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Implications of Brexit

The United Kingdom (UK) left the EU on 31st of January 2020. The transitional period ended 31st of December 2020, and the rules regarding free movement therefore no longer apply. On 24th of December 2020, the EU Commission and the British Government came to agreement on a Trade and Cooperation Agreement, which went into force 1st of January 2021. The agreement regulates social security for persons moving between the UK and the EU for the first time after 31st of December 2020.

There will no changes for persons already resident in the UK on 31st of December 2020. There is no need to worry whether one, for instance, can continue to have pension disbursed from the UK. This also apply for those who retire later on: If they have acquired pension in Denmark, the pension will be disbursed as if the UK was still an EU Member State. At the same time the right to receive benefits from the UK, such as unemployment benefits, health benefits and childcare benefits, will apply according to the EU rules.

This follows directly from the withdrawal agreement. Citizens will keep acquired rights to social benefits, as if the UK was still an EU Member State, when the transitional period ends. However, this only applies to citizens who have been covered by the EU rules regarding free movement before the end of the transitional period, i.e. the 31st of December 2020.

EU citizens and British Citizens who move between the UK and the EU from the 1st of January 2020 onwards are covered by the Trade and Cooperation Agreement. As a starting point the agreement means that EU citizens are treated like other third country citizens in the UK in regards to access to the labor market and vice versa for British Citizens in the EU.

However, the agreement secures coordination of social security benefits for persons arriving in the UK from 1st of January 2021 and vice versa for British Citizens in the EU. The rules correspond to a great extend to those which apply to citizens that move internally in the EU. If you move to the UK for the first time from 1st of January 2021 onwards, you will for instance be able to receive your pension and voluntary early retirement benefit (efterløn) from Denmark, as if the UK was an EU Member State. However, to be able to receive disability pension (førtidspension) you have to fulfill the requirements in the Act on Social Pension, regarding export to third countries. Further, it will not be possible to receive unemployment benefits from Denmark in the UK. The agreement does not cover family benefits, such as child care benefits.

According to the agreement it is also possible (as it applies in the EU) to remain covered by Danish law on social security, if you are sent out for temporary work in the UK by your employer, for instance if you are posted in a subsidiary/parent company.