• Insights

The Impact of Comprehensive Sickness Insurance on EEA Permanent Residency

March 28, 2017

Countries / Territories

  • 🌐

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

According to a recent Liberal Democrats analysis reported in The Guardian, in the last two quarters of 2016, more than 12,800 EU citizens had their permanent residency requests refused with a further 5,500 declared invalid, a rejection rate of around 28%.

To qualify for permanent residency in the UK, EEA nationals need five years of continued residence in the UK and must meet certain criteria. We are aware of a recent trend in residency applications submitted by EEA citizens relying on the period of time spent as students or as self-sufficient persons being refused on the grounds that they did not hold Comprehensive Sickness Insurance (CSI) coverage. These cases highlight a little-known requirement, which has the capacity to seriously prejudice an application for permanent residency.

When do EEA Nationals Require Comprehensive Sickness Insurance?

Under EU law, EEA citizens who are students, or self-sufficient persons resident in another member state for more than 3 months must have their own medical insurance. The CSI rule was designed as a barrier against benefit tourism.

This covers applications for Residence Cards and Permanent Residence cards, and also applies to non-EEA family members applying on the basis that their EEA national family member is exercising Treaty rights and sponsoring them in the UK.

Applicants must submit evidence that they:

  1. Have sufficient resources for themselves and family members so as not to become a burden on the social assistance system of the host Member State and have comprehensive sickness insurance cover in the host Member State; or
  2. Are enrolled as students within the host Member State and have Comprehensive Sickness Insurance cover and assure the national authorities that they have sufficient resources for themselves and family members not to become a burden on the social assistance system of the host Member State during their period of residence; or
  3. Are family members of Union citizens falling within one of the above categories.

Applications will normally be refused if none of these conditions are met.

What Documents can an EEA National or their Family Members Provide to Show they have CSI?

EEA nationals applying for documentation confirming their right to reside in the UK as a student or self-sufficient person must present one of the following forms of evidence covering the duration of period of residence in the UK.

For applications for a registration certificate or a residence card, they must provide one of the following documents to show they have CSI: 

  1. A comprehensive insurance policy document confirming that the applicant has private medical insurance. When considering what is ‘comprehensive, the caseworker may accept for example, a policy containing certain exemptions if the applicant is  covered by  the  policy  for medical treatment in the majority of circumstances; or
  2. For persons temporarily in the UK, a valid European Health Insurance Card (EHIC). The EHIC is the replacement for form E111. It must have been issued by a member state other than the UK because the member state that issued the card will cover the cost of treatment. The applicant must also provide a statement of intent that they intend to return to their home country; or  
  3. In certain circumstances, Form S1, S2 or S3. The S1 form is a certificate of entitlement to health care in another EEA country for a limited duration and may only be used in limited circumstances; for example, by state pensioners or dependents of an insured person working in another Member State. The S2 form covers the actual cost of treatment; for example, for insured persons who are referred for specific treatment in another EEA country or Switzerland. The S3 form will cover the cost of treatment; for example, for retired frontier workers continuing treatment in the Member State they previously worked.

For applications for a document certifying permanent residence or a permanent residence card, they must provide one of the following documents or a combination of these documents covering the whole of their 5 years continuous residence in the UK:  

  1. A comprehensive private medical insurance policy document; or 
  2. A valid European Health Insurance Card (EHIC) issued by an EEA member state other than the UK (or its predecessor form E111); or 
  3. Form S1 (or its predecessor forms E109 or E121), Form S2 (or its predecessor form E112) or Form S3. 

If the applicant submits an EHIC which does not cover the whole of the period relied upon, or does not feature a valid from date, they must also submit evidence from the issuing authority confirming that they held a valid EHIC card for the period relied upon. 

If the applicant submits Forms S1, S2 or S3 they must provide one or a combination of these forms for their 5 years continuous residence. It is possible to apply to the country of origin retrospectively for these certificates.

What Happens If You have not had CSI and Your Application is Refused?

A refusal means that Permanent Residence will not be granted, but this does not mean removal from the UK.

There were growing fears among EEA citizens that they would be deported for not complying with the requirement to have CSI after a German student was warned by a UKVI official that she could be removed if she could not show insurance documents.  

On 1st March 2017, the Home Office confirmed that this will not be acted upon, and issued the following statement:

“EU citizens will not be removed from the UK or refused entry solely because they do not have comprehensive sickness insurance.”

Countries / Territories

  • 🌐

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related offices

  • Fragomen in Brussels, Belgium
  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Sheffield, United Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Media mentions

Professional Engineering: How to Access International Engineering Talent in a Changing Immigration System

In this article published by Professional Engineering, Senior Manager Nadine Barnole examines how UK engineering employers can continue to access international talent amid growing skills shortages and a rapidly evolving immigration landscape.

Learn more

Media mentions

Times Brasil CNBC: How Technology is Reshaping Identity Verification Systems

In this Times Brasil CNBC Real Tech interview, Partner Diana Quintas discusses Brazil’s recent visa exemption for Chinese nationals, what it signals for Brazil-China mobility and how technology is helping support more efficient cross-border movement.

Learn more

Podcast

World Refugee Day 2026

In this episode of The Immigration Conversation, Business Immigration Manager Ayana Ibrahimi is joined by Lara Dyer, Chief Solutions Officer (Americas) at Talent Beyond Boundaries; Stuart Szabo, CEO and Co-founder of Beacon; and Jessica Turner, Co-founder and CEO of ThriveON, to discuss refugee labour mobility and employment-based pathways for displaced talent.

Learn more

Video

Business Travel to China | #MobilityMinute

In this Mobility Minute, Manager Maja Sugui provides an overview of key visa and compliance considerations for business travelers planning trips to China.

Learn more

Media mentions

Michigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers

In this profile published in Michigan Law’s Law Quadrangle, Counsel Christopher Wendt discusses the role of immigration in supporting the US healthcare workforce and expanding access to civil legal aid in Minnesota.

Learn more

Media mentions

WealthBriefing: The End of the Golden Visa?

Director Isobel Neilson discusses how investment migration programs are evolving amid political scrutiny, regulatory reform and shifting priorities, with governments moving toward pathways that emphasise economic contribution, talent and stronger ties to host countries.

Learn more

Fragomen news

Fragomen Welcomes Christopher Wendt as Counsel

Fragomen welcomes Counsel Christopher Wendt in Minnesota, bringing nearly three decades of immigration law experience, including more than 20 years supporting workforce immigration programs for Mayo Clinic.

Learn more

Media mentions

The ABC: Switzerland is Set to Vote on a Population Cap. Here's Why it's Divided the Nation

Senior Counsel Dr. Anna Boucher discusses Switzerland’s rejected population cap referendum and the role of immigration in supporting workforce and economic stability.

Learn more

Awards

Fragomen Featured in Global Mobility Lawyer’s 2026 GML Elite

Fragomen has been featured in the 2026 GML Elite, Global Mobility Lawyer’s inaugural guide to leading global mobility teams, highlighting the firm’s global immigration capabilities, international footprint and work supporting multinational clients.

Learn more

Media mentions

Deutscher AnwaltSpiegel: Die Blaue Karte EU 2026

Partner Marius Tollenaere outlines the key 2026 EU Blue Card changes employers must understand to stay compliant and competitive.

Learn more

Media mentions

STV News: What Can Scots Fans Do if Their US Travel Permits Have Been Revoked?

Partner Charlotte Slocombe explained options available to Scotland fans whose US ESTAs have been denied or revoked ahead of the FIFA World Cup.

Learn more

Media mentions

Arabian Gulf Business Insight: Corporate Relocations to the Gulf Retain Appeal

Partner Abeer Al Husseini discusses evolving corporate relocation strategies and sustained demand for moves to the Gulf.

Learn more

Media mentions

Professional Engineering: How to Access International Engineering Talent in a Changing Immigration System

In this article published by Professional Engineering, Senior Manager Nadine Barnole examines how UK engineering employers can continue to access international talent amid growing skills shortages and a rapidly evolving immigration landscape.

Learn more

Media mentions

Times Brasil CNBC: How Technology is Reshaping Identity Verification Systems

In this Times Brasil CNBC Real Tech interview, Partner Diana Quintas discusses Brazil’s recent visa exemption for Chinese nationals, what it signals for Brazil-China mobility and how technology is helping support more efficient cross-border movement.

Learn more

Podcast

World Refugee Day 2026

In this episode of The Immigration Conversation, Business Immigration Manager Ayana Ibrahimi is joined by Lara Dyer, Chief Solutions Officer (Americas) at Talent Beyond Boundaries; Stuart Szabo, CEO and Co-founder of Beacon; and Jessica Turner, Co-founder and CEO of ThriveON, to discuss refugee labour mobility and employment-based pathways for displaced talent.

Learn more

Video

Business Travel to China | #MobilityMinute

In this Mobility Minute, Manager Maja Sugui provides an overview of key visa and compliance considerations for business travelers planning trips to China.

Learn more

Media mentions

Michigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers

In this profile published in Michigan Law’s Law Quadrangle, Counsel Christopher Wendt discusses the role of immigration in supporting the US healthcare workforce and expanding access to civil legal aid in Minnesota.

Learn more

Media mentions

WealthBriefing: The End of the Golden Visa?

Director Isobel Neilson discusses how investment migration programs are evolving amid political scrutiny, regulatory reform and shifting priorities, with governments moving toward pathways that emphasise economic contribution, talent and stronger ties to host countries.

Learn more

Fragomen news

Fragomen Welcomes Christopher Wendt as Counsel

Fragomen welcomes Counsel Christopher Wendt in Minnesota, bringing nearly three decades of immigration law experience, including more than 20 years supporting workforce immigration programs for Mayo Clinic.

Learn more

Media mentions

The ABC: Switzerland is Set to Vote on a Population Cap. Here's Why it's Divided the Nation

Senior Counsel Dr. Anna Boucher discusses Switzerland’s rejected population cap referendum and the role of immigration in supporting workforce and economic stability.

Learn more

Awards

Fragomen Featured in Global Mobility Lawyer’s 2026 GML Elite

Fragomen has been featured in the 2026 GML Elite, Global Mobility Lawyer’s inaugural guide to leading global mobility teams, highlighting the firm’s global immigration capabilities, international footprint and work supporting multinational clients.

Learn more

Media mentions

Deutscher AnwaltSpiegel: Die Blaue Karte EU 2026

Partner Marius Tollenaere outlines the key 2026 EU Blue Card changes employers must understand to stay compliant and competitive.

Learn more

Media mentions

STV News: What Can Scots Fans Do if Their US Travel Permits Have Been Revoked?

Partner Charlotte Slocombe explained options available to Scotland fans whose US ESTAs have been denied or revoked ahead of the FIFA World Cup.

Learn more

Media mentions

Arabian Gulf Business Insight: Corporate Relocations to the Gulf Retain Appeal

Partner Abeer Al Husseini discusses evolving corporate relocation strategies and sustained demand for moves to the Gulf.

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
June 17, 2026 | United StatesMichigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers
June 18, 2026 | IndonesiaIndonesia: Processing Delays Following Ongoing Anti-Corruption Investigations
June 18, 2026 | United KingdomProfessional Engineering: How to Access International Engineering Talent in a Changing Immigration System
June 18, 2026 | BrazilTimes Brasil CNBC: How Technology is Reshaping Identity Verification Systems
June 17, 2026 | IrelandIreland: Stricter Family Sponsorship Requirements
June 17, 2026 | United StatesMichigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers
June 18, 2026 | IndonesiaIndonesia: Processing Delays Following Ongoing Anti-Corruption Investigations
June 18, 2026 | United KingdomProfessional Engineering: How to Access International Engineering Talent in a Changing Immigration System
June 18, 2026 | BrazilTimes Brasil CNBC: How Technology is Reshaping Identity Verification Systems
June 17, 2026 | IrelandIreland: Stricter Family Sponsorship Requirements
June 17, 2026 | United StatesMichigan Law’s Law Quadrangle: Christopher Wendt, ’98: At the Intersection of Immigration and Health Care Workers
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.