Brexit Update – The Time is Now

Sweden: Brexit Update – The Time is Now

In this TaxNews Brexit Update, we look at what we know about the possible Brexit outcomes for Global Mobility Services professionals and their employees, as they affect Sweden and the UK.



Victoria Robinson


KPMG i Sverige


The EU and the UK have yet to negotiate a deal following the transition period end on 31 December 2020. With only 7 weeks to go until this date, now more than ever before, it is essential that businesses who have not already done so get ready for all possible outcomes at the end of the transition period.

In this TaxNews Brexit Update, we look at what we know about the possible Brexit outcomes for Global Mobility Services professionals and their employees, as they affect Sweden and the UK.

Migration – What we Know

On 11 November 2020, the Swedish Riksdag formalised the arrangements for British nationals who will enter Sweden prior to the end of the Brexit transition period, which ends on 31 December 2020. It has now been confirmed that any British citizens who arrive in Sweden to live, work and study prior to 31 December will retain their right to remain in Sweden.

For such British citizens, a new ‘residence status’ has been introduced, and from 1 December 2020, an application can be made to the Swedish Migration Agency to obtain this.

To make the process as time efficient as possible, the Migration Agency will introduce a special web application exclusively for British nationals which will allow a whole family to file a single application. The application can be made any time from 1 December 2020 to 30 September 2021, during which time British nationals can remain in Sweden without a special permit. Once granted, the residence status will apply indefinitely, but the certificate will need to be renewed every 5 years.

The position for UK nationals arriving in Sweden after Brexit remains unclear, but it is likely that they will be treated the same way as all third country nationals arriving in Sweden.

United Kingdom
For Swedish nationals who arrive in the UK prior to 31 December 2020, an application must be made to the EU Settlement Scheme prior to 30 June 2021 to protect the right to remain in the UK post-Brexit.

The UK has released its Statement of Changes to UK Immigration. Many of the changes will come into force from 09:00 on 1 December 2020 in order to prepare for the end to Freedom of Movement between the UK and the EU. From 1 January 2021, all foreign nationals (including EU nationals) will be subject to the new immigration rules. Companies should make themselves aware of the new immigration rules for relocating and visiting employees to the UK.

Social Security – What We Know

In the event of the UK’s departure from the EU on 31 December without any further agreement, the EU Commission has confirmed that social security entitlements acquired by EU27 or UK nationals prior to 31 December 2020 will be protected.

However, in the absence of any new agreement, EU Social Security Coordination rules including the rules for Posted Workers will cease to apply to any new cross border arrangements. New rules between Sweden and the UK will have to be agreed at a country level. The existing bi-lateral agreement between the two countries is somewhat insufficient and outdated, particularly, with respect to multi-state workers. If this bi-lateral agreement is not renegotiated, there is a risk that social security may be payable in both Sweden and the UK.

The UK government has confirmed that any A1 certificates granted prior to the end of the transition period with an end date after 1 January 2021 will remain valid until the end date on the certificate.

Sweden has not yet confirmed the final position on A1 certificates after Brexit, but the most recent information available suggests the possibility that A1 certificates may be revoked in the event of a no-deal exit. This is inline with current EU guidance on the potential implications of a no deal exit.

Health insurance – What we Know

European Health Insurance Cards and S1 reciprocal schemes may cease to be valid for cross-border UK/EU healthcare. Employers should therefore carefully review their healthcare insurance policies for their employees.

Brexit Mobility Clinic

At KPMG, we understand that particularly in the current climate, Brexit has slipped down the focus list for many Mobility stakeholders. We have a range of support options to assist with all your Brexit planning requirements including employee audit strategy, process administration solutions and bespoke advice. Please contact us for more information.

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The article in Swedish

Victoria Robinson
Global Mobility Services
+46 72 186 90 02

Heléne Markström
Global Mobility Services
+46 73 327 22 08

Nina Holgersson
Global Mobility Services
+46 70 698 96 09

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