From EU Citizens to Third Country Nationals via Brexit: The Unfolding Reality for UK Citizens Living in the EU

Working Paper
Orsolya Farkas


With Brexit UK nationals lost EU citizenship and this fact profoundly changes the way they can exercise the right to free movement and residence. This paper considers some of the difficulties UK citizens can easily face if they want to reside in the EU. The Withdrawal Agreement safeguards the residence rights of those who exercised their free movement rights and continue to do so after the end of 2020, but the implementation of the measures reserves challenges for many applicants. Those who want to move to the EU from 2021 fall under the category of Third Country Nationals and they must meet more restrictive requirements than EU citizens. Some segments of the labour market might even remain closed to them. Despite these findings it is argued that the Trade and Cooperation Agreement opens the way towards an ambitious relationship between the EU and the UK: it contains provisions related to labour mobility and if they are fostered with a cooperative and creative spirit, they can contribute to the construction of a special partnership.