Relations with the United Kingdom
Social insurances schemes of Switzerland and the United Kingdom are coordinated on the basis of an agreement, which contains the same principles as the Agreement on the Free Movement of Persons between Switzerland and the EU (FMOPA). To protect the rights that insured persons acquired under the FMOPA before the United Kingdom's exit from the EU, an agreement on citizens' rights has been concluded.
New social security agreement
Switzerland and the United Kingdom have concluded a new social security agreement following the United Kingdom's exit from the European Union (Brexit). The agreement ensures the long-term coordination of the two countries' social security systems, in line with the Agreement on the Free Movement of Persons between Switzerland and the EU (FMOPA). The new agreement is provisionally applicable from 1 November 2021. The definitive entry into force is on 1st October 2023.
It contains the same coordination principles as the FMOPA: equal treatment; determination of applicable legislation; aggregation of insurance periods, export of benefits, administrative assistance and cooperation between authorities and institutions. The provisions from the EU coordination law (EU Regulations No. 883/2004 and No. 987/2009) have been slimmed down and tailored to the needs of the two States.
The following text of the agreement is not an official publication. Only the texts published in the Official Compilation of Federal Law are legally binding.
Social security convention CH-UK
Documents
Protection of acquired rights
In order to guarantee the rights that insured persons have acquired under the FMOPA, an agreement on citizens' rights has been concluded between Switzerland and the United Kingdom. This agreement is applicable from 1st January 2021. It maintains the rights arising from the FMOPA for persons who were subject to the FMOPA before 1 January 2021.
Text of the agreement
(as far as social security is concerned, these provisions also apply to EU nationals)
This agreement has been supplemented by a decision of the Swiss-EU Joint Committee of the FMOPA amending Annex II to the FMOPA (Protocol II), which extends the protection of rights to cross-border situations involving the EU:
Decision 1_2020 of the joint committee (PDF, 371 kB, 17.12.2020)
Citizens rights agreement
The aim of the agreement is to ensure that persons who were covered by the FMOPA before it ceased to apply to the United Kingdom (31 December 2020) experience as few changes as possible and that the acquired rights are protected.
Regulations (EC) No 883/2004 and (EC) No 987/2009 shall continue to apply in particular to the following persons (as well as to their family members and survivors):
- Swiss nationals and nationals of EU countries who are subject to the social security legislation of the UK on 31 December 2020
- UK nationals who are subject to the Swiss social security legislation on 31 December 2020
- Swiss nationals and nationals of EU countries who reside in the UK and are subject to the Swiss social security legislation on 31 December 2020
- UK nationals who reside in Switzerland and are subject to the social security legislation of the UK on 31 December 2020
For these persons, nothing changes as long as they are without interruption in a cross-border situation described above, i.e. as long as there is a connection to both states with regard to the nationality, activity or residence.Cross-border situations in which there is also a link with EU countries are also protected, this covers situations other than those mentioned above.
Regulations (EC) No 883/2004 and No 987/2009 continue to apply to certain persons who are not or no longer in a cross-border situation if they have the right to work or reside in the other State. These are, for example, Swiss nationals who go on working in the United Kingdom at the end of their posting or those who give up their employment in the United Kingdom and continue to reside there.
Applicable legislation
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.
Health insurance
The Federal Office of Public Health's communication of 8 December 2020 provides detailed information (available in German and French).
Persons insured for healthcare in the United Kingdom can find information here: Healthcare for UK nationals visiting the EU - GOV.UK (www.gov.uk) and Living in Europe - GOV.UK (www.gov.uk)
Family benefits
Information on the coordination of family benefits between Switzerland and the United Kingdom from 01.01.2021 is provided in the Mitteilung über die Durchführung der Familienzulagen Nr. 38 and in an information sheet (available in German, French and Italian):
Information sheet Brexit Familienzulagen
Pension insurance
If you retire after 31.12.2020, you are still entitled to a pension in accordance with national legislation. Insurance periods completed in the other country are taken into account for the fulfilment of the minimum insurance period and the pension continues to be paid without restriction even in case of residence to the other country. In this case, health insurance cover is also guaranteed by one of the two states.
Disability and survivors' pensions are also paid in the case of residence in the other state.
For persons who are not in a cross-border situation on 31.12.2020 but were previously covered by social insurance in the United Kingdom or Switzerland, the periods of insurance completed before and after 31.12.2020 are taken into account for the
acquisition of a Swiss or a British pension. Their pensions can also be exported.
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.