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 on other sites:

Finnish Centre for Pensions – Central body of and expert on statutory earnings-related pensions