Brexit and its impact on social security

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Two months after the end of the transition period during which the UK remained subjected to EU laws, what are the implications with regard to EU citizens who work, travel to or move to the UK and UK citizens who work, travel to or move to the EU since 1 January 2021?

As we all recall, after months of intense negotiations, the UK and the EU reached an agreement of cooperation starting 1 January 2021. This agreement is currently in force on a temporary basis, until it is approved by the European Parliament (at the latest on 30 April 2021). In terms of social protection, the Agreement draws on most of the provisions of Regulation (EC) No 883/2004.

Consequently, the principle of unitysecondment (within a 24-month limit) and pluriactivity remain in force. Member States were required to specify whether they intended to maintain the provision on secondment, which is something that all Member States have now confirmed. However, please note that the Agreement does not provide for extraordinary derogations (in particular for secondments exceeding 24 months).

Regarding EU citizens working in the UK or UK citizens working in the EU under a local contract, no matter the contract’s start date, the applicable rules remain unchanged. They will continue to be affiliated to the social security system of the country in which they carry out their activity.

For British citizens working under a local contract in France, the CNAM (French Social Security body) has recently issued a circular that specifies the documents required in order to be affiliated to French Social Security.

When staying in the UK (for EU citizens) or in the EU (for UK citizens), European Health Insurance Cards (EHIC or CEAM in French) remain valid until expiration of the card. 
French citizens who do not have a CEAM will have a temporary certificate of replacement issued.
British authorities have recently launched the GHIC (Global Health Insurance Card) which will replace expired EHICs.


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