Healthcare & No Deal Brexit

New Reciprocal Healthcare Brexit Arrangements for Expats.

ProACT Sam clarifies the current position on cross border EU Healthcare agreements for Expats.

How can UK and EU Expats qualify for UK NHS treatment or Healthcare in their EU Country?

While the UK Government is committed to protecting the existing rights of EU Expats Living and Working Abroad in the UK, how can EU and UK Expats Qualify for UK NHS Healthcare Treatment?

In this article ProACT Sam clarifies how UK and EU Expats could qualify for UK NHS Healthcare treatment.

In the event of a no deal Brexit on 31st October 2019 UK Expats Could Lose EU Healthcare.

ProACT Sam explains ‘what is the worst case scenario for healthcare for UK Expats with a bad Brexit?’ and what Reciprocal Healthcare arrangements are proposed by the UK Government in the aftermath of no deal Brexit or during any transition period.

Finally we examine the EU Expats Brexit Guarantees from the UK Government and the Reciprocal Healthcare offers made to the EU for UK Expats.


If there’s a no-deal Brexit, you should be ready for possible changes to how you access healthcare.

The EU countries operate under a common Social Insurance Agreement that allow equal treatment for EU Citizens across the EU.

Under this agreement each EU country can set its own terms, within an EU framework, for issuing cross border healthcare cover for its own citizens that are relocating oversea in the EU as:

    1. State retired expats,

    2. temporary working expats,

    3. people with medical exemptions or

    4. students.

    5. dependant family of a person qualifying for an S1

For Expats the transfer of healthcare service to any new EU country of tax residence requires the issue of an S1 certificate by the home country, that is registered with the new EU country of tax residence.

Within the Withdrawal treaty there is contained EU Citizen right provisions including maintaining current EU Healthcare arrangements during the transition period to 31st December 2020.

Within the treaty there is also a ‘6 month grace period’ after that date maintaining the status quo.

If there was a no deal Brexit then the UK could leave the EU Healthcare scheme from 31st October and the S1 would no longer provide free medical cover overseas for UK Expats in the EU, or EU Expats in the UK.


The UK government would like to continue to participate in with S1 Healthcare arrangements after Brexit. The government aims to reach reciprocal healthcare arrangements either

  1. with the EU across all EU countries or

  2. Bilaterally with each country individually.

State Healthcare is under the control of sovereign states within the EU, the EU have a common cross border treatment, but individual states can make their own rules, allowing for bilateral agreements. Such an agreement existed between Cyprus and UK before Cyprus joined the EU in 2004.

The government has made an offer to all EU countries to continue the current reciprocal EU healthcare arrangements if there’s a no-deal Brexit until 31 December 2020 at least.

Additionally the UK government is also seeking to extend and maintain the current healthcare arrangements with EU countries post Brexit.

Like everything else in Brexit the issues of family and business are caught up in politics and vested interests of big cross border business and their PR, lobby and negotiation position.

The EU’s long term interest is to protect the EU project. It rules means it cannot negotiate new trade deals until the UK has left the EU. The long term trade negotiations cannot begin with the UK or EU until after Brexit day. The longer the delay in settling the Brexit process the longer the confusion and delay for EU Expats Healthcare arrangements to be confirmed and extended with the whole EU.

Spain and Belgium have legislation in place to continue reciprocal bilateral healthcare arrangements for UK and EU Expats after Brexit. The UK have offered to keeping paying Cyprus for bilateral UK Expats healthcare arrangements also but these are not confirmed at the start of October 2019


The proposed transition period has not changed during the comings and goings of Brexit negotiations. It would be part of any withdrawal treaty and could be part of any ‘no deal Brexit’ mini deal, ie the transition period be retained as a mini deal to allow Brexit to occur on 31st October and a period for negotiations to be started while maintaining the status quo on all matters including healthcare through to the end of the transition period on 31/12/2020.

This would mean the UK government continuing to pay for healthcare costs for current or former UK residents who are living in or visiting EU countries, Norway, Iceland, Liechtenstein or Switzerland.


Expats can qualify for the UK NHS in the following way:

  1. If UK Expats return to live in the UK and meet the ordinary residence test, you will be able to use NHS services.

  2. EU Expats Living and Working Abroad in the UK as residents before Brexit qualify for NHS.

  3. If you are living in an EU country on Brexit day and have an S1 form

    1. you may use NHS services in England, Scotland and Wales without charge when on a short visit the UK.

    2. You may use the NHS in Northern Ireland is you move permanently to live there

  4. This will not change In UK after Brexit.


European Health Insurance Card (EHIC) issued by the UK will not be valid in any EU country when travelling unless there is a specific agreement between the UK and that country on a bilateral or EU basis. Travellers may need to ensure travel insurance is in place after 31st October

EHIC cards issued by the UK will only work if the UK achieves its objectives of remaining in the EU healthcare scheme or a similar bilateral arrangement with individual countries. The UK could extend such a scheme to other countries outside the EU post Brexit.


EU Expats working abroad in the UK and UK Expats working abroad in the EU who are registered locally as tax resident and paying qualifying social insurance, will be then able to qualify under the local rules of that country for local state healthcare.

In the UK it means being resident in the UK as your base. This is not necessarily tax resident, but could be. UK citizens would be challenged to argue they are resident for NHS purposes without also being deemed tax resident in some way.

Each EU country has its own rules and qualifying period for working expats. Ask ProACT to confirm the arrangements of your Expat location.


Expats not eligible for an S1 and not working and paying social insurance in their EU country of tax residence need to consider how they can access healthcare. Even before Brexit they may well not be eligible for state healthcare.

EU & UK Expats Living and Working Abroad in an EU country for more than 5 years could apply for permanent residency now. Even if not working and paying social insurance, by registering as a permanent resident and tax resident then an Expat could qualify to register for local healthcare.


There are some provisional transitional UK government provisions in the event of no deal Brexit. UK Expats should still make arrangements to ensure they are covered in their country of residence.

UK Expats S1 holders could benefit from the following provisions:

    1. A UK Expat undergoing medical treatment during Brexit, the UK will continue to cover and pay for treatment.

    2. for 6 months after Brexit - If your EU country of residence has no reciprocal healthcare agreement with the UK, and the UK Expat is asked to pay, the UK government can arrange to pay for this healthcare directly.

    3. If a UK Expat has applied to join a local EU country healthcare scheme, and the application takes time to process, and medical costs are not covered during the processing of the application, the UK will pay such medical costs. This is subject to the UK Expat registering in that EU country in accordance with the local rules AND within 6 months after Brexit.

These additional provisions offered to UK Expats with an S1 still require the the Expat to ensure they are registered to be Living and Working Abroad in their country of residence; to live as a resident, for tax, for social insurance if working and for the local healthcare system.

After Brexit UK Expats will lose their EU citizen rights of free movement to be Living and Working Abroad in the EU. If there is a no deal Brexit the EU Citizen rights could be lost from 31st October 2019.

Even so after the end of any transition period and in the absence of any new bilateral or EU wide arrangements, UK expats will need to register as non EU citizens. Similarly in the UK different registration rules will apply to EU Expats relocating to the UK after Brexit. EU Expats should secure their rights as soon as possible.

ProACT Expat Experts are here to help, if you need any help and assistance Living and Working Abroad, contact us for residency, tax registration, starting a business and protecting assets plus the latest EU Brexit for Expats Contact us.

We have produced guides on residency and healthcare for expats. Get your ProACT Know How now.

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