David Hencke’s analysis of the restrictive measures being drawn up by European countries and EU member states on the post-Brexit fate of British nationals seeking to make their lives there.

Switzerland has become the first country in Europe which plans to introduce a quota system for British nationals seeking jobs there if a ‘no deal’ Brexit occurs on 31 October.

The country will introduce a limit of 3,500 job permits for Brits from 1 November until the end of 2020 – broken down between temporary and permanent permits – and administered by individual cantons.

The decision to limit Brits getting preferential treatment for jobs was drawn up at the same time as Liam Fox, the former International Trade Secretary, hailed a “continuity” trade deal with the Swiss that guaranteed tariff-free trade after Brexit. But, what he didn’t disclose was the new labour restrictions.

The decision – part of the complex arrangements now taking place across 27 EU member states and the four European Economic Area countries – has alarmed the expat community, which is worried that other countries could follow suit and also impose jobs quotas for Brits in the event of a ‘no deal’ Brexit.

“They would neither have EU citizenship status nor a separate post-Brexit immigration status”

Dispatches Europe

The website Dispatches Europe, which covers British expat issues, warned this month: “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.”

The website has listed all of the latest developments, which suggest a rush of decisions to restrict movement for Brits living in EU countries at the last moment should Britain leave the EU without a deal. All the countries, with the exception of Malta, point to scrapping British rights if there are no reciprocal arrangements, which still have to be passed by Parliament.

Spain, for example, will continue to provide free healthcare for Brits but only as long as Britain agrees to give free access to the NHS for all Spaniards. Sweden is waiting to see whether a ‘no deal’ goes ahead before announcing any special measures.

After Brexit, France will require Brits to obtain a residency permit and pass a self sufficiency test so that they are not a drain on the state. Expats are already finding that people who have lived in France for less than three months may not be granted residency by local prefectures.


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Germany, which has 100,000 British residents, is only going to allow three months’ grace for its Brits to get residency if there is a ‘no deal’ Brexit – although some officials are granting residency permits in advance of the ‘no deal’ date.

Brits in Greece will be required to obtain a biometric identity card to stay in the country and register with the police.

Denmark has passed a special Brexit Act which is generous to existing Brits and their families resident there, but new people coming to the country will be subject to the Aliens Act, meaning they will only be allowed to take jobs in areas with shortages or research jobs – provided that they have the right qualifications. British visitors will no longer get fast access at ports or airports but will have to join the “other countries” group to be checked by officials.

Estonia will allow existing Brits to remain and get residency permits, but new Brits coming to the country will be subject to the Aliens Act. At present, there are no quotas for those from the US and Japanese people coming to Estonia to work and the UK is hoping that this will be extended to the UK – which may explain why Boris Johnson entertained the Estonian Prime Minister this month.

Belgium is planning to allow existing long-term British residents to get the right to stay, but Brits seeking work in the country after a ‘no deal’ Brexit will be treated as third country applicants. Whether they can go to Belgium will depend on different rules set by the four regions of the country. It has also proposed stringent checks for British visitors who will have to have the right travel documents, proof of enough money to live during their visit, and details of where and how long they are going to stay in the country. When they leave, they will need proof that they have not overstayed.

The Dispatches Europe website advises: “You should really do a deep-dive into the official website because, while there is a worst-case, ‘no deal’ Brexit transition period until 31 December 2020, the Belgians make it clear that after that, British citizens are on their own.” 

In general, the site warns: “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.”

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