Before Brexit, UK citizens could travel, live, go on holiday and work anywhere in the EU without any special permits or visas. As of 1 January 2021 that is no longer the case.
The Guardian’s Money team has spent the week poring over the many pages of documentation to explain how Brexit will affect you.
Holidays and travel
What does all this mean for holidays this year – if and when they are allowed to resume? While the coronavirus crisis has pretty much put a halt to all immediate travel, when the current restrictions are lifted and European trips can resume, Brits face some significant changes over the next two years.
While most of those taking city breaks or beach holidays to an EU country (plus Norway, Switzerland and Iceland) will see little immediate difference, the picture is markedly different if you travel a lot or spend a significant amount of time in the EU.
Britain and the EU have agreed visa-free travel for short visits, meaning UK passport holders can spend up to 90 days in the its Schengen zone during any 180-day period.
This can be in a series of short visits or one long visit, and it applies to all EU countries with the exception of the non-Schengen countries Bulgaria, Croatia, Cyprus and Romania. You could make a 90-day trip to any of those and still not use up your 90-day allowance. The same is true of Ireland, which allows unrestricted travel from the UK as part of a common travel area for British nationals.
From 2022 (the exact date is yet to be confirmed), you will have to buy a visa waiver for holidays and short stays in the EU. This is not a visa but a permission to enter. It will cost €7 (£6.29) and will be issued under the European Travel Information and Authorisation System, similar to the Esta permit currently required to visit the US.
I usually spend more than 90 days in the EU over a six-month period as a tourist – will I be able to with a visa? Probably not. The Brexit agreement clearly restricts short trip visits to a maximum 90 days within one 180-day period. While the UK government says Brits who have exceeded their 90 days will be able to apply for a visa to stay longer, the European commission says that once the 90 days are up, the person would cease to be a tourist or “short stay” visitor, and would have to apply for a full long-term immigration visa – with all the costs and hassle that that entails.
As it stands, someone spending May, June and July with a friend in Spain would not be able to return visa-free to any EU country inside the Schengen travel area until November – six months after they arrived in Spain. So, for example, if they wanted to visit Venice in August, that might prove tricky.
However, each EU country has the right to set its own entry terms. It is possible that, for example, the Spanish or Portuguese governments, which are keen on maintaining UK tourist levels, could decide to offer an easy, non-work visa in the future, but this is by no means a given.
Expect more details to emerge from EU countries during the coming months – but don’t bank on it.
Will my Ehic card still work? Yes and no. According to the NHS website, your European health insurance card remains valid in the EU until it expires, which for some people will be quite a way off.
However, a replacement is being developed called the global health insurance card (Ghic). The bad news is that there are few details at the moment, and it does not for now extend as far as the Ehic.
Currently, the new Ghic is expected to cover you for travel in EU countries, but not Switzerland, Iceland and Liechtenstein. If travelling to any of those countries, buying private cover should be regarded as an absolute necessity. Transitional arrangements have been put in place for Norway allowing UK nationals to use their UK passport to access state-provided medical treatment if necessary.
The government is also negotiating new arrangements with Switzerland and the European Economic Area (EEA)/European Free Trade Association (Efta) states that could result in Ehic-style reciprocal healthcare cover there.
Keep in mind that the Ehic and its successor the Ghic are not the same as travel insurance. The Ehic card entitles visitors only to necessary state healthcare for free or at a reduced cost. It does not, for example, cover repatriation to the UK after a serious accident.
The “global” bit of the new Ghic is something of a misnomer. The British government has not suddenly decided to give British tourists free health cover in the US. It will offer cover only under existing reciprocal arrangements: largely in Commonwealth countries such as Australia and New Zealand.
Will I need travel insurance? It is not a legal requirement that a traveller buys insurance when visiting the EU, but for the vast majority of people it would be daft not to, with scores of annual multi-trip policies costing less than £50 available for travel to Europe in 2021. There have been widespread concerns about the cost of travel insurance post-Brexit as the Ehic is withdrawn, particularly for those with pre-existing conditions.
What about passports/immigration control? Pre-Brexit, you could travel to EU countries on your passport right up to the point it expired. As of 1 January 2021, the UK government was advising travellers visiting the EU plus Iceland, Liechtenstein, Norway and Switzerland, to have at least six months left on their passport.
You will no longer be able to use EU fast-track passport control and customs lanes, meaning possible delays at some airports. Also, when you arrive in an EU country (except Ireland), be prepared to show your return ticket. You could also be asked to show that you have enough money for your stay.
And driving abroad? The good news is that your UK driving licence will continue to be valid in Europe. Previously it was understood that UK drivers would have to apply at the Post Office for one of two (or both) international driving permits, depending on the destination country.
However, if you are taking your own car or other vehicle abroad, you will still need to apply to your insurer for a green card to prove that you have cover. There shouldn’t be a charge, except perhaps an admin fee, according to the Association of British Insurers. You should print it out and be ready to show it if asked by the police or other authorities. Note that Northern Irish drivers who enter the Republic will also need one. The ABI says the EU could end the green card requirement in the coming months.
What about mobile roaming? The right to use your UK phone allowance while in Europe will end, meaning there is nothing to stop the phone companies reintroducing roaming charges. The big four main providers – EE, 02, Vodafone and Three – have said they have no plans to do this in the short term.
As part of the deal, the UK and EU have agreed to cooperate on “fair and transparent” rates for mobile roaming. It remains to be seen what that means.
And pet passports? The old EU pet passports are no longer valid. Instead the EU has agreed that Great Britain should be given “part two listed” status, allowing pets to travel within its borders providing the owners obtain an animal health certificate (AHC). This confirms that your pet is microchipped and vaccinated against rabies. You will need to get a new certificate each time you travel up to 10 days prior to travel. The AHC will be valid for four months.
How much booze can I bring back with me? The days of filling the car with as much wine as the suspension could take are also over, and a booze cruise to Calais won’t really be worth it after 1 January. Travellers returning from the EU will be restricted to 18 litres of wine (24 bottles), 42 litres of beer and 4 litres of spirits or liqueurs over 22% in alcohol – plus up to 200 cigarettes.
So, compensation for flight delays … will we still get it? Yes. The EU261 rules that require airlines to compensate passengers for seriously delayed or cancelled flights have been written into UK law and remain as before. EU travel firms supplying UK consumers will also still have to provide compensation if their company goes bust.
Studying in the EU
For anyone who was already living or studying in the EU before 31 December 2020, it is business as usual, and you will pay the same (EU) fees until the course ends.
You will also continue to be eligible for the same support – access to loans and so on – as students from the country you are studying in.
However, as things stand, British students applying to study in the EU from September 2021 onwards face paying the much higher international fees paid by all non-EU nationals. They may well also not have access to the loans and other help that their predecessors enjoyed.
Working in the EU
From 1 January 2021, UK citizens no longer have an automatic right to live or work in the EU, so if you are looking to do this, you will need to check your destination’s immigration rules.
UK citizens who moved to an EU member state before 31 December 2020 can carry on living and working there but must register as a resident in the country where they live by 30 June 2021.
For Britons who live in the UK but spend a lot of time working in the EU, things are now very complicated.
There is a deal for senior managers who are seconded, and some short-term business visitors can work for 90 days in any given six-month period, but there are restrictions on the activities they can perform. The list of permitted activities shows that while meetings, trade exhibitions and conferences, consultations and research are fine, anything that involves selling goods or services directly to the public will require a work visa.
Each EU member state has its own immigration regime, with often strict sanctions for those who don’t comply.
Musicians and other performers have been left out of the deal, meaning that they have to get work permits to tour in the EU. The singer-songwriter KT Tunstall and the comedian Dawn French are among the more than 200,000 people who have signed a petition on the subject.
There is no mutual recognition of professional qualifications in the deal, causing complications for those such as doctors, accountants and architects qualifying in the UK who wish to practise in the EU after 1 January.
Living in the EU
I am a UK national in Europe – will I still get my UK pension? Yes. UK pensioners (including EU citizens who have worked in the UK) who have retired to an EU country have already been guaranteed that they will be able to receive the UK state pension, and benefit from any annual uprating. For people who intend to retire to another EU nation in future, there are also safeguards.
The government guidance says: “You can carry on receiving your UK state pension if you move to live in the EU, EEA or Switzerland, and you can still claim your UK state pension from these countries. Your UK state pension will be increased each year in the EU in line with the rate paid in the UK.”
If you are receiving a private pension, such as an annuity, from the UK but are resident abroad, the government says you should contact your provider. But in general it says: “UK law allows for workplace pensions to be paid overseas. The government does not expect this to change because the UK has left the EU.”
However, there may be issues about the bank account into which your pension is paid. The Pensions Advisory Service says that although practice varies, pension schemes and annuity providers do not typically pay pension benefits directly into an overseas bank account, leaving the individual to transfer the money from a UK bank account – which will result in transfer fees and exchange rate fluctuations.
More importantly, if you are resident overseas, there is a risk that your bank may close your UK account. In that case, you will need to contact the pension provider to ensure that it can pay the money into an overseas account.
So can I keep my UK bank account? Thousands of Britons resident in the EU were told in September that they would have their UK bank accounts closed by the end of the year. UK banks have been operating across the EU under passporting arrangements. Account holders who bank with firms that own an EU-based subsidiary will have their accounts transferred to that EU entity. But where that is not the case, accounts are likely to be closed.
The Netherlands is particularly affected, with Lloyds Banking Group, Nationwide and the Co-operative Bank withdrawing services. The Lloyds group, which includes Bank of Scotland and Halifax, is also closing accounts in Germany, Italy, Portugal, Ireland and Slovenia, and Nationwide will no longer serve Italy. Barclays is closing accounts for customers in Belgium, Estonia, Italy and Slovakia, and Barclaycard accounts across the EEA will be closed unless linked to a UK address. While Santander customer accounts remain open, the bank is not taking on any new requests from EU-based customers.
What does this mean for my payments in and out of the account? If you used your account to run direct debits for bills in the UK, there is no obvious solution other than to check with other banks to see if you can switch to a new account, according to Robert Hallums, of the advice consultancy Experts for Expats. Some pension providers may accept transfers from a currency account such as the Moneycorp online currency account, which converts payments and receipts into the desired currency without large fees or currency fluctuations. You can also use this kind of account to pay bills in the UK or receive rental income. In the worst-case scenario, you may need to consider paying it into a local bank account and accept the higher costs of currency exchange rates and fees.
Will £85,000 of my savings still be protected? The Financial Services Compensation Scheme will still pay out the first £85,000 of your balance if your bank collapses, provided it is regulated by the UK’s Financial Conduct Authority.
All Rights Reserved for Patrick Collinson and Miles Brignall