EU citizens (and their family members and surviving dependants) who at the end of the transition period were covered by the British social security regime generally still have the same access to social security benefits in the United Kingdom as they did previously.

With many of the means-tested benefits (e.g. Universal Credit) and applications for child benefit, applicants need to prove that they have the “right to reside” in the UK. They normally have this right if, in particular, they are economically active (employees or self-employed) or seeking work, or have already acquired permanent resident status through having lived in the UK for the previous five years. EU citizens with settled status automatically meet the residence conditions for receiving benefits.

Persons with pre-settled status can apply for certain benefits (e.g. contribution-based Jobseeker´s Allowance or disability benefits) without having to meet further criteria. However, in the case of income-based or means-tested benefits, applicants additionally need to be able to show they have the right to reside in the UK.

EU citizens who moved to the United Kingdom on or after 1 January 2021 or who move there in the future only get temporary right of residence, which is also conditional on them having no recourse to public funds during their stay. This means they cannot claim most benefits.

Further information can be found on the British government website and on the Citizens Advice website

Under the Withdrawal Agreement, there is basically no change to unemployment insurance, health insurance, long-term care insurance and pension insurance for UK nationals who were already living in Germany on 31 December 2020.

For UK nationals who moved to Germany on or after 1 January 2021 or who move there in the future, benefits are governed by the Trade and Cooperation Agreement. The arrangements are basically the same as the previous provisions in many areas. However, there are some departures from the former legal position, in particular with regard to family benefits, long-term care insurance and unemployment insurance.

Further information can be found on the website of the Federal Ministry of Labour and Social Affairs and the British government website

Further information on family benefits can be found at arbeitsagentur.de

Further information on long-term care insurance can be found at dvka.de

Further information on unemployment insurance can be found at arbeitsagentur.de