firm’s leadership in advancing humanitarian mobility initiatives.

Learn more

Media mentions

The Toronto Star: Canada will reduce international student permits by more than half, budget reveals

Partner Rick Lamanna discusses Canada’s 2025 federal budget and its significant shift in immigration policy including new limits on international student permits and temporary residents.

Learn more

Fragomen news

2025年10月 アメリカ移民法ダイジェスト Learn more

Fragomen news

Fragomen Cited in House of Lords Report on the Future of the UK Space Economy

Fragomen is cited in the UK House of Lords’ landmark report, “The Space Economy: Act Now or Lose Out,” published on 4 November by the UK Engagement with Space Committee.

Learn more

Blog post

Georgia Immigration Reform 2025: New Work Permit Rules for Foreign Nationals

Manager Zaur Gasimov discusses Georgia’s new immigration and labour-migration reforms introducing mandatory work permits, stricter employer compliance requirements and increased penalties for non-compliance.

Learn more

Awards

Senior Associate Agata Richardson Honored with Casa Cornelia Law Center Pro Bono Publico Award

Senior Associate Agata Danuta Richardson is recognized with a prestigious Pro Bono Publico Award by the Casa Cornelia Law Center.

Learn more

Media mentions

European Security & Technology Magazine: Die kritische Wachstumsbremse der europäischen Verteidigungsindustrie

Frankfurt Managing Partner Dr. Axel Boysen highlights the growing skilled labor gap as Europe’s defense industry expands.

Learn more

Media mentions

Games Industry: US H-1B Visas: Alternatives to a $100,000 Fee

Senior Manager William Diaz outlines the US visa options available to the games industry for bringing international talent to the United States, including O-1, L-1 and E-2.

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

© 2025 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.