HomeGuidesMoving from the UK to Germany — Post-Brexit Expat Guide

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Post-Brexit, UK nationals are now third-country nationals in Germany. This guide covers the residence permit, work permit, business registration, and tax implications.

2026
8 min read

Post-Brexit Status for UK Nationals in Germany

The UK left the EU on 31 January 2020 (Brexit). UK nationals are now treated as third-country nationals under German and EU law.

CategoryPre-2021 ArrivalPost-2021 Arrival
Residence rightProtected by Withdrawal AgreementMust obtain Aufenthaltserlaubnis
Work rightExisting rights preservedRequires work permit or appropriate visa
Free movementEWR rights retained if registered by 30.06.2021No longer applicable
British citizenshipUnchangedUnchanged (Brexit only affects residency)
German naturalisationCan apply after 5 yrs residenceCan apply after 5 yrs residence

UK nationals who registered with German authorities (Einwohnermeldeamt) before 30 June 2021 received a Aufenthaltsdokument-GB confirming their Withdrawal Agreement rights. This is a permanent document — it does not expire. If you did not register by this deadline, you must obtain a new German residence permit based on your employment, family, or self-employment status.

Residence and Work Permits for New UK Arrivals

UK nationals arriving in Germany after January 2021 must apply for a German residence permit (Aufenthaltserlaubnis) from the local Ausländerbehörde. Options:

  • Employment (§18 AufenthG): with German job offer and recognised qualification — employer usually initiates the application
  • EU Blue Card (§18g AufenthG): for highly qualified professionals with salary ≥€48,300/year (lower for shortage occupations: ~€37,440)
  • Self-employment (§21 AufenthG): for entrepreneurs with a viable business plan and IHK assessment
  • Chancenkarte (§20a AufenthG): new in 2024 — points-based job seeker card for qualified applicants without a job offer yet
  • Family reunification (§28/§30 AufenthG): joining a German spouse or family member

UK Businesses Expanding to Germany Post-Brexit

Post-Brexit, UK companies lost EU single market access. Implications for UK businesses in Germany:

  • UK company services to German clients: now subject to cross-border service restrictions and potential German establishment requirements
  • Goods exports UK → Germany: full EU customs procedures, EORI number, customs duty, import VAT
  • German establishment required: for ongoing German market presence, a German GmbH subsidiary or registered branch is needed to avoid PE risk
  • VAT: UK no longer in EU VAT area — UK companies making German supplies must register for German VAT
  • Professional services: UK lawyers, accountants, architects need separate recognition in Germany post-Brexit

Frequently Asked Questions

Do UK nationals need a visa to move to Germany?

UK nationals can enter Germany visa-free for up to 90 days within any 180-day period (standard Schengen rules). For stays longer than 90 days, a German residence permit (Aufenthaltserlaubnis) is required. This must be applied for before the 90-day period expires, at the local Ausländerbehörde. Entry without a valid residence permit beyond 90 days is an immigration violation.

Can UK professionals get their qualifications recognised in Germany?

Yes — under the EU-UK Trade and Cooperation Agreement, the UK and Germany maintain mutual recognition pathways for some professions. Regulated professions (doctors, nurses, architects, engineers) can apply for recognition via the respective German Kammer or Landesbehörde. The ANABIN database and the "Anerkennung in Deutschland" portal guide the process. Processing typically takes 2–4 months. We assist with the recognition process for clients.

What taxes does a UK national in Germany have to pay?

A UK national with German residence is subject to unlimited German tax liability (unbeschränkte Steuerpflicht) on worldwide income from the moment of registration. Employment income, self-employment, investments, and foreign-source income (subject to German-UK DTA provisions) are all taxable in Germany. The UK-Germany Double Tax Agreement (in force, unaffected by Brexit) prevents double taxation in most cases.

Can a UK company send employees to work in Germany?

Yes — posted workers from UK to Germany are allowed under the EU-UK TCA, but German employment law applies from day one for employees working in Germany. AEntG (Arbeitnehmer-Entsendegesetz) posting rules mandate German minimum wage and working conditions. For postings over 8 days, the employer must register with the Zoll (customs) Meldepflicht system. For long-term assignments, a German work permit or company-internal transfer permit may be required.

How does German health insurance work for UK nationals?

UK nationals living in Germany must have German health insurance. Employees with salary ≤€73,800/year (2026 threshold) are automatically covered by statutory GKV health insurance (employer contributes ~50%). Higher earners and self-employed can choose private health insurance (PKV). EHIC / GHIC cards provide emergency coverage for visits but do not substitute for German health insurance for residents. The UK S1 certificate (for UK pension recipients) can provide some coverage.

Do UK nationals need to register with the Einwohnermeldeamt when moving to Germany?

Yes — all residents of Germany (regardless of nationality) must register with the local Einwohnermeldeamt (residents' registration office) within 2 weeks of establishing a permanent address. This Anmeldung (registration) provides a Meldebescheinigung (registration certificate), which is required for opening a bank account, obtaining a Steuernummer, and applying for a residence permit. Failure to register is an Ordnungswidrigkeit (administrative offence).

Can UK nationals access the German state pension (Rentenversicherung)?

UK nationals who work in Germany contribute to the German Rentenversicherung (statutory pension insurance) on the same basis as German nationals. Contributions made in the UK before Brexit can be taken into account for qualifying periods under the UK-Germany Social Security Convention. NI contributions from the UK do not directly transfer as pension entitlements — but UK National Insurance years may count toward qualifying the minimum contribution period for a German Rente. Check with the Deutsche Rentenversicherung Bund for your personal position.

What driving licence rules apply for UK nationals moving to Germany?

UK nationals with a UK driving licence can use it in Germany for the first 6 months after establishing residence. After 6 months, the UK licence must be exchanged for a German licence (Fahrerlaubnis) without requiring a new test — a straight exchange is possible (Führerscheinumtausch) for most UK licence categories within the EU-UK TCA framework. Apply at the local Führerscheinbehörde. The exchange fee is approximately EUR 40–100. After 3 years from Brexit, the direct exchange right may be reviewed — check current rules at fahrerlaubnis.de.

How do I transfer my UK pension to Germany?

UK private pensions (SIPPs, workplace pensions) cannot be directly transferred to German pension schemes. UK state pension (National Insurance contributions) does not transfer to Germany but can still be claimed from the UK DWP when you reach UK state pension age, even if you live in Germany. The UK-Germany Double Taxation Agreement prevents double taxation of UK pension income for German residents — usually by allowing Germany to tax it while providing credit for any UK withholding.

What are the German Anmeldung (registration) requirements for UK businesses?

A UK company providing services to German clients on an ongoing basis may be required to register a Zweigniederlassung (branch) or establish a subsidiary GmbH if it has a fixed place of business in Germany. Even without a physical office, regular activities performed by staff based in Germany can create a Betriebsstätte (permanent establishment) triggering German corporate tax obligations. Post-Brexit, UK companies no longer benefit from the EU freedom of establishment — German market presence now requires formal German company registration for most activities.

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