No-deal Brexit: Which EU member state is being the most generous to Britons?

Most EU member states have passed legislation or intend to, aimed at safeguarding the rights of Britons living there. However certain countries are more generous and more accommodating than others. Here's a look at how they square up.

No-deal Brexit: Which EU member state is being the most generous to Britons?
Photo: Depositphotos

From a 10-year work and residence permit to stringent income criteria, the packages of rights on offer from EU27 member states to mitigate a no-deal Brexit for resident UK nationals vary immensely from country to country.

Duration of no-deal residence permits

By far the most generous is Malta's. “The Maltese authorities will give a 10 year status to UK nationals who are resident in Malta on 29th March 2019. For a UK citizen to become a beneficiary of such status, they will have to be resident in Malta on 29th March 2019,” Sarah-Louise Galea, head of international media at the Maltese Prime Minister’s Secretariat, confirmed to The Local by email. 

Students will be able to continue studying in Malta; workers “will automatically have open access to the labour market, hence eliminating the requirement for an employment licence.” Self-sufficient individuals will have to prove they have income equivalent to the Maltese minimum wage, as well as valid health insurance.  

Malta's offer contrasts sharply with that of other nations. It does not matter how long UK nationals have been in Malta, as long as they are resident by March 29th or the UK's withdrawal date. There will be no fee for applications.

France, on the other hand, has various offers depending on how long UK nationals have resided there. UK nationals who have been in France for five years will be able to apply for a carte de séjour permanent. Those who have been there less than five years may have to meet income criteria, as of yet not published. 

And there is talk of the fees for a carte de sejour reaching €269 albeit the British Embassy says it expects the cost to be around €150

READ ALSO: 24 days to: The new Brexit advice for Britons in France

Germany also intends to process UK nationals under third country national migration law and will offer a likely brief three month transition period to allow more time. UK nationals in the EU's largest economy have been urged to apply for new residence permits. 

READ ALSO: Brexit: Brits across Germany urged to apply for residence permit

Poland will offer two options: a temporary residence permit of three years and permanent residency for UK nationals who have resided continuously in Poland for five years at the time of the withdrawal date, according to the EU Commission.

Sources at rights group British in Europe say Italy is considering the right to remain for life for those UK nationals who have residency at the time of withdrawal. Italy has not yet published details of the 'decree' it has said it will pass to protect UK nationals' rights in the event of a no-deal. 

READ ALSO: The ultimate no-deal Brexit checklist for Brits in Italy

Transition periods

When it comes to rights, “the funniest thing about Europe is the little differences,” to borrow from Pulp Fiction's Vincent Vegas. These are particularly evident on the no-deal rights question when it comes to how quickly Brits will have to apply for new documents after March 29th.

Sweden has said UK nationals will have a year to apply for a new residency status in the event of a no-deal; Austria on the other hand says all Brits will have to apply within six months for new documents.

READ ALSO: How the Swedish Migration Agency is preparing for a no-deal Brexit

Spain is considering a 24-month transition period – “Spanish authorities need an enough period of time to cope with the process (sic),” states an outline by the EU Commission of the rights of UK nationals in each member state in the event of a no-deal exit. 

READ ALSO: Spain to pass new law to protect rights of Britons in case of no-deal Brexit

Overview on no deal #Brexit actions for UK citizens by EU27 countries below. MS committed to use national law generously; also, many long-term UK residents will have rights under EU law. But the WA & its orderly exit is obviously a much better way forward

— Stefaan De Rynck (@StefaanDeRynck) March 6, 2019

UK nationals in the German capital Berlin will likely have only three months to apply for a new residency permit. British nationals have already been asked to re-register their presence. Although Germany's transition period could be “possibly longer,” according to info from the EU Commission. 

READ ALSO: What you need to know about Berlin's Brexit registering process

The Netherlands' so-called “national transition scheme” for UK nationals in the event of a no-deal proposes a 15-month transition period up until 1 July 2020. Italy's transition period is set to last between six to nine months, although details have not yet been officially confirmed. Belgium has said it will guarantee the rights of UK nationals until the end of 2020, regardless of the outcome. Portugal also envisages a transition period until the end of 2020, during which the rights of UK nationals resident before March 29th will not be altered. 

Bulgaria will also give UK nationals until the end of 2020 to apply for new residence permits. Latvia has proposed a similar transition period. Lithuania is one of the only countries that will accept applications for new 'no-deal residency permits' before March 29th 2019. Luxembourg's transition period will run until the end of 2019. 

Red tape v automatic documents

Some countries require Brits to actively register for new documents – France, Germany and Spain for example. Others will simply issue temporary documents by default. UK nationals resident in the Netherlands will automatically receive a temporary residence via the post in the event of a no-deal and be invited to apply for permanent residency by April 1st 2020.

Croatia, Slovenia, Cyprus and Bulgaria have said they will also offer a package of rights although all remain mirky on the details of what that will entail and how it will work.

Cost of documents

Malta has said applications will be free of charge. Other countries have said they will charge a fee. France, for example, has announced there will be a fee to get a new residence permit, although the government has not said how much it will be. And there is talk of the fees for a carte de séjour reaching €269 albeit the British Embassy says it expects the cost to be around €150

As far as we can see, Malta is the only country that is offering residence permits free of charge. 


Spain and France have said they will introduce income assessment criteria for some UK nationals to obtain a permit, which is likely to affect low-income families and pensioners most. Malta only requires “self-sufficient” UK nationals to prove they have an income equivalent to the Maltese national minimum wage – €175.84 per week for those aged over 18. This means UK nationals with an income of at least €9,000 per year will be able to meet the criteria.

“Possessing the right of residence or permanent residence under free movement rules in Poland on the withdrawal date will be the only positive condition for granting these permits,” states an EU Commission outline. 

Countries like Germany and Czech Republic have said that UK nationals will have to apply as third country nationals for residence permits after the transition period, meaning Britons in those countries will be subject to more stringent income criteria and checks. Third country nationals applying for residency in Germany must prove relevant qualifications for employment, or have a job offer. 

Denmark is encouraging UK nationals there to apply for a permanent residency card before March 29th, although it has said it will pass a 'no-deal' bill for UK nationals. 

READ ALSO: Denmark’s no-deal Brexit bill: What British residents need to know

A no-deal Brexit would become a reality if the UK parliament does not approve the Withdrawal Agreement agreed by UK and EU negotiators in the next three weeks and if the UK and the EU cannot agree on an extension period to Article 50, which expires on March 29th. 

READ MORE: No-deal Brexit: Country by country guide to how the rights of Britons will be affected






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Summer travel between Spain and the UK: What can I not pack in my suitcase?

If you're travelling between Spain and the UK this summer and want to take some of your favourite treats with you, here's what you should know about the food and drink rules post-Brexit so you don't get caught out by customs.

Summer travel between Spain and the UK: What can I not pack in my suitcase?

Flying to the UK from Spain

For those flying to the UK from Spain, the rules are relatively lax.

Note, if you’re spending the summer in Northern Ireland there are different rules on food and animal products. Find them here. 

You can bring the following products from Spain into the UK without worrying about any restrictions:

  • bread, but not sandwiches filled with meat or dairy products
  • cakes without fresh cream
  • biscuits
  • chocolate and confectionery, but not those made with unprocessed dairy ingredients
  • pasta and noodles, but not if mixed or filled with meat or meat products
  • packaged soup, stocks and flavourings
  • processed and packaged plant products, such as packaged salads and frozen plant material
  • food supplements containing small amounts of an animal product, such as fish oil capsules

Meat, dairy, fish and animal products

If, like many of us, you have friends and family already putting in their orders for stocks of jamón serrano, know that the rules on bringing meat, dairy, fish and other animal products into the UK are relatively relaxed. You can bring in meat, fish, dairy and other animal products as long as they’re from the EU, so your jamón and Manchego cheese are safe. 

what food can and cannot bring between spain and the uk

You will still be able to bring cured Spanish ham from Spain to the UK. (Photo by Robyn Beck / AFP)

Alcohol allowance

For many, the big one, but there are some limits on how much booze you can bring in from Spain and the EU more generally. How much you can bring depends on the type of alcohol, so get up to speed on the limits and make sure your favourite Rioja and Cava aren’t taken off you or heavily taxed:


  • beer – 42 litres
  • still wine – 18 litres
  • spirits and other liquors over 22 percent alcohol – 4 litres
  • sparkling wine, fortified wine (port, sherry etc) and other alcoholic drinks up to 22 percent alcohol (not including beer or still wine) – 9 litres

It’s worth knowing that you can split your allowance, for example you could bring 4.5 litres of fortified wine and 2 litres of spirits (both half of your allowance).

Flying into Spain from the UK

While British borders are laid back when it comes to travelling with food and drink, the rules are much tougher when entering the EU from the UK.

Most importantly, tea bags – longed for by Brits the world over – are allowed. Marmite, which is vegan, is also fine to bring but Bovril, which contains beef stock, is not.

Travellers arriving in the EU from Britain can, according to the European Travel Retail Confederation (ETRC), bring the following quantities of alcohol, so if you fancy a British tipple in Spain over the summer such as Pimm’s it is possible, within reason: 4 litres of still wine and 16 litres of beer, 1 litre of spirits, or 2 litres of sparkling or fortified wine.

If you arrive in the EU from a non-EU country, you cannot bring any meat or dairy products with you. That means no Wensleydale, no Cornish Brie in your ploughman’s lunch and no British bacon to enjoy in Spain for English breakfast fry-ups.

Ploughman's lunch

British cheese for your Ploughman’s lunch is not allowed. Photo: Glammmur / WikiCommons

The EU’s strict rules mean that all imports of animal-derived products technically come under these rules, so even your custard powder to make rhubarb fool or bars of your favourite chocolate are now banned, because of the milk.

Be aware, however Spanish customs do not always check your suitcase, so you may be able to get away with bringing in a small packaged item such as a chocolate bar, without it being confiscated. 

Similarly, if you’re planning on asking a friend or family member to bring you over some sweets, cakes, or other home comforts, be aware that the ban includes all products that contain any meat or dairy as an ingredient – which includes items like chocolate, fudge, and some sweets (because of the gelatine.)

You are allowed to bring a small quantity of fruit and vegetables as well as eggs, some egg products, and honey. Restricted quantities of fish or fish products are also allowed: eviscerated fresh fish products (gutted, with all the organs removed), and processed fishery products are allowed up to 20 kg or 1 fish, so you can enjoy some Scottish smoked salmon in Spain over the summer if you want.

If you’re travelling with kids, note that powdered infant milk, infant food and specifically required medical foods are allowed up to 2kg, as is the case for pet foods. 

Clotted cream for cream teas won’t be allowed to be brought into Spain. Photo: Tuxraider reloaded / WikiCommons

This means that even the classic British summertime favourites such as sausage rolls, scotch eggs, packaged trifle and clotted cream for your cream tea will not be allowed because of the meat and dairy they contain.

It is worth noting that these strict EU rules also apply to sending products by post, so if you were hoping to get around the newly applicable legislation by having someone send you a delivery some Devon fudge, they will probably be intercepted and confiscated by Spain’s postal service, unfortunately. 

READ ALSO: Are there limits on bringing medicines into Spain?