Expat Essentials

No deal, no problem, Pt. 2: More EU countries guarantee British expats post-Brexit grace periods

(Editor’s note: We’ve broken up the original “No deal, no problem” post into two parts so it will load faster. This post includes Spain and other expat centers. You can see Pt. 1 here.)


CliffsNotes Version: (Updated) Luxembourg is a constitutive system. British nationals legally residing in Luxembourg before the end of 2020 can apply for a new residency card, and will have until 31 December to do it after Luxembourgish officials extended the compliance period. Current residency permits are still valid.

But if you wait after 31 December, expect a rush … a rush that might mean you have to wait for the residency card. Which means you won’t be able to leave Luxembourg and return as anything but a tourist.

The number of British expats in the Grand Duchy is rising because Luxembourg has turned out to be the “surprise” winner in the contest to lure financial operations from The City, according to Financial Times. Luxembourg has landed at least 72 companies, about the same number as Ireland and more than twice as many as France and Germany.

The Whole Story: British nationals who fall under the Withdrawal Agreement have the same rights as EU citizens and their family members and keep these rights even after the end of the transition period.

Brits in Luxembourg have to reapply for their residence status if they want to maintain their rights under the Brexit withdrawal agreement once the UK has left the EU. You can do that here. Luxembuorgish officials previously said Brits wouldn’t have to apply for biometric residency cards, but now are requiring them to reapply by 31 December.

So you might want to monitor the official government website to see other zig-zags.

Here’s the official government website.

Here’s the link to the Luxembourg page on the new GOV.UK website.


CliffsNotes Version: Malta is a constitutive system.

With its strong ties to the UK, Malta acted quickly and generously to assure Brits of their right to remain before the withdrawal agreement. But now that it’s in effect, Maltese officials are suddenly less generous.

The Whole Story:

As in all of the EU, when you arrived in Malta matters. If you lived in Malta for at least five years before 31 December, you have to apply for a new biometric residence status by 30 June. With that card, you and your family members will be exempt from ETIAS and visa requirements when entering Malta.

You can see the details here including an application portal.

If you lived in Malta for less than five years before the end of the transition period, you win a prize … an all new status as a third-country national who must apply for residence status.

Unlike other EU countries, there doesn’t seem to be any reciprocity demand for Maltese citizens in the UK. So maybe it’s a done deal … an estimated 15,000 British expats get to keep on living in Malta as if they’re still EU nationals.

Here’s the Malta page on the new GOV.UK Brexit website.


CliffsNotes Version: The Netherlands is a constitutive system but is observing the rules under the withdrawal agreement. If you want to stay after 31 December, you’ll need a residence document.

The Dutch immigration service stood up a very complete website with up-to-the-minute details including a newsletter. The Netherlands is the first country to extend the deadline to register. It’s now 1 October.

The Whole Story:

As of mid-June, about 3,000 Brits living in the Netherlands have yet to register.

On Brexit Day 2020, British citizens registered in the Netherlands received a letter from the Dutch Immigration Service outlining the terms of the withdrawal agreement including:

• after the transition period, they’ll need to have a new residence document no later than 1 July to stay in the country. Most Brits have received an invitation to apply. The application cost is 58 euros for adults and 31 euros for children under 18 years old.

• you must wait for the invitation because the Dutch, being the methodical people they are, know they can’t get all 45,000 Brits registered at the same time. From February through June, the IND has sent 22,010 invitation letters to UK nationals living in the Netherlands, with 15,278 Brits submitting applications for a residence document. To date, the IND has decided on 10,072  applications.

this is really important – if you already have a permanent residence document as an EU citizen, you’re going to need to change it – free of charge – for a new document. Again, you’ll get an invitation via post.

Find out here what those conditions are.

Read this updated Dutch information carefully here. Brits in the Netherlands are going to have some big decisions to make moving forward.

Here’s the Netherlands page on the GOV.UK Brexit website.

NORWAY (new)

CliffNotes Version: Brits already living in Norway must apply for a new residence permit by the end of 2021. If you’re British and never registered, and you want to leave the country, make sure you have some proof of residence, including tax documents, in case you get hassled coming back in.

The whole story: In Norway, the song remains the same – if you already had a residence permit, you’re good to go. You just need to trade it in for a new one by the end of the year. If you’re arriving post 31 December 2020, you’re a third-country national who has to go through the whole immigration rigamarole.

Here’s a helpful FAQ website.

POLAND (new)

CliffsNotes Version: Poland is a declaratory system. Poland passed multiple bills in March 2019 including one applying to British businesses, one applying to recognizing professional credentials and one addressing the residency rights of UK citizens. Bottom line: Brits get 12 months from Brexit to get a temporary residence permit and/or apply for a permanent residence.

All British citizens who’d been living and working in Poland get to stay. UK nationals will be able to exchange residence permits issued to them as EU nationals for documents certifying their rights under the Withdrawal Agreement, or obtain such residence permits if they did not have one before. New docs will be issued by the voivodeship offices.

You can see more info on the Polish Office for Foreigners website.

The Whole Story: Poland, more than any other EU states, is adamant that the UK honor reciprocity and give Polish citizens and businesses in Great Britain (and there are many of both) the same deal they are extending to the Brits. Which is an on-going conversation.

You can see a thorough legal explanation here at the National Law Review.

Here’s the Poland page on the new GOV.UK Brexit website.


CliffsNotes Version: Portugal is a declaratory country. With a deal, British citizens in Portugal need to start the process of exchanging old EU documents for new documents establishing residency.

The new portal for starting the process is here. And see the video above that walks you through the process. Since 1 January, the Portuguese immigration service are contacting UK nationals registered on the portal to schedule an appointment at one of the 38 town halls. This is when they provide their biometric data for the new identification card.

To obtain residency, you must have a registered address, proof of financial support (though this is vague) and have access to healthcare.

Here are the details.

The Whole Story: 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.

Here is “The United Kingdom Nationals Keep their Right of Residence” notice .pdf, posted last November.

As we’ve mentioned many, many times 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.

Here’s the link to the Portugal page on the new GOV.UK Brexit website.

And by the way, Portugal is one of the countries where British expats have received notice their banks will be closing their accounts because “passporting” is ending and with it London-based financial institutions’ rights to do business in the European Union.


CliffsNotes Version: All systems go. Ireland is a declaratory country.

The Whole Story: On 8 May 2019, the Brits and the Irish finally inked an agreement that – aside from border issues – codifies continuity.

The new agreement assures Irish citizens in the United Kingdom and British citizens in the republic that everything will remain the same, from rights to residency to insurance and pensions to the right to run in local elections, or even for the British parliament.

(Because of historic ties and the Common Travel Area, the Irish in Britain enjoy rights closer to full citizenship in the UK, according the Guardian.)

About 300,000 Brits live in the Republic, and about 350,000 citizens of the Republic live in the UK.

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 reported 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.

Here’s the link to the Ireland page on the new GOV.UK Brexit website.

SPAIN (updated)

CliffsNotes Version: Spain is a declaratory country. Brits already living in Spain with residencia – the green certificate of residence – can now register for the new Tarjeta de Identidad de Extranjaro (TIE).

Spain also just created an 060 Brexit hotline to answer Brexit-related questions from Brits and Spanish citizens in English or Spanish. Outside Spain, call +34 902 887060.

Information categories include residence requirements, healthcare, driving licenses, education, travel and business. BUT, the Spanish bureaucracy is daunting and the Independent has a post about the cottage industry that has grown up around helping Brits – who typically don’t speak Spanish – navigate the process.

Those fees can be stiff – as much as 1,100 euros, according the the Independent post.

The Whole Story: Spain went out of its way to make sure estimated 400,000 Brits living in Spain remain in place if the UK ultimately left the EU without a deal. But there is a deal, and Spain has a slightly different process for Brits to stay.

It’s not necessary for Brits already living in Spain for more than five years to apply for a new residence card.

But here’s the fine print:

Even if you have a permanent residence document under EU rules, you and your family members have the right to request the new biometric residence card showing that you enjoy the rights defined in the Withdrawal Agreement. We strongly recommend that you do (apply for a new residence card.) The card shows your right to enter Spain and exempts you and your family members from ETIAS and visa requirements when entering Spain. ​

Here’s the official Spanish website.

There are a few uncertainties because the actual number of Brits in Spain is closer to 1 million, many of whom have second homes there where they live only part of the year. If they don’t have a long-term residency visa, they could be limited to spending only 90 days per year under Schengen tourist-visa rules.

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.

Also, don’t forget that Spain is one of the Golden Visa countries. The New York Times has new post about how you can buy a house in Spain and get a passport in the bargain.

However, the income requirements for staying in Spain are significant – a contract with a Spanish company (not a part-time gig) with income of at least 2,000 euros a month. Or this amount coming from another sources such as investments or pensions. If you have a family, it’s much more – 500 euros per month for each family member. So a family of four must prove they have an annual income of at least 47,000 euros, according to the BBC.

If you’re the Old Woman who lives in the Shoe, forget about it ….

Here’s the link to the Spain page on the new GOV.UK Brexit website.

SWEDEN (updated)

CliffsNotes Version: Like France, Sweden has a constitutive system that requires applying for settled status. You can apply here. Applications for residence status must be submitted to the Swedish Migration Agency by 30 September 2021.

Here’s the official Swedish Migration Agency website with all the details.

The Whole Story:

UK nationals who already have a Swedish residence permit have the right to live in Sweden and don’t need to apply for residence status … though they can. Among other things, residence status gives more family members the right to join them in Sweden.

There are about 30,000 British expats in Sweden, about 20,000 of whom don’t hold Swedish passports, according to reports.

Those moving to Sweden after 1 January must apply for long-term residency as third-country citizens.

Here’s the link to the Sweden page on the new GOV.UK Brexit website.


CliffsNotes Version: No change for Brits already living in Switzerland. Switzerland and the UK have recently signed various new agreements including one – good for the next two years – that allows UK professionals to work visa-free up to 90 days in Switzerland.

The Whole Story: Oh, the ignominy.

British citizens have joined 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 2019 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.

As to residence rights (you thought we forgot), Brexit has no effect because Switzerland isn’t in the EU and it signed a Citizens Rights agreement with the UK last December guaranteeing nothing will change.

Here’s the link to the Switzerland page on the new GOV.UK Brexit website.

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