Guidance

Social security contributions for workers coming to the UK from the European Economic Area (EEA) or Switzerland

Check where you need to pay social security contributions if you’re from the EU, Iceland, Liechtenstein, Norway or Switzerland and are working in the UK.

If you normally work in the UK or the EU and your work location has changed temporarily because of coronavirus (COVID-19) travel restrictions, HMRC can consider your individual circumstances to decide if you should pay National Insurance contributions in the UK.

If you need proof that you have to pay UK National Insurance contributions, you should apply for a certificate and include details of the COVID-19 restrictions.

If you’re an employee or self-employed, where you pay social security contributions will depend on your circumstances and the country you work in. If you’re an employer, your liability to pay social security contributions will follow the liability of the employee concerned.

If you come to work in the UK from:

  • the EU or Switzerland you’ll only pay into one country’s scheme at a time
  • Iceland, Liechtenstein or Norway, you may only pay into one country’s social security scheme at a time

This will usually be the UK, if that is where the work is being done.

In the UK, social security contributions are called National Insurance contributions.

Paying social security contributions in the EU whilst working in the UK

The UK has social security agreements with the EU.

You’ll continue to pay social security contributions only in the EU, if you have been issued with the relevant certificate as evidence from the social security institution in that country. You, or your employer, should apply for a certificate from the social security institution if you’re:

  • coming from the EU to work temporarily in the UK for up to 2 years
  • working in one or more EU countries and the UK
  • a civil servant working for an EU Government
  • working on board a vessel at sea, with an EU flag
  • working as a flight or cabin crew member, where your home base is in the EU

The relevant certificate or document is not a work permit. You’ll need to check the UK’s immigration rules if you’re not lawfully resident in the UK.

Paying social security contributions in Switzerland whilst working in the UK

The UK has social security agreements with Switzerland.

You’ll continue to pay social security contributions only in Switzerland if you have been issued with the relevant certificate as evidence from the social security institution in Switzerland. You or your employer should apply for a certificate from the social security institution if you are:

  • coming from Switzerland to work temporarily in the UK for up to 2 years
  • working in Switzerland and the UK
  • a civil servant working for the Swiss Government
  • working on board a vessel at sea, with Swiss flag
  • working as a flight or cabin crew member, where your home base is in Switzerland

Working in the UK

If you’re covered by the EEAEFTA Separation Agreement

You’ll be covered by the EEAEFTA Separation Agreement if you’re a:

  • national of Iceland, Liechtenstein or Norway, who was resident or started working in the UK before 1 January 2021 and have been working here since
  • national of the UK, who was resident or started working in Iceland, Liechtenstein or Norway before 1 January 2021
  • family member of a UK national who has a right to reside in Iceland, Liechtenstein or Norway under the agreement and you’re residing in Iceland, Liechtenstein or Norway
  • person with dual nationality, one of which is the UK and one of which is Iceland, Liechtenstein or Norway
  • national of Iceland, Liechtenstein or Norway, who works in the UK and 1 or more countries of Iceland, Liechtenstein or Norway before 1 January 2021 and continue to do so, and you work mainly in Iceland, Liechtenstein or Norway
  • family member of a national of, Iceland, Liechtenstein or Norway who has status under the EU Settlement Scheme, and you are residing in the UK

If you’re covered by this agreement, you’ll continue paying social security contributions only in Iceland, Liechtenstein or Norway if the social security institution you have come from has issued you with the relevant certificate as evidence that this is the case. You, or your employer, should apply for a certificate if you’re:

  • coming to work temporarily in the UK for up to 2 years
  • working in one or more of Iceland, Liechtenstein or Norway and the UK
  • a civil servant working in the UK for the government of Iceland, Liechtenstein or Norway
  • working onboard a vessel at sea, with a flag of Iceland, Liechtenstein or Norway
  • working as a flight or cabin crew member, where your home base is in Iceland, Liechtenstein or Norway

The relevant certificate is not a work permit. You’ll need to check the immigration rules of the country you’re working in if you’re not lawfully resident there.

If you’re not covered by the EEAEFTA Separation Agreement

The UK also has social security agreements with Iceland and Norway which are sometimes called reciprocal agreements.

If you’re not covered by covered by the EEAEFTA Separation Agreement, you may be covered by a social security agreement. If so, you may still be able to apply to your social security institution for a certificate to show evidence that you are liable to pay social security contributions only in that country if you’re coming to work in the UK from:

Coming to work in the UK from Norway

You should apply to the relevant social security institution for a certificate as evidence that you’re liable to pay social security contributions only in Norway, if you’re working temporarily in the UK for up to 3 years. You should apply for a certificate before you come to work temporarily in the UK but must apply within the first 4 months of coming to work here. This means you’ll not have to pay National Insurance contributions in the UK for that duration of work.

Coming to work in the UK from Iceland

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

When you’ll pay social security contributions in the UK

If you are coming here to work and you are not covered by a social security agreement and so are not eligible for a certificate or document from the social security institution you’re coming from, you’ll need to pay National Insurance contributions in the UK.

However, you will not need to pay National Insurance contributions for the first 52 weeks of your employment in the UK, if:

  • you’re not ordinarily resident in the UK
  • you normally work outside the UK for a foreign employer
  • you’re sent to work in the UK for a time by your foreign employer
  • when in the UK you continue to work for your foreign employer (even if your foreign employer has a place of business in the UK)

HMRC consider you’re ordinarily resident in a country if you:

  • normally live there, apart from temporary or occasional absences
  • have a settled and regular mode of life there

For more information about when you must pay Class 1 National Insurance contributions and ordinarily resident read leaflet NI38.

How to apply for a certificate or document

If you’re resident in the EU, Iceland, Liechtenstein, Norway or Switzerland and work in that country, contact the social security institution in the country you reside in to find out if you can apply for a certificate as evidence to show that you are liable to pay social security there.

If you do not work in your country of residence but think you’re eligible for a certificate from the HMRC, follow the table to see how to apply:

Your circumstances Form to complete
You’re working in 2 or more of the UK, EU, Iceland, Liechtenstein, Norway or Switzerland. Form CA8421
You’re flight or cabin crew with a home base in the UK. Form CA8421
You work 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 CA3822
You’re a UK civil servant or other government worker. Form CA3822

If your situation changes

If you need to check if a change in your situation stops the existing social security rules from applying to you, send a letter to HMRC, telling them:

  • what your circumstances were
  • what has changed, for example, if your work, employment or self-employment ends earlier than expected, or you change employer
  • when the changes happened

You should send your letter to:

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

You do not need to include a street name or PO box in the address.

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

Published 26 December 2020
Last updated 1 November 2021 

Guidance

Social security contributions for workers coming to the UK from the EEA or Switzerland from 1 January 2021

Check where you need to pay social security contributions from 1 January 2021, if you’re a worker from the EU, Norway, Iceland, Switzerland or Liechtenstein working in UK.

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 pay your social security contributions will depend on your circumstances and the country you are coming from.

If you come to work in the UK from 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 UK if that is where the work takes place.

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

If you are a national of the EU, Norway, Iceland, Switzerland or Liechtenstein living in the UK before 1 January 2021, you should apply to the EU Settlement Scheme to protect your right to stay in the UK and your social security rights. The deadline for applications is 30 June 2021.

When you will continue to pay social security contributions in the EU, Norway, Iceland, Switzerland or Liechtenstein

The relevant certificate or document is not a work permit. You’ll need to check the UK’s immigration rules if you’re not lawfully resident in the UK.

You, or your employer, should apply for a certificate or document if you are coming to work temporarily in the UK and you’re a:

  • person lawfully resident in the EU who started working in the UK before 1 January 2021, and has been working here since
  • national of Iceland, Liechtenstein or Norway who started working in the UK before 1 January 2021 and has been working here since
  • national of Switzerland who started working in the UK before 1 January 2021, and has been working here since
  • national of the UK who was resident in the EU, Iceland, Liechtenstein, Norway or Switzerland before 1 January 2021
  • person with dual nationality, one of which is the UK and one of which is the EU, Norway, Iceland, Switzerland or Liechtenstein
  • multistate 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 an EU country, Norway, Iceland, Switzerland or Liechtenstein

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

You’ll also pay social security contributions in the EU if you’re a:

  • UK or Irish national, or any national lawfully resident in Ireland, coming to work in the UK
  • multistate worker working in the UK and one or more EU countries, and you are predominantly working in the EU

You’ll still be able to apply for a certificate or document to continue to only pay National Insurance in the country that you have come from if you are coming to work temporarily in the UK from the following countries:

EU countries that apply the ‘detached worker’ rules

You should continue paying social security contributions in the EU if you’re working temporarily for up to 2 years in the UK where the ‘detached worker’ rules apply. This means you will not have to pay social security contributions in the UK.

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 come to work in the UK before 1 February 2021 from a country that has not ‘opted out’ of the ‘detached worker’ rules, you should apply for a certificate or document from that country to continue paying social security contributions there.

If your work started before 1 February 2021 and you’re entitled to a certificate or document from the EU, you will continue paying social security contributions there unless your circumstances change (for example, you change your 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 paying 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 for a certificate or document to continue paying social security contributions in Norway if you’re working temporarily in the UK for up to 3 years. You should apply for a certificate or document before you come to work temporarily in the UK but must apply within the first four months of coming to work here. This means you will not have to pay National Insurance contributions in the UK for that duration of work.

Switzerland

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

Iceland

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

When you will pay social security contributions in the UK

You will need to pay social security contributions in the UK if you are coming here to work temporarily and you are not eligible for a certificate or document from the relevant EU country.

In the UK social security contributions are called National Insurance contributions.

How to apply for a certificate or document

If you’re resident in the EU, Norway, Iceland, Switzerland or Liechtenstein, contact the social security institution in the country you reside in to find out if you can apply for a certificate or document .

If you think you’re eligible for a certificate or document from the UK, follow the table to see how to apply.

Your circumstances Form to complete
You’re flight or cabin crew with a home base in the UK. Form CA8421
You’re working on a vessel at sea with a UK flag and you are either paid by someone based in the UK or in a country other than where you live Form CA8421 or CA3822

You do not need to apply for a certificate or document if you’re resident in the EU, Norway, Iceland, Switzerland or Liechtenstein and working permanently in the UK for a UK employer.

If your situation changes

If you need to check if a change in your situation stops the existing social security rules from applying to you, 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
Share this article

Contact McMahon Legal