UK departing from the EU affects how work abroad is insured, for example, the validity of A1 certificates.

Brexit came into force on 1 February 2020. The withdrawal agreement included a transition period until the end of 2020 during which EU’s current regulations have prevailed. Although the transition period has come to an end, workers posted to the UK can still be granted A1 certificates under certain conditions.

EU-UK Trade and Cooperation Agreement in force on 1 January 2021

The EU and the UK have reached a trade and cooperation agreement that is applied as of 1 January 2021. The agreement includes comprehensive regulations on how social security is to be applied to cross-border situations, for example, posted workers.

New postings that start as of 1 January 2021 are covered by the trade and cooperation agreement. Based on the agreement, a worker posted to the UK may, under certain conditions, be covered by the social security of their sending country for 24 months (providing a certificate for a posted worker has been applied for).

On its website, the European Commission has published a draft of the trade and cooperation agreement.

A1 certificates to the UK

As of 1 January 2021, either the Trade and Cooperation Agreement or the Withdrawal Agreement are applied to persons in cross-border situations. Which agreement applies depends on when the work in the UK has begun.

As of 1 January 2021, the Withdrawal Agreement and its regulations are applied to new postings to the UK.

The Withdrawal Agreement and the EU Regulations on social security may be applied to persons who, before 1 January 2021, have been in a cross-border situation (EU-UK) at the turn of the year as, for example, posted workers.

A1 certificates granted before 31 December 2020 continue to be valid as usual for the period stated in the A1 certificate. If the certificate has been applied for and granted for a period that extends beyond 1 January 2021, it will be valid for the period stated in the A1 certificate. The certificate can also be applied for in retrospect.

In order for an A1 certificate to continue to be valid after 1 January 2021, the Withdrawal Agreement must be applicable to the person’s situation and they must continue to be in a cross-border situation between an EU country and the UK.

For more information on the requirements and applications of the agreements, check the section on the withdrawal agreement and the transition period.

The FAQ section includes also practical information on how the agreements affect various work situations in the UK.

More elsewhere

The draft agreement on the Commission’s website (pdf)

Topical information on the subject on the Commission’s website

The withdrawal agreement between the EU and the United Kingdom came into force on 1 February 2020. The withdrawal agreement establishes the terms of the UK’s orderly withdrawal from the EU.

The withdrawal agreement governs the transition period until the end of 2020. During this period,  the UK’s relationship with the EU continues under currently valid rules, as if the UK were a member of the EU. The only significant difference is that the UK no longer participates in EU decision making or the work of various EU bodies.

The withdrawal agreement also secures the rights of EU citizens residing in the UK and UK citizens residing in EU countries in terms of residence, work and social security rights, providing they are in a cross-boarded situation on 31 December 2020, that is, in a situation which involves both an EU Member State and the UK.

Their positions and rights are secured as they are when the transition period ends on 31 December 2020, according to central EU legislation. The social security of individuals covered by the withdrawal agreement continues to be subject to the rules of EU’s social security regulations if the individuals are at a cross-border situation when the transition period ends and if they have been covered by EU’s social security regulations and their situation continues unchanged without interruptions. 

FAQs about Brexit and social security

Question: I am working in the UK at the moment. I have an A1 certificate that is valid until the end of June 2021. What will happen to my certificate?

Answer: Your A1 certificate will remain in force. Under the withdrawal agreement, A1 certificates that have been granted before the end of the transition period will be in force for as long as the certificate has been granted, providing your work continues without interruptions. In other words, you don’t have to do anything regarding your A1 certificate.

Question: Our worker works in several EU countries, including the UK, on a monthly basis. Do we have to take any action regarding Brexit? He has been granted an A1 certificate for work in several EU countries in 2020 – 2021.

Answer: An already granted A1 certificate will be valid for your worker until the end of 2021. Under the withdrawal agreement, A1 certificates that have been granted before the end of the transition period will be in force for as long as the certificate has been granted, At this stage, you don’t need to take any action regarding the A1 certificate. Brexit does not impact the work in other countries either – the A1 certificate is valid for the other countries until the end of 2021.

Question: My two-year posting to the UK will begin in February 2021. I would like to remain covered by Finnish social security during that period. What should I do? Does Brexit affect my situation in any way?

Answer: Your employer must apply for an A1 certificate for you from the Finnish Centre for Pensions. The certificate attests that you are covered by Finnish social security laws while working in the UK..

If your posting to the UK begins in February and is your first one, and if you were not in a cross-boarder situation (EU-UK) on 1 January 2021, your work will be subject to the EU-UK Trade and Cooperation Agreement. Based on the agreement, you can continue to be insured in the sending country, that is, Finland. 

Question: I came to Finland in September 2018 to work. My A1 certificate is valid until September 2021. Will I remain covered by UK social security throughout the validity period of my A1 certificate?

Answer: Yes, your certificate will remain valid since, under the Withdrawal Agreement, all certificates granted before the end of the transition period remain valid throughout the period they have been granted for. You can ask for more information on your certificate and social security from the UK authority that issued your A1 certificate.

Question: As of 1 April 2021, I will start working in several EU countries. I reside in Finland and will also work in the UK on several occasions each year.  Can I be granted an A1 certificate that also includes my work in the UK?

Answer: If you do a considerable part of your work in Finland or if you have only one, Finnish employer, you will be covered by Finish social security laws under the EU-UK Trade and Cooperation Agreement. Since you reside in Finland, your employer can apply for an A1 certificate for your work from the Finnish Centre for Pensions. If all conditions for granting an A1 certificate are met, the certificate granted will cover all your work abroad, including that in the UK.

Question: I will start working in the UK for a local employer as of 1 April 2021. In other words, I am not a posted worker but I have a fixed-term employment contract with a local company and will work only in the UK. How does this affect my social security?

Answer: According to the EU-UK Trade and Cooperation Agreement, you will be covered by the social security of your country of work. Your social security are to be paid to the UK and your right to social security (for example, a pension) is determined under UK laws. Since you will be working in the UK for a local company, you will be covered by the social security laws of your country of employment (the UK).

Question: I will be a posted official to the UK as of 1 March 2021. I will work in the UK for three years. Will I and my family members continue to be covered by Finnish social security?

Answer: As a rule, under the EU-UK Trade and Cooperation Agreement, officials are covered by the social security legislation of their employer’s country of domicile. In Finland, an official is a person who is in an employment relationship in the public sector with an employer whose operations are financed with state funds. Your employer must apply for an A1 certificate for you from the Finnish Centre for Pensions. As a rule, family members of officials working abroad are covered by Finnish social security laws. Contact Kela as it will issue a decision regarding the social security of your family members. 

Question: I have been awarded a grant from Finland that is valid until the end of 2021. I will go to work in the UK on that grant. How does Brexit affect my social security?

Answer: Apply for an A1 certificate in order to be covered by Finnish social security. The certificate attests that you are covered by Finnish social security while working on a grant in the UK. Grant recipients are usually covered by the same rules as self-employed persons. Under those rules, you can work in the UK temporarily until the end of 2021 and still be covered by Finnish social security. Read more about the preconditions for posting a grant recipient.

Question: I live in the UK and get an earnings-related pension from Finland. Will Brexit affect the payment of my pension?

Answer: Brexit will not affect the payment of your pension.  Finnish earnings-related pensions are paid to all countries in the world, including the UK (regardless of  Brexit).

Question: If I have questions about Brexit and my social security, whom should I turn to?

Answer:  You can contact the Finnish Centre for Pensions and/or Kela in Finland and, if necessary, the equivalent authorities in the UK for more information on how Brexit affects your social security.
Customer Service of the Finnish Centre for Pensions

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