Guidance

National Insurance for workers from the UK working in the EEA or Switzerland from 1 January 2021

Check which country’s social security contributions you must pay from 1 January 2021, if you’re a worker from the UK working in the EU, Norway, Iceland, Switzerland or Liechtenstein.

Brexit transition: new rules for 2021

The UK has left the EU. This page tells you the new rules from 1 January 2021.

It will be updated if there’s new information about the UK’s deal with the EU that affects what you need to do.

Get your personalised list of actions and subscribe to email updates to find out when things change.

From 1 January 2021, if you’re an employee, self-employed or an employer, where you will pay social security contributions will depend on your circumstances and the country you are going to work in.

If you work in the EU, Norway or Switzerland, you’ll only have to pay into one country’s social security scheme at a time. This will usually be in the country where the work takes place.

But if you are only working temporarily in the EU, Norway, Iceland, Switzerland or Liechtenstein you may be able to get a certificate or document from HMRC to carry on paying National Insurance contributions in the UK. This means you will not have to pay social security contributions abroad.

When you will continue to pay UK National Insurance contributions

You will continue to only pay National Insurance contributions in the UK if you have the relevant certificate or document from HMRC. You, or your employer, should apply for a certificate or document if you’re going to work temporarily in the EU, Norway, Iceland, Switzerland or Liechtenstein and you’re a:

  • person lawfully resident in the UK who started working in the EU before 1 January 2021, and has been working there since
  • national of the UK or Iceland, Liechtenstein or Norway who started working in Iceland, Liechtenstein or Norway before 1 January 2021 and has been working there since
  • national of the UK or Switzerland who started working in Switzerland before 1 January 2021, and has been working there since
  • national of the EU, Iceland, Liechtenstein, Norway or Switzerland who was resident in the UK before 1 January 2021, including if you have EU Settlement Scheme (EUSS) status
  • family member of a national of the EU, Norway, Iceland, Switzerland or Liechtenstein who has status under the EUSS and you are residing in the UK
  • person with dual nationality, one of which is the nationality of the EU, Norway, Iceland, Switzerland or Liechtenstein
  • multi-state worker, meaning that you were working in 2 or more countries of the UK, EU, Norway, Iceland, Switzerland or Liechtenstein before 1 January 2021 and continue to do so and you work predominantly in the UK

You may also be able to apply for a certificate or document if you’re covered by any of the other conditions in the withdrawal agreement or equivalent agreements with the EU, Iceland, Liechtenstein, Norway and Switzerland.

If you are a national of the EU, Iceland, Liechtenstein, Norway or Switzerland and you were living in the UK before 1 January 2021, you must apply for EUSS status by 30 June 2021 if you want to protect your right to stay in the UK and your social security rights.

You’ll also only pay National Insurance in the UK if you’re a:

  • UK or Irish national or any national lawfully resident in the UK going to work in Ireland
  • multi-state worker working in the UK and one or more EU countries

You will still be able to apply to HMRC to continue to only pay National Insurance in the UK if you are going to work temporarily in the following countries:

EU countries that apply the ‘detached worker’ rules

You should apply to HMRC for a certificate or document to continue only paying UK National Insurance contributions if you’re working temporarily for up to 2 years in an EU country where the ‘detached worker’ rules apply. This means you will not have to pay social security contributions in the country that you are working in.

An EU country must agree to apply the ‘detached worker’ rules by 1 February 2021 in order for them to continue to apply.

If you go to work in an EU country before 1 February 2021 and they have not ‘opted out’ of the ‘detached worker’ rules, you should apply for a certificate or document from HMRC to continue only paying UK National Insurance contributions.

If your work started before 1 February 2021 and you’re entitled to a certificate or document from HMRC, you will continue only paying UK National Insurance contributions unless your circumstances change (for example, you change employer, you go to work in another country you have not told HMRC about or any break in your work). This applies even if the EU country you are working in no longer applies the detached worker rules.

This guidance will be updated regularly. We’ll publish more information about EU countries that have agreed to apply the rules, or have opted out, as soon as it is available.

Norway

You should apply to HMRC for a certificate or document to continue paying UK National Insurance contributions if you’re working temporarily in Norway for up to 3 years. You should apply for a certificate or document before you go to work temporarily in Norway but must apply within the first 4 months of going to work there. This means you will not have to pay social security contributions in Norway for that duration of work.

Switzerland

You should apply to HMRC for a certificate or document to continue paying UK National Insurance contributions if you’re working temporarily in Switzerland for up to 2 years. This means you will not have to pay social security contributions in Switzerland for that duration of work.

Iceland

You should apply to HMRC for a certificate or document to continue paying UK National Insurance contributions if you’re employed and a non-UK and non-EEA national working temporarily in Iceland for up to 1 year. This can be extended by a further year, but you must get agreement from the Iceland social security institution before the end of the first year. This means you will not have to pay social security contributions in Iceland for that duration of work.

When you will pay social security contributions in the country you are going to work in

You will need to pay social security contributions in the country you are going to work in if you are going to work temporarily in the EU and you are not eligible for a certificate from HMRC. Contact the relevant EU social security institution to find out how to pay these.

You will not be able to pay contributions in the UK during this period, but you may be able to pay voluntary contributions.

Going to work in Liechtenstein

If you’re going to work in Liechtenstein and you are not eligible for a certificate or document from HMRC, you’ll need to continue paying UK National Insurance contributions for the first 52 weeks.

You may also have to pay social security contributions in Liechtenstein. You should contact Liechtenstein social security institution for more information.

How to apply for a certificate or document from HMRC

If you think you are eligible for a certificate or document, then follow the table to see how to apply.

Your circumstances Form to complete
Your employer sends you to work temporarily in the EU, Norway, Iceland, Switzerland or Liechtenstein. Form CA3822
You’re normally self-employed in the UK and you’re going to temporarily carry out some activities in the EU, Norway, Iceland, Switzerland or Liechtenstein you should complete. Form CA3837
You’re working in 2 or more of the UK, EU, Norway, Iceland, Switzerland or Liechtenstein. Form CA8421
You’re flight or cabin crew with a home base in the UK. Form CA8421
You’re a UK resident who works on a vessel at sea with a UK flag or an EU, Norwegian, Icelandic or Swiss flag but you’re paid by someone based in the UK. Form CA8421

If HMRC advises that you must pay UK National Insurance contributions, we will issue a certificate or document for you to use as proof that you do not have to pay social security contributions in the EU, Norway, Iceland, Switzerland or Liechtenstein.

If your situation changes

You’ll need to check if a change in your situation stops the existing social security rules from applying to you. To do this, send a letter to HMRC, telling them:

  • what your circumstances were
  • what has changed
  • when the changes happened

You should send your letter to:

PT Operations North East England
HM Revenue and Customs
BX9 1AN

HMRC will let you know if they need any more information.

Published 26 December 2020
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