The U.K. is not the only country affected if it exits the EU with no deal. Several governments have published plans that will take effect after March 29, 2019. We look at what Czech Republic, Denmark, Germany, Luxembourg and Poland are doing to minimize the impact of a no-deal outcome on U.K. citizens planning to work and reside in the countries.
Czech Republic
The Czech government confirmed there will be a transition period of 21 months, during which U.K. citizens registered in the country will be required to apply for a residence permit.
U.K. citizens residing in the Czech Republic for five years or more can apply for a permanent residence permit. U.K. citizens who have been in the country for less than five years must apply for a local residence permit. Eligibility criteria will be the same as for non-EU applicants.
U.K. citizens holding an EU temporary residence permit can continue employment and stay in the Czech Republic until December 30, 2020. The same applies to any non-EU family members holding a corresponding permit.
Key considerations
Czech employers planning to offer employment to a U.K. citizen should be aware that an EU temporary residence certificate application is required.
This summary was prepared using information obtained from the Ministry of the Interior of the Czech Republic (language: Czech).
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
Denmark
A temporary transitional scheme will apply until replaced with a permanent solution.
All British citizens, as well as non-EU family members, living in Denmark without an EU registration certificate or EU residence card must apply before March 29, 2019. The Ministry of Immigration and Integration will inform the EU Commission that registration certificates and residence cards will serve as right of residence proof in Denmark.
Key considerations
Once the outcome of negotiations becomes clear, the Danish Government will continue work on a permanent scheme.
This summary was prepared using information obtained from the Denmark news.
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
Germany
The German Government has announced its intention to allow a three-month transition period for U.K. nationals registered in Germany on March 29. These U.K. nationals will be able to continue with current employment for the duration of the three months while applying for a permit.
Details of the planned transition regulation are however still unclear. The following questions remain unanswered:
- Will U.K. nationals planning to start employment in Germany after February 29 need to apply for a visa?
- Will their accompanying spouses be obliged to present an A1 German language certificate?
- Are U.K. nationals under the transition regulation free to travel within/abroad Schengen borders?
- Will U.K. nationals that do not qualify for an immigration permit under German immigration law be able to continue to live and work in Germany after the transition period?
Key considerations
While these details are being clarified, if you are a German employer, you should prepare for a hard Brexit and therefore the following is recommended:
- Immediately identify your U.K. population (including third-country nationals married to a U.K. national) in Germany
- Start collecting the relevant immigration documents (please contact us if you require checklists)
- Prepare immigration applications in order to register and file shortly before/after March 29
- Prepare and file visa applications for U.K. national employees with a start date after March 29
- Postpone the business travel of U.K. nationals scheduled for April
This summary was prepared using information obtained from the Germany immigration.
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
Lithuania
The transit period in Lithuania will be nine months. During this time, U.K. citizens and their non-EU family members can continue to work and reside in Lithuania. Nonetheless, residence registration is very important for ensuring legal stays in the case of any scenario.
Key considerations
After March 29, 2019, U.K. citizens whose residency documents expire before 2020 are advised to apply for a temporary or permanent residence permit. This will save time and avoid any application delays. A residence permit for work must also be obtained for those wishing to work in Lithuania.
Non-EU family members of U.K. citizens who wish to stay beyond December 31, 2019, are required to obtain a different national permit during the nine-month grace period.
It is not decided whether U.K. nationals arriving after March 29, 2019, will benefit from special requirements for national permits.
This summary was prepared using information obtained from the Migration Department of Lithuania.
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
Luxembourg
The transition period will be 12 months. This time allows U.K. citizens and their non-EU family members to continue to work and reside in Luxembourg after March 29, 2019. After this period a residence permit must be applied for. The application, however, must be filed before December 31, 2019.
No confirmation has been published on whether U.K. citizens residing in Luxembourg for five years or longer will be able to apply for a permanent residence permit.
Key considerations
Please note that both a residence permit and work authorization is required for U.K. citizens and their non-EU family members.
This summary was prepared using information obtained from the Luxembourg Government.
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
Poland
The transition period will be 12 months. This time allows U.K. citizens and their non-EU family members to continue to work and reside in Poland. After this period a residence permit and work authorization must be applied for.
U.K. citizens residing in Poland for five years or longer can apply for a permanent residence permit. Eligibility criteria will be the same as for EU nationals.
U.K. citizens who have been in the country for less than five years can apply for a special, three-year temporary permit. After three years, the permit holder will qualify for a standard national type under the same eligibility criteria as non-EU nationals.
Key considerations
U.K. citizens who plan to work and reside in Poland after March 29, 2019, should ensure that they hold the necessary documents for registration:
- Confirmation of insurance
- Purpose of stay (e.g. work or study confirmation, has a Polish spouse, etc.)
- Completed questionnaire
- A valid passport
This summary was prepared using information obtained from the Polish Government (language: Polish).
Disclaimer: The above information is provided for general information purposes only and should not be construed as legal advice. If you have any further inquiries regarding the applicability of this information, please contact Michele Giordani, Regional Immigration Manager, EMEA.
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