Since the UK remains bound until the end of the year to EU agreements with Switzerland, including VPAs, and remains considered an EU member state in terms of social security, nothing will change immediately for Swiss and British citizens who can continue to live, work and move in both countries. In another scenario, a withdrawal agreement between the EU and the UK would be ratified, with the UK no longer expected to be an EU member state from 29 March 2019, but entering a transition period that is to continue until 31 December 2020. The UK and the EU could jointly decide to extend the transition period to two years. During this period, EU law will continue to apply to the UK, although the UK has left the EU; EU agreements with third countries, including the Swiss-EU VPA, are valid for the UK until the end of the transitional period.4 The EU-UK withdrawal agreement came into force on 1 February 2020 and brings Brexit back to life. It provides for a transition period until December 31, 2020. As with the other EU/EFTA and Switzerland, the UK`s social security system was previously coordinated with that of other Member States. The UK`s decision to leave the EU has made significant changes to existing social security legislation, as Switzerland applies these rules bilaterally. Note: British nationals working in Switzerland and another EU Member State are also affected by Brexit, as EU social security coordination rules will no longer apply to such cases in the future. In the event that Switzerland and the United Kingdom fail to agree on a new bilateral social security agreement, the 1968 bilateral social security agreement (more below) should continue to apply to these people under the scenarios, either on 1 January 2021 or 30 March 2019 (see more, see below). However, people who move between Switzerland and the United Kingdom after 30 March 2019 or after 1 January 2021 are not covered by the civil rights agreement between Great Britain and Switzerland. (As Switzerland is not part of the EU, bilateral agreements between Switzerland and the UK are still in place) The purpose of the agreement is to ensure that those covered by the FMOPA are subject to the same condition and that vested interests are protected. This agreement will not suspend or succeed the agreement between Britain and Swiss civil rights.
UK and Swiss nationals covered by the civil rights agreement will continue to protect their rights under the agreement after the end of 2020. Forms A1 relating to current social security legislation for preliminary work started before 01.01.2021 remain valid for the duration of the cross-border situation or until the expiry date indicated on the document. European health insurance cards issued before 31.12.2020 (or an equivalent document) remain valid as long as the situation of those affected remains unchanged. On 31 October 2019, the UK and Switzerland agreed on an interim social security agreement after the UK withdrew from the EU. In this blog, we give a quick overview of this agreement and its implications. More information on the Citizens` Rights Agreement For persons who are not in a cross-border situation on the date indicated but who were previously insured in the United Kingdom or Switzerland, the periods of insurance completed before and after the date indicated for the acquisition of a Swiss or British pension are taken into account.