What you need to know if you live and work in Spain, France or other EU country after Brexit

Living and working in the EU depends on the rules of the individual country

Living and working in the EU depends on the rules in that country and here we take a look at three of the most popular EU countries for ex pats - France, Spain and Germany.

You can check this website for more information and click on the country where you live.

You may need to register or apply for residency and you should also check that you are covered for healthcare.

You may also need to exchange your UK driving licence for a licence issued by the EU country where you live.

The government describes how the Withdrawal Agreement provides "certainty" to UK nationals resident in the EU that you "will be able to continue to live your lives broadly as you have done so far after the end of the implementation period".

It means if you are studying, working or retired in EU countries, during the implementation period you will be able to continue to do so.

You will also be free to move to live in another EU country should you wish.

But you may need some form of registration in EU countries once the UK leaves.

France

If you have applied and your residency application has been refused, or you think it has been handled incorrectly by your préfecture,  contact British Embassy Paris.

Many people are choosing to wait and apply to the post-Brexit system, which should be simpler and easier to complete.

After Brexit, whether you have obtained a European carte de séjour or not, all UK nationals resident in France will need to obtain a new type of residence permit relevant to their situation to claim their rights.

You will be able to apply for the new residence permit via an  online portal, which is currently being updated, although live in an initial trial phase.

If you are resident in France before the end of the implementation period on 31 December 2020, you will be able to stay.

Read the French government’s  guidance on residency rights (in English).

You must register for healthcare as a resident in France, and in addition, you can sign up for top-up health insurance (mutuelle).

If you are legally resident in France, you can get a French social security card for healthcare (carte vitale).

To get a French social security card, you will need to register with your local Caisse Primaire d’Assurance Maladie (CPAM).

They can tell you which documents they need for your registration.

There will be no changes to your healthcare access before 31 December 2020. You can also continue to use your EHIC, as you did before, during this time.

If you’re living in France or move there permanently before 31 December 2020, you’ll have life-long healthcare rights in France as you do now, provided you remain resident.

Spain

You should register as a resident in Spain and register for health care as a resident in Spain and exchange your UK driving licence for a Spanish one.

And you must register as a Spanish resident if you want to stay in Spain for more than 3 months.

You will get a green A4 certificate or credit card-sized piece of paper from Extranjeria or the police. If you are resident before the end of December 31, you will be able to stay.

You must  register for healthcare as a resident in Spain.

If you live in Spain and receive an exportable UK pension, contribution-based Employment Support Allowance (ESA) or another exportable benefit, you may currently be entitled to state healthcare paid for by the UK.

You will need to apply for a certificate of entitlement known as an S1 certificate.

If you are entitled to an S1, you are also entitled to apply for a UK-issued EHIC.

If you are not an S1 holder, but are registered for public healthcare in Spain in another way and are travelling outside of Spain, you must  apply for a Tarjeta Sanitaria Europea (TSE - a Spanish-issued EHIC) online (in Spanish), or go to your nearest  social security office (Insitituto Nacional de la Seguridad Social).

You must also buy comprehensive travel insurance to cover anything not covered by your TSE, EHIC or for travel to countries outside the EU.

If you are resident in Spain, you must not use your EHIC from the UK to access healthcare in Spain.

If you are resident in Spain,  exchange your UK licence for a Spanish one. You can still use your Spanish licence in the UK for short visits or exchange it for a UK licence without taking a test if you return to live in the UK.

If you hold an old UK licence that doesn’t have a 10-year validity period, you must renew or exchange it for a Spanish licence once you’ve been a resident in Spain for two years.

Germany

Register as a resident in Germany, oncluding registering at your local registration office and applying for a new residence permit

• Get your professional qualifications recognised

If you are resident in Germany before the end of the implementation period on 31 December 2020 you will be able to stay.

To confirm your rights under the Withdrawal Agreement and stay after the end of the implementation period, you must  apply for a new residence permit from your local Foreigners Authority (Ausländerbehörde) after Brexit.

You will need a valid passport when applying for a residence permit.

The German authorities have not yet confirmed the new residency application processes after Brexit.

The government will update this guidance as soon as information is available.

UK nationals will be able to continue to move to Germany during the implementation period, as now.

If you are permanently resident in Germany, you may be able to  apply for German citizenship (in German).

The UK has no restrictions on dual nationality. Germany only allows dual nationality in exceptional cases.

As a resident in Germany, you must register with a health insurance company (Krankenkasse) to access healthcare. This is usually done through your employer. Ask your employer’s HR department for more information.

Read the German government’s  guide on social security in Germany.

You are able to choose your  health insurance provider (in German) and in some cases you can choose private health insurance (private Krankenversicherung) instead of the standard statutory health insurance (gesetzliche Krankenversicherung).

If you are a resident in Germany, you must exchange your UK licence for a German one within 6 months of moving to Germany. You can still use your German licence in the UK for short visits or exchange it for a UK licence without taking a test if you return to live in the UK.