After Brexit: moving to the EU from the UK
For UK citizens planning a move to Spain, Portugal, France, Italy or elsewhere in the EU. What changed in 2021, the 90-day rule, the new border checks, and the visas open to Britons now.
Before 2021, a UK passport let you live and work anywhere in the EU. That ended when the Brexit transition period finished on 1 January 2021. UK citizens without earlier residence rights are now “third-country nationals” in the EU, treated much like Americans or Canadians. Moving is still very possible. It now takes a visa, some paperwork and a money test. This guide covers what changed and the main routes open to you.
What changed for UK citizens
- You need a visa or permit to live or work. Visits are still visa-free, but anything longer, or any work, needs a national visa or residence permit from the country you choose.
- The 90-day rule applies. You can stay in the Schengen area for up to 90 days in any rolling 180-day period. Those days count across all Schengen countries together.
- Your entries are recorded. The EU’s Entry/Exit System (EES) records your fingerprints, photo and each entry and exit at Schengen borders.
- ETIAS is coming. UK visitors will need this travel authorisation once it starts.
- There is no youth mobility scheme yet. A UK-EU “youth experience scheme” was agreed in principle in May 2025. Negotiations were still going on in 2026.
If you lived in an EU country before 1 January 2021, you may hold residence rights under the Withdrawal Agreement. GOV.UK’s “Living in Europe” guidance explains these rights.
The 90-day rule and the new border checks
The 90-in-180 rule is the one that catches people. It is a rolling window, so on any day you count back 180 days and add up the days you spent in the Schengen area. Overstaying can bring an entry ban; GOV.UK cites up to three years.
The Entry/Exit System started on 12 October 2025 and became fully operational at all external borders on 10 April 2026. It replaces passport stamps and calculates your 90 days automatically. Expect a longer first crossing while your biometrics are taken. Once you hold a residence permit, show it at the border so your days are not counted against you.
ETIAS is not running yet, and no applications are being taken. The EU will announce the start date several months ahead. Press reports point to 2027. When it starts, it will cost EUR 20, with people under 18 or over 70 exempt. It will last three years or until your passport expires. Any site taking ETIAS applications today is not official.
Two EU countries sit outside Schengen: Cyprus and Ireland. Days there count separately. Neither operates the EES.
Ireland: the exception
UK citizens do not need any permission to live or work in Ireland. This comes from the Common Travel Area between the UK and Ireland. If Ireland appeals, it is the simplest EU move for a Briton. See our guide to moving to Ireland.
Routes worth a look
Every EU country runs its own visas. These routes are open to UK citizens and cover the most common reasons to move: retiring, living on savings, or working remotely. The key money figure is for 2026.
| Country | Route | Who it fits | Key money figure |
|---|---|---|---|
| Spain | Non-Lucrative Visa | Retirees, people on savings | EUR 28,800 a year |
| Spain | Digital Nomad Visa | Remote workers | About EUR 2,849 a month |
| Portugal | D7 visa | Pensions, passive income | EUR 920 a month |
| Portugal | D8 Digital Nomad Visa | Remote workers | EUR 3,680 a month |
| France | Visitor visa | Retirees, people on savings | EUR 1,477.93 net a month |
| Italy | Elective residence visa | Retirees with passive income | About EUR 31,000 a year (consulate practice) |
| Croatia | Digital nomad stay | Remote workers | EUR 3,622.50 a month |
A few points to know before you choose:
- Spain’s non-lucrative visa allows no work at all, including remote work for UK clients. To renew, you must live in Spain at least 183 days each year.
- Portugal’s D7 must be passive income. Consulates commonly add amounts for a partner and children, and many want savings in a Portuguese bank. These are consulate practice, not figures on the visa page.
- France’s visitor visa needs a written promise not to work. From 1 January 2026, multi-year cards also need a civic exam and higher French levels.
- Italy sets no legal threshold. Consulates abroad use about EUR 31,000 per person as a guide and may expect more.
See each country’s page for every route, including work permits and ancestry routes.
Health care and tax
Long-stay visas set their own health insurance rules, usually stricter than travel cover. Spain’s non-lucrative visa, for example, needs a policy from an insurer authorised in Spain with no deductible, no co-payment and no coverage limit. Travel insurance does not count. Check what your route accepts before you buy a policy.
Moving changes your tax position too. In Spain and Portugal, spending 183 days or more a year there makes you tax resident, taxed on worldwide income. Other countries set their own tests. Spain and Portugal each have special regimes for some workers, but most retirees do not qualify. Speak to an adviser who knows both the UK and your new country before you move pensions or savings.
What catches people out
- Old advice is everywhere. Guides written before 2021 assume free movement. Check the date on anything you read.
- Long-term thinking about citizenship. Spain asks new citizens from the UK to formally renounce their old nationality. Portugal now asks for 10 years’ residence before naturalisation. Ireland, by contrast, needs no visa at all.
- Counting days wrongly. The 90 days are shared across every Schengen country. A month in France and two in Spain use up your whole allowance.
- Waiting for a youth scheme. No UK-EU youth mobility scheme existed in 2026. Younger Britons need a standard visa for now.
This is general information, not legal, tax or immigration advice. Confirm every requirement with GOV.UK and the official source for your chosen country before you act.