Expat Essentials

No deal, no problem (updated): More EU countries guarantee British expats post-Brexit grace periods

(Editor’s note: It‘s clear the British Parliament doesn’t want Prime Minister Theresa May’s deal, nor do they want a no-deal Brexit. With the original Brexit Clock down to 4 days, British officials are trying to figure what they do want while the EU grants a delay to either 12 April or 22 June, depending on what happens this week.  Meanwhile, countries across Europe are taking proactive measures to make sure British expats – and EU citizens living the UK – don’t become hostages in the political maneuvering.)

As the United Kingdom moves inexorably toward a no-deal Brexit, an increasing number of countries across the European Union are assuring British expats that life will go on as normal. Well, at least for a few months.

This comes after the European Commission asked  – but decided not to order – member states to grant temporary residence permits to British nationals so they’ll have time to apply for long-term residency status. Germany and Italy already notified their British expats at the end of 2018.

Questions remain as to which former EU residence rights each country will extend to British citizens, who instantly become third-country nationals at the strike of midnight on 29 March. If you’re an American in the Netherlands, for example, you have specific rights under the Dutch American Friendship Treat.

But a no-deal Brexit would push British citizens into a neither-nor purgatory where they would neither have EU citizenship status nor a separate post-Brexit immigration status.

What a lot of people – especially British politicians – don’t seem to understand is that no-deal means no transition time to implement new treaties.

In EU countries, reciprocity is becoming key to all expats’ fates, with Spanish authorities saying British expats will have the same rights in Spain post-Brexit as long as the UK extends residency rights to Spaniards in the UK.

So while British expats will be able to remain where they are living in Italy, the Netherlands and other countries, they will lose the right to move – or even travel – within the Schengen Area until the UK can draw up separate reciprocal long-stay residence agreements.

AUSTRIA

Austria has posted details of how British citizens living there should prepare for a no-deal Brexit.

That includes a “special legal regulation” allowing British nationals to obtain a residence permit under the Settlement and Residence Act (Niederlassungs- und Aufenthaltsgesetz) with free access to the labor market, according to the official federal residency website.

If you’ve lived in Austria  (and they always state “legally,” though that’s a given) for less than five years, you’re eligible for a ‘Rot-Weiß-Rot – Karte plus’ residence permit.

If you lived there more than five years, you’re eligible for a permanent residence status (‘Daueraufenthalt – EU’).

Please check out all the details on the website.

About 10,000 Brits live in Austria.

BELGIUM

Belgium has assured its British expats they can stay in place in the event of a no-deal Brexit. But again, Belgium’s offer is based on reciprocity.

That said, former Belgian prime minister and current member of the EU Parliament Guy Verhofstadt said he wants to see Belgium’s assurances become an EU-wide policy, with all member nations assuring Brits they won’t be loaded onto planes and flown back to Blighty on 29 March.

There are about 25,000 Brits in Belgium, most working ironically for the EU, or at Belgium-based multinationals such as AB InBev.

BULGARIA

Bulgarian officials have launched an English-language page on its Interior Ministry website laying out their Brexit policy.

If the UK leaves with some sort of deal, Brits living legally in Bulgaria as of 29 March will have until the end of 2020 to re-register as third-country nationals rather than EU citizens … as long as the UK offers a reciprocal deal for Bulgarians in the UK.

In the event of a no-deal Brexit, there will be no transition period, though the statement is confusing and contradictory. But it’s clear one way or the other, all British expats will have to register as third-party residents, which is true in most EU countries.

There are about 5,000 Brit living in Bulgaria, mostly business executives and tech entrepreneurs.

CYPRUS

Cyprus is the latest to EU member state (a member since 2004) to officially sign on the list of countries giving British expats a grace period. “Cyprus stands ready to ensure that those British citizens residing in Cyprus presently, and until 29 March 2019, will be able to continue residing and enjoying the same rights as provided for in the (Plan B) withdrawal agreement,” Cypriot Foreign Minister Nikos Christodoulides wrote in a letter to UK Foreign Secretary Jeremy Hunt, according to media reports.

Christodoulides didn’t specify how long they’d be allowed to stay at the time. but British officials posted on Facebook that it will be a year.

By the way, we were shocked to learn that about 60,000 Brits live in Cyprus, according to the Institute for Public Policy Research.

The other side of the island is the Republic of Nothern Cyprus … only recognized by Turkey, which is not an EU member.

CZECH REPUBLIC

Emerging Europe is reporting the Czech government has proposed legislation that will allow British citizens to remain through 2020 post-Brexit.

Only about 7,000 British citizens live in the Czech Republic, but about 40,000 Czech citizens live in the UK. “We are, of course, counting on there being a reciprocal move,” Emerging Europe quotes Czech Prime Minister Andrej Babiš as saying.

DENMARK

Danish government officials just released an official statement this month saying they were hoping the UK Parliament okays May’s Plan B. It didn’t. BUT, presciently, the statement adds officials are preparing for “all possible outcomes of the negotiations” including a no-deal exit. That includes guaranteeing residence documents already been issued in accordance with EU free movement rules will be valid for “a transitional period” though it doesn’t say how long that might be.

If you are a British citizen in Denmark but do NOT have an EU registration certificate (issued for EU citizens) or an EU residence card (issued to third-country nationals) you must submit a registration certificate application before 29 March 2019.

You can see the full statement here.

There are about 2,000 British expats in Denmark.

EEA EFTA COUNTRIES

Britain and the EEA EFTA countries –  Iceland, Liechtenstein and Norway – reached a no-deal Brexit agreement back in February. The reciprocal agreement guarantees the right to remain of EEA EFTA citizens living in the UK and British citizens living in the EEA EFTA states. Norway is home to about 30,000 British citizens, most of whom work in the petroleum industry.

ESTONIA

Pending reciprocity from the UK, Estonians are basically giving British expats till 2021 to figure it all out. No matter what happens including a no-deal Brexit, UK citizens will be able to continue living in Estonia.

In the event of a “hard” Brexit, Estonia’s Aliens Act will apply to the citizens of the UK as of 11 p.m. on 29 March. BUT, the Estonians are granting them temporary residence permits for settling permanently – valid for up to five years – or a long-term resident’s permit, depending on whether they have temporary status or rights of residence.

“All UK citizens who wish to settle in Estonia after the withdrawal of the UK from the EU will have to apply for a residence permit like all other citizens of third countries,” the statement added.

If the current deal struck with the EU somehow passes against long, long odds, British expats would stay under “right-of-residence, without anything changing in two years,” according to legislation passed earlier this month.

Brits arriving in Estonia after April 2021 “would already fall within the scope of regulation of the Aliens Act, which means they will require a residence permit for living in Estonia like all other citizens of third countries.”

FRANCE

The final French policy doesn’t appear to actually be final and might be contested in the French courts. But so far, post-Brexit terms are not great.

In the Ordonnace published last month, British citizens have three months after 29 March to stay and work without a residence permit. During that time, they have to apply for a residence card under third-country status. (Be sure you have your immigration lawyer by your side as you work your way through the new rules, which are incredibly long and written in masterfully vague boilerplate.)

To complicate things, the French law has multiple categories. If you’ve been living in France legally for five years or more, you eligible to apply for a long-stay residence visa. But of course, you’ll have to prove you have substantial assets and health care policies and won’t be a drain on the French social services. But the new law doesn’t give any details.

Other categories include rules for students and others. And by the way, the Ordonnance can be torn up if UK officials don’t offer French citizens the same rights.

Expat group Remain In France Together reports that municipalities are already struggling to deal with processing the paperwork as an estimated 200,000 British expats try to apply for various long-stay visa options. See RIFT’s detailed post here.

GERMANY

Wait … did we say “… no problem”? Because here’s a big one: Germany is going all Hotel California on expats. You can check out any time you like, but you can never leave.

Berlin correspondent Laura Kaye sent us a screenshot of the notification she got back after filling out her residency title. And as you can see, the fourth bullet point in the reply states expats can stay, but if they travel to another country, they can’t come back. Which we’re thinking could be incredibly inconvenient for executives who travel on business.

Or any expat, really, who has a legitimate need to leave Germany.  More as we know more.

Here’s what we posted earlier this month.

Berlin officials have issued a notification that clarity on Brexit is lacking. “Whatever happens, British citizens will in future require a residency title or some other proof of their right of residency in order to reside in the territory of Germany,” according to a news release posted on Berlin.de. Starting 30 March, British citizens in Germany will get an initial 3-month transition period through 30 June 2019 to get that German residency title. So all British citizens have several months to apply for residency title at their local Foreigners Registration Office, and you can stay in Germany and keep working till you get a ruling on your application. But after 30 June, British expats will have to prove their right to stay, which we interpret as an employment contract or one of the visas for self-employed freelancers and entrepreneurs.

Brits will also lose certain benefits including new-parent allowance. (See the full post here.)

Germany has at least 100,000 British expats, most of whom are either corporate nomads, or who are married to German nationals. There are about 16,000 Brits in Berlin alone, the largest expat community in Germany’s capital city and most popular expat destination.

GREECE

At the 31-day mark, the Greek government took live a website with detailed Brexit plans.

The website has information based on two scenarios: The UK leaves the EU with a deal, and the UK leaves without a deal.

From the website:

Will it be necessary for British nationals to obtain a residence permit? What will be the steps to take to obtain a residence permit?

• If the Withdrawal Agreement enters into force: UK nationals living in Greece before 31 December 2020 will have to apply for the new title required for in the Withdrawal Agreement (see WA Article 18). They will be able to make the request according to terms and a schedule that will be specified later.

• In case of no deal (absence of withdrawal agreement): UK nationals permanently living in Greece before 29 March 2019 and already in possession of a registration certificate (βεβαίωση εγγραφής) or a temporary or permanent residence document(πιστοποιητικό έγγραφο άδειας διαμονής), will be asked to proceed, after 1 January 2020, to the municipal authorities and submit the relevant paperwork, in order to exchange their certificates with new biometric resident cards. A draft bill is currently being prepared on British citizens’ rights in Greece that may include provisions on this issue. Details will be communicated via this website soon.UK nationals living in Greece before 29 March 2019 but not registered with the police authorities, may need to apply for a registration certificate. After acquiring their registration certificate they will also be asked to proceed to the municipal authorities to submit the relevant paperwork and acquire their biometric resident cards. A draft bill is currently being prepared on British citizens’ rights in Greece that may include provisions on this issue. Details will be communicated via this website soon.

The website is fairly detailed and well-organized.

Brits can still apply for residence permits as usual. They can also apply for citizenship after living in Greece for seven years. That might be lowered to five. If a Brit buys a house for 250,000 euros or more, residency is guaranteed, as is citizenship. You can see a full post about moving to Greece here.

About 45,000 British expats live in Greece full-time and contribute heavily to the economy.

– Lynne Evans in Athens

ITALY

Expat group British in Italy members say they’ve been assured by Italian officials they’ll be allowed to remain in Italy after 29 March, 2019. That includes an initial transitional period of up to 9 months during which all British expats will be allowed to stay, then re-register as Third-Country Nationals.

You can see the full details on the British in Italy website here.

Italian officials are discussing (still) legislation to grant a grace period of 6-to-9 months (or longer) to move to a third-country national status. British citizens legally resident in Italy on 29th March 2019 would keep most of their existing EU rights during the grace period. The grace period will apply to British nationals who have, by March 29th, registered or applied to register their Residenza or Soggiorno Permanente.

There are an estimated 25,000 British expats living in Italy.

LATVIA

Latvia just formalized its Brexit policy on 21 March.

If a deal – any deal – with the EU is approved, EU law will continue to apply to British citizens, who will be able to continue living in Estonia on the basis of right of residence for the next two years. British expats arriving in Estonia after April 2021 would fall under the Aliens Act, and will need to get a residence permit like all other citizens of third countries.

In the event of a no-deal Brexit, the Aliens Act will apply immediately.

From the official statement:

In such a case, the (new) act will grant them a temporary residence permit for settling permanently in Estonia, with the period of validity of up to five years, or a long-term resident’s residence permit, depending on whether they live in Estonia on the basis of temporary or permanent right of residence at the Brexit moment. 

Last month, Latvian and British officials reached an informal gentleperson’s agreement allowing each country’s expats to remain in place even if there’s a no-deal Brexit. At the time, Foreign Minister Edgars Rinkēvičs said he was still concerned about reciprocity for Latvians in the UK.

(Editor’s note: Thanks to Joanna Storie in Latvia for the update.)

LUXEMBOURG

In perhaps the wordiest formal declaration of all the EU countries, Luxembourg is giving British citizens one year – until 30 March 2020 – for a transition in the event of a no-deal Brexit. By that date, all Brits must have a residence permit of some sort. (The deadline to apply for a residence permit is 30 December 2019.)

Details to follow at www.guichet.lu, the government’s official website.

MALTA

With its strong ties to the UK, Malta acted quickly and generously to assure Brits of their right to remain. Malta will grant UK citizens full residency permits good for 10 years even if there’s no deal.  Unlike other EU countries, there doesn’t seem to be any reciprocity demand for Maltese citizens in the UK. So done deal … an estimated 15,000 British expats get to keep on living in Malta as if they’re still EU nationals.

THE NETHERLANDS

The Dutch government issued a statement on 7 January that, in the event of a no-deal Brexit, British citizens and their families “who are lawfully resident in the Netherlands prior to 29 March” will be entitled to live, work and study in the Netherlands for at least another 15 months. This transition applies to family members of British citizens who aren’t EU citizens according to the statement. So, British expats in the Netherlands are good to go for more than a year during which time surely something concrete will happen.

There are an estimated 45,000 British citizens living in the Netherlands.

PORTUGAL

British expats hoping to stay post-Brexit must sign up for a temporary registration certificate or a permanent residence card if they’ve lived in Portugal for more than five years.

If Britain crashes out on March 29 without a Brexit deal, only those already resident will have a legal right to stay.

This if from the government’s “The United Kingdom Nationals Keep their Right of Residence” notice pdf, posted last November:

IN CASE OF A NO-DEAL SCENARIO

As there would be no agreed implementation period, the guarantee to acquire the right of permanent residence would only apply to UK nationals who are resident in Portugal by 29 March 2019; all those UK nationals and their family members who are already in Portugal by that date would have until 31 December 2020 to apply for a registration certificate.

As we’ve mentioned so often before, Portugal has a liberal “Golden Visa” program that allows foreigners to stay permanently AND travel within the EU. Portugal requires a minimum investment of 350,000 euros, and there are lots of options.

Politico.eu has an interesting Brexit-related post on the Brits pouring a remote region of Portugal that has been losing population for years.

There were about 50,000 British citizens living in Portugal, but there are indications that number has risen even in the past few months.

REPUBLIC OF IRELAND

The border between the Republic and Northern Ireland is crucial to whether there is a no-deal Brexit. Hardline Brexiteers want to bring back a hard border with passport and customs checks; everyone else thinks that would be a violation of the Good Friday agreement and rekindle The Troubles.

That’s just one issue. As the Republic of Ireland is in the EU, it’s being inundated by British people seeking a second passport to keep their freedom of travel/migration. The Irish Times is reporting that the number of Republic passport applications by British citizens has risen to about 92,000 in the past 11 months from 46,000 in 2015, overwhelming the embassy passport services in London. About 4.4 percent of the 1.2 million UK citizens living across the EU have the family links back to Ireland that make them eligible for Irish passports, according to the Times post.

SPAIN

Did you hear a huge sigh of relief on 1 March? That was the sound of 300,000-plus expats getting word Spanish officials have finally come out with a definitive no-Brexit policy: Everyone gets to stay in the EU country that’s home to the most British citizens.

Spain’s cabinet approved legislation for an estimated 400,000 Brits living in Spain remain in place if the UK leaves the EU without a deal. And under a reciprocity agreement, 150,000 Spanish citizens would remain in the UK. Spanish Prime Minister Pedro Sanchez said in December that Brexit won’t change the status of British citizens in Spain … as long as the UK extends reciprocity to his citizens.

Under the plan, Britons living in Spain will have to apply for a foreigner identity card before 31 December 2020 to prove their legal residency status. The process would be “nearly automatic” for those UK nationals who already have permanent residency, according to media reports

There are a few uncertainties because the actual number of Brits in Spain is closer to 1 million, many of whom have homes there where they live only part of the year. That said, Brits in Spain hold a strong hand, injecting about 1.32 billion euros each year just into the economy of Alicante, where more than 25 percent of them live, according to Forbes.

SWEDEN

Swedish officials have talked about giving UK citizens a one-year extension with no change in residence status in the event of a no-deal Brexit, according to Reuters.  The waiver is to give Brits time to negotiate the paperwork of applying either for a third-country national residence permit or citizenship.

But Beyond Plan B. and an orderly exit, the government’s official website here doesn’t commit to anything related to a no-deal Brexit other than to state the obvious: “Contingency planning to handle such an eventuality therefore needs to be in place.” That said, the Brexit website states that Brits in Sweden would be given the conditions” to continue to live and work in Sweden and have access to social security, health and medical care and education. It just doesn’t specify how long. And as with every country, Sweden’s policy is built on reciprocity.

There are about 30,000 British expats in Sweden.

SWITZERLAND

Oh, the ignominy.

British citizens are about to join expats from Syria and Libya at the back of the line. Switzerland is instituting a quota system that will limit the number of Brits coming to work to 3,500. At first we thought this was The Onion.

But we found the Swiss official statement which says (emphasis ours):

As part of its ‘Mind the Gap’ strategy, the Federal Council decided at its meeting on 13 February to introduce a separate quota as a temporary measure, allowing 3,500 British citizens to work in Switzerland. This is intended to mitigate the consequences for the economy and the cantons of an abrupt change in the status of British citizens from persons benefiting from freedom of movement to third-country nationals; it will also prevent undesirable competition for jobs between British citizens and other third-country nationals.

You can read the full release here.

The quotas would not apply to the  42,000 or so Brits already living in Switzerland, just new people trying to enter the Alpine paradise to work.

The release goes on to say “it should be possible to recruit a total of 3,500 workers from the UK: 2,100 residence permits (B) and 1,400 short-stay permits. This will guarantee the flexibility that the Swiss economy needs.” It’s not clear whether the 42,000 number will be a benchmark, or if the total falls below that, new visas will be issued.

The good news (sort of) is that there are talks are underway that might lead to Swiss officials lightening up a little bit on the Brits. (Can you say, “Kicking them while they’re down?”) This is also a harbinger of bad things to come because while Switzerland isn’t an EU member, it observes many of the EU rules and regulations. So if this is happening in Switzerland, then it could happen in other non-EU countries with large British expat populations.

OTHER COUNTRIES

Croatia, which has a substantial number of British expats, hasn’t issued any formal, final post-Brexit policy about their future status.

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