The United Kingdom left the EU on 31 January 2020. The withdrawal agreement provides for a transitional period until 31.12.2020 during which the UK continues to apply EU law on the coordination of social security systems in relation to EU states and Switzerland. During this transitional period, Regulations (EC) No 883/2004 and (EC) No 987/2009 on the coordination of social security systems remain applicable without any change in the relations between Switzerland and the United Kingdom, and the United Kingdom is assimilated to an EU state.
From 1 January 2021, the relations between Switzerland and the United Kingdom are to be governed by a new coordination regime; these rules are currently being defined.
However, it is likely that the old bilateral agreement between Switzerland and the United Kingdom of 1968 will be applied for a short period of time on 1 January 2021, until the future coordination regime can come into force.
Protection of acquired rights
At the end of the transitional period on 31.12.2020, the Agreement on the Free Movement of Persons between Switzerland and the EU (FMPA) does no longer apply to relations between Switzerland and the United Kingdom.
In order to regulate the exit of the United Kingdom from the FMPA and to guarantee the rights that insured persons have acquired under the FMPA, an agreement on citizens' rights has been concluded between Switzerland and the United Kingdom. This agreement is applicable from 01.01.2021. It maintains the rights arising from Annex II (social security coordination) of the FMPA for persons who were subject to the FMPA before 01.01.2021.
A1 forms concerning the applicable social security legislation for assignments 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 any equivalent document) remain valid as long as the situation of the persons concerned remains unchanged.
The Mitteilung an die AHV-Ausgleichskassen und EL-Durchführungsstellen Nr. 430 (available in German, French and Italian) explains the protection of acquired rights in the areas of applicable legislation and first pillar benefits.
You will find here further information on the social security provisions of the agreement via: