What Brexit changed: UK citizens are now treated as non-EU nationals
Until 31 December 2020, UK citizens enjoyed full EU freedom of movement and could live, work, and stay in Germany without a visa or residence permit. Since 1 January 2021, this no longer applies.
UK nationals are now treated like other non-EU third-country nationals (Drittstaatler) in Germany. This means:
What you now need that EU citizens don't:
- A German residence permit (Aufenthaltstitel) to stay longer than 90 days in any 180-day period
- A work visa if you want to be employed in Germany
- Going through the visa application process at the German consulate in the UK before moving
What hasn't changed:
- UK citizens do NOT need a visa for short stays (tourism, business visits) under 90 days — the UK-EU visa-free arrangement for short stays remains in place
- UK qualifications are still widely recognised in Germany (degree equivalence is assessed by APS or Anabin database)
- The UK-Germany bilateral Social Security Agreement remains in force (separate from the EU social security coordination it replaced)
Who is exempt from these new rules:
- UK citizens who were legally resident in Germany before 31 December 2020 and obtained a Niederlassungserlaubnis (permanent residence permit) or registered under the EU Settlement Scheme equivalent — they retain their status
- Family members of German citizens
Visa routes from the UK: Blue Card, skilled worker, freelance, family
EU Blue Card (most common for employed professionals) Available to UK citizens with:
- A university degree (any nationality, including UK degrees) equivalent to at least a German bachelor's (most UK degrees from UCAS-listed universities qualify)
- A German job offer with gross salary of at least €48,300/year (2025, standard fields) or €43,759.80/year (shortage occupations: IT, engineering, medicine, maths, physics)
The Blue Card gives 4-year residence, after which you can apply for permanent residence (Niederlassungserlaubnis) — after just 21 months if you have B1 German, otherwise after 33 months. It also covers your spouse and children.
Skilled worker visa (Fachkräftevisum) For UK professionals with a job offer but below Blue Card salary threshold, or in non-shortage occupations. Requires:
- Recognised German-equivalent qualification (use Anabin database to check your degree)
- Job offer in your field
- Basic German (A1 in some cases, often not required for IT/technical roles)
Freelance visa (Freiberuflervisum) For UK self-employed professionals (designers, journalists, artists, consultants, software developers):
- Must demonstrate sustainable income and German clients or viable business plan
- German at A1/B1 level may be required depending on the Ausländerbehörde
- More subjective than employment visas — approval varies by city
Family reunification If your German spouse or EU citizen spouse/partner is in Germany, you can apply for family reunification. Often requires A1 German (Grundkenntnisse) before entering, though exceptions apply if the German spouse can demonstrate you will learn.
Job seeker visa Allows qualified UK professionals to look for a job in Germany for 6 months:
- German or internationally equivalent university degree
- Proof of financial means (approx. €6,000–10,000)
- Language proof (German or English)
- Apply at German consulate in UK
UK-specific documents: DBS, apostille, qualifications
DBS check (police clearance) Some German visa applications and professional roles require a police clearance certificate. In the UK, this is a DBS (Disclosure and Barring Service) Basic Certificate. Apply at gov.uk/request-copy-criminal-record.
Apostille for UK documents The UK is part of the Hague Apostille Convention. UK documents (degree certificates, birth certificates, marriage certificates) need an apostille from the Foreign, Commonwealth and Development Office (FCDO). Apply at gov.uk/get-document-legalised.
Qualification recognition UK qualifications are assessed for German equivalence using:
- Anabin database (anabin.kmk.org): check whether your UK university and degree are already classified
- APS (Akademische Prüfstelle): for degrees from countries with complex assessment requirements (less relevant for UK)
Most degrees from UCAS-listed UK universities are recognised without formal assessment for the Blue Card. Regulated professions (doctors, nurses, lawyers, architects, teachers) need profession-specific Berufsanerkennung — check with the relevant German regulatory body.
Certified German translations Documents in English submitted to German authorities may need certified German translations (beglaubigte Übersetzungen) by a sworn translator (vereidigter Übersetzer). The German Embassy in London has a list of accepted translators.
First steps after arriving: Anmeldung, NHS → GKV, bank account
Anmeldung (address registration) — within 14 days Register your address at the Einwohnermeldeamt. Bring your passport, your residence permit (or appointment letter if still in process), and the Wohnungsgeberbestätigung from your landlord. This unlocks your German tax ID (Steuer-ID, arrives by post in 2–4 weeks) and enables health insurance enrollment.
Health insurance: from NHS to GKV UK nationals moving to Germany are not covered by the NHS once they no longer live in the UK — the NHS covers UK residents, not expats. From your first day of employment in Germany, you are covered by GKV.
If you're employed: your employer notifies the GKV of your start date. Sign up with TK (Techniker Krankenkasse), Barmer, AOK, or another GKV before day one — they have English-speaking service and simple online enrollment.
If you're freelancing: you can voluntarily join a GKV (freiwillige Versicherung) by applying directly. Your premium is based on your income.
If you're between jobs or still sorting the visa: travel insurance covering Germany until your GKV starts.
Bank account Open a German bank account after Anmeldung. N26, DKB, and ING offer straightforward online account opening. You will need your Meldebestätigung (Anmeldung certificate) and passport.
HMRC deregistration Inform HMRC that you are leaving the UK — complete the P85 form (gov.uk). This determines your UK tax residency status from the date you leave, which affects whether you still owe UK income tax.
UK driving licence in Germany: the post-Brexit rules
The rules changed with Brexit. Before Brexit, UK driving licences were treated like EU licences (no conversion needed). After Brexit, the situation depends on when you moved:
If you moved to Germany while the UK was still in the EU (before 31 December 2020): Your UK licence continues to be treated as an EU licence in Germany. You can keep driving on it until it expires and then renew it in Germany.
If you moved after 31 December 2020 (post-Brexit): Your UK licence is no longer treated as an EU licence. You can drive in Germany on your UK licence for:
- 6 months from your Anmeldung date — then you must exchange or convert
The good news: UK is on Germany's bilateral exchange list — meaning conversion is largely administrative (no full theory or practical test required):
- You surrender your UK licence
- You take a simple eye test and pay a fee
- You receive a German driving licence (Führerschein) in exchange
- No theory test, no practical test required
This is very different from Indian, US, or other non-bilateral-country licences that require full conversion. Apply at the Führerscheinstelle (licensing office) in your municipality.
UK State Pension, NI contributions, and the UK-Germany Social Security Agreement
The UK-Germany Social Security Agreement (Sozialversicherungsabkommen) replaced the EU coordination framework that applied when the UK was in the EU. It remains in force and covers:
National Insurance (NI) contributions: While working in Germany, you contribute to the German Rentenversicherung (pension system), not NI. However:
- Years worked in Germany count towards your qualifying years for German pension
- Years worked in the UK count towards your UK State Pension
- The bilateral agreement coordinates these so your total qualifying years in both countries count for each country's pension separately
UK State Pension: You may still qualify for a UK State Pension based on your NI record at retirement age, even if you live in Germany. NI gaps can be filled by voluntary Class 2 or Class 3 NI contributions — worth considering if you have gaps.
German Rentenversicherung: After 5 years of German pension contributions, you have a vested pension entitlement from Germany paid at German retirement age.
For the first 2 years working abroad: Some UK employees remain in the UK social security system (and pay NI, not German Rentenversicherung) if they are posted to Germany by a UK employer. This requires an A1 certificate from HMRC.
Already living in Germany before Brexit? Your status explained
If you were legally resident in Germany before 31 December 2020, the Withdrawal Agreement protects your rights.
What you should have (if you registered correctly): A Aufenthaltserlaubnis (residence permit) issued under Article 18 of the Withdrawal Agreement. This is sometimes called the "Brexit residence permit" and gives you the right to stay indefinitely in Germany under the terms you had as an EU citizen — as long as you continue to meet the conditions (work, self-sufficiency, or family connection).
If you never formalised your status (didn't get this permit): Contact the Ausländerbehörde immediately. There was a deadline of 30 June 2021 to apply under the Withdrawal Agreement — if you missed it, you may need to apply for a regular third-country national residence permit. Legal advice (Migrationsrecht) is worth getting for your specific situation.
Long-term residency (Niederlassungserlaubnis): If you have lived in Germany for 5+ continuous years and meet the conditions (language, income, pension contributions), you may already be entitled to permanent residence — regardless of Brexit. Apply at the Ausländerbehörde.