EU Citizens in the UK: Key documents for Cross-border Work, Pensions, Healthcare and Social Security


 For EU Citizens from other EU states and for UK Nationals there are key documents that enable them to move back and forth from the UK to the rest of the EU and to move around other EU and EEA states (including Switzerland) in the ordinary course of their working lives and after. These documents concern temporary work in another country, moving to work and reside in another country, pension entitlements where a person has worked in more than one country, healthcare entitlements, and social security entitlements.

These documents are separate to and different from immigration residence permits, settled status documents, registration certificates and the like. In addition, they do not depend on whether a person is a national of one country or another. A UK National who is employed by a law firm in London who is posted to the firm’s Rome office may need the same document as a self-employed Italian journalist resident in London but who works in Rome for six months while investigating a story. The EU Regulation 883/2004 provides for the co-ordination of rights and entitlements as regards social security, pensions and healthcare. These key documents help people to assert their rights and entitlements under that Regulation.

Working in another country: Form A1

 The A1 is for EU Citizens and UK Nationals living and working in the UK but who work in another EU/EEA states for not more than 24 months (2 years). It can be shown to the authorities in the country in which the person is working temporarily to that the holder is paying social security contributions in the state in which she normally resides. In showing the document the UK-based A1 document holder proves that she is paying national insurance contributions in her home state (say the UK) even though she is working temporarily elsewhere (say Italy). Remember her nationality is irrelevant in this example. She could be a British citizen, an Italian national, or even a French citizen. What matters is that she is UK-based and working temporarily elsewhere in the EU/EEA.

Employees (and their employers) residing in the UK can obtain an A1 here.

For the self-employed residing in the UK the A1 may be obtained here.

Self-employed people often forget to obtain this form when working on short-term projects in other EU/EEA countries, not least when working back in their country of nationality. However, such persons may be fined or questioned in the host country if they do not have this form, even though they are paying national insurance in the UK. The form is required while the UK is in the EU and, subject to the ratification of the UK-EU Withdrawal Agreement, will continue to be needed by all those who fall within its scope.

For people moving between the UK and the EU/EEA for the first time after the end of the transition period, the position is not clear. There may be a future status agreement between the UK and the EU that provides for the continuing co-ordination of social security, pensions, and healthcare arrangements, or there may be a No Deal scenario where no similar arrangement applies.

What about my Pension? Form P1

 This is the form that shows the pensions decisions taken by the various EU counties in which a person has worked. If you have worked in the UK, Italy, and Greece for example, it will show your pension entitlement in all three countries. For UK-based  EU Citizens and UK Nationals who have lived and worked in other EU/EEA countries, contact the International Pension Centre here.

What if I become unemployed? Forms U1 and U2

 On occasion, an unemployed person who moves to another EU/EEA state (including the UK) to look for work, can received an unemployment benefit from the country in which she last worked, while job-seeking in the new state. Periods of work in another state may also be taken into account when calculating entitlement to a contribution-based unemployment benefit in the host state.

Form U1 sets out the periods of national insurance to be taken into account when calculating unemployment benefit. It is issued by the last country or countries in which a person worked and should be submitted to the authorities in which a person wishes to claim the benefit. For more information click here.

Form U2 is the authorisation issued by one country that enables a person to receive that country’s unemployment benefit while working in another country. It is issued by the last country or countries in which a person worked before becoming unemployed and should be submitted to the authorities in which a person wishes to claim the benefit.  For more information click here.

There is a Form U3 as well. It informs the country paying the unemployment benefit of changes to the beneficiary’s situation that may lead to a revision to the payment.

What about my healthcare when working temporarily in another EU/EEA country or when retired there as a Pensioner? Form S1

 The S1 form used by posted workers, cross-border workers, pensioners, and civil servants. It can be used by both employed and self-employed UK-based EU Citizens and UK Nationals working in another EU/EEA state on a short-term basis (not more than 24 months). It allows for healthcare to be provided in that other EU/EEA state at the expense of the UK. It provides for better healthcare coverage than a UK-issued European Health Insurance Card (EHIC). For more information on how to obtain one if you are employed or self-employed and will be working in another EU/EEA state for not more than 24 months, click here.

Pensioners entitled to a UK pension but resident in another EU/EEA state also get a healthcare entitlement in the country of residence at UK expense and require an S1 to do so. For more information about an S1 for pensioners click here.

There is Form S2 as well. It covers planned healthcare treatment in another EU/EEA state.

There is a Form S3 as well. It is a certificate of entitlement to healthcare in the country of former employment. It is useful for cross-border workers no longer otherwise publicly insured for healthcare in their country of former employment.

There is a Form DA1 as well. It entitles a person to receive medical treatment in another EU/EEA country under conditions arising from an accident at work or occupational disease.

Temporarily staying in another EU/EEA State: the European Health Insurance Card (EHIC)

 If a person is UK-based and insured in the UK for healthcare (e.g. by paying national insurance), a UK EHIC card will enable that person to obtain healthcare in the EU/EEA state in which she is temporarily staying. The EHIC card is the card used by tourists and those staying for short-term purposes on other EU/EEA states.

UK-based EU Citizens and UK Nationals who are self-employed or employed temporarily in another EU/EEA state should remember that an EHIC Card does not provide the same level of healthcare coverage as Form S1. Even if they have an EHIC Card, they should  obtain and use a Form S1 as well when working temporarily outside the UK.

For more information on how to obtain a UK EHIC card, click here.

One comment

  1. […] – New articles were published on the UK in a Changing Europe website, including the following – “Getting Brexit done” – the hard work starts now; How will government change post-election?; State aid after Brexit; Defence is another reason for Britain to leave the EU– A new article was published on the Cosmopolis blog – EU Citizens in the UK: Key documents for Cross-border Work, Pensions, Healthcare and Social Security […]


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