Can I still move to France, Germany or other EU countries after Brexit?

British citizens’ rights to live in member states change dramatically from 1 January 2021

We have been listening to arguments about the impacts of Brexit for over four years, but those impacts will finally become real from the start of next month.

For those dreaming of an escape from the UK and the expected economic turmoil, the end of the transition period on 31 December brings about the biggest changes to freedom of movement in decades.

While the trading relationship is still highly uncertain, we can be sure of some of the basic rules for British citizens who want to move to countries inside the EU from 2021.

What happens if I want to move to the EU after 1 January?

Last year’s Withdrawal Agreement guaranteed Britons freedom of movement to live and work in EU members states until the end of the transition period – so that automatic right comes to an end from the start of January.

British citizens who want to move to an EU country will need to apply in accordance with that country’s residency rules. And those looking to work in an EU country will have to make sure that their professional qualifications are recognised in that particular country.

There’s simply no avoiding the complexity of different residency, work and study rules across 27 member states after the Brexit transition ends. The UK government has provided a country-by-country guide to moving to the EU – including rules around healthcare and applying for benefits in each nation – after 1 January 2021.

Why I still be able to visit my holiday home in the south of France?

Yes, if you’re lucky enough to have one – but you won’t be able to live there all year round. There have been headlines in recent days about expats’ “fury” at rules preventing them from spending more than three months in their second homes in the EU.

In reality we’ve known for a long time that from 1 January 2021, Britons will only be allowed to stay in an EU country, without a visa, for a maximum of 90 days. Anyone who wishes to regularly spend long periods of time in the EU will have to apply for a long-stay visa or residency.

UK negotiator David Frost and EU counterpart Michel Barnier are still trying to forge trade deal (Reuters)

If I manage to get residency in one EU country, can I move to other countries in the bloc?

It’s unclear how much freedom of movement British citizens living in one EU country will get from next year. The matter has been discussed in talks between UK and EU officials in recent months.

The right to “onward movement” to live or work in another EU country could come with strict limitations – including the need to prove five years of continuous residence in the bloc, according to Politico.

What happens if I’ve already moved to the EU?

British citizens who have been living in one the EU’s member states for a while – or who moved there during the transition period – could be given settled status, but will need to apply for residency with the government of the country they are in by 30 June 2021.

The EU confirmed in September that some member states were considering extending this deadline in 2021 because of the Covid pandemic. So the exact times and terms for residency applications will vary between EU countries.

Will I be able to travel to the EU after 1 January?

Yes. The EU has added the UK to its list of visa-exempt countries, granted British citizens the right to travel for up to 90 days without a visa. But after the transition period ends, it’s likely EU border officials may ask travellers from UK for additional information on the length and purpose of their stay. It’s also likely that fast-track lanes for passport control will no longer be open to British travellers.

From 2022 (or possibly later) British visitors will need to register online and pay in advance for an “Etias” permit under the European Travel Information and Authorisation System. This is a relatively light-touch visa, akin to the Esta used by the US.

For business travellers, a limited number of basic activities – such as meetings with clients or customers – are likely to be covered in visa-free travel. But anything beyond that is likely to require a business visa.