Withdrawal of the United Kingdom from the European Union

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The United Kingdom of Great Britain and Northern Ireland today declared its intention to withdraw from the European Union (EU). European social legislation with respect to the United Kingdom nevertheless remains fully in force until the withdrawal has taken effect at the end of the transitional phase, which will normally last for two years. The specific arrangements that will govern the rights of employees and pensioners in the relationship between the UK and Germany following withdrawal will depend in particular upon the terms of withdrawal negotiated between the EU and the United Kingdom. The umbrella associations of the German social insurance drew attention to this circumstance today in Berlin.

Many employees have worked in both Germany and the United Kingdom. They have acquired pension entitlements in both countries, or are already drawing both a German and a British pension. They enjoy comprehensive protection under European social law as employees and as pensioners. Both the periods during which they made contributions to the German retirement pension insurance system and those during which they contributed to the statutory retirement pension system in the United Kingdom are therefore taken into account for their total pension entitlements in either country. The same applies in conjunction with periods spent in a further EU member state or in Iceland, Lichtenstein, Norway or Switzerland. In addition, European social legislation is equally applicable to arrangements concerning the health insurance of pensioners.

The German pension insurance is now issuing only temporary A-1 certificates regarding the applicable legislation (certificates of the posting of workers) for the United Kingdom. Employees posted to the United Kingdom can use this form to certify that they are already covered by social insurance in Germany. Duplicate insurance is thus avoided.

In the event of an occupational accident or occupational disease, European social legislation also makes provision for the necessary benefits in kind to be delivered outside the country responsible, as is the case for example when an individual insured in Germany is working temporarily in the United Kingdom. In addition occupational accidents or periods of employment presenting an occupational health hazard in the United Kingdom or in Germany have to date been taken into account reciprocally in assessments of whether the criteria are satisfied for entitlement to a pension owing to an occupational accident or disease.

The German social insurance institutions will provide information promptly as soon it becomes apparent what developments will occur following withdrawal. We then recommend that insured individuals obtain advice on a case-by-case basis on the specific consequences of BREXIT.