No-deal Brexit contingency plans

IMPACT – MEDIUM

What is the Brexit news? The Finnish government has announced plans for how it would administer the status of U.K. nationals in Finland in the event of a “no deal” Brexit.

What does the news mean? On Jan. 25, the Finnish Cabinet Committee on European Union Affairs announced its plans to ensure that U.K. nationals will retain their rights to work, live, study and receive government benefits in the event of a “no deal” Brexit. While the specifics, including how long U.K. nationals would retain their current status post-Brexit, have not been determined, officials have stated that the draft legislation will only apply to registered U.K. nationals. Officials are therefore urging U.K. nationals to register with immigration authorities if they have not done so already.

• Implementation time frame: Immediate and ongoing.
• Who is affected: U.K. nationals living and working in Finland who have not registered with the Finnish Immigration Office.
• Next steps: Employees should ensure they are registered to prove pre-Brexit residence status by March 29.

Background: If there is not a withdrawal agreement, U.K. nationals in Finland will be considered third-country nationals on March 30. The Finnish government is drafting new legislation to address the effects of a “no deal” Brexit for U.K. nationals living and working in Finland. U.K. nationals will retain their current rights until at least the end of 2020. The government has made it clear that any measures intended to protect the rights of U.K. nationals will only apply to U.K. residents who have registered their right of residence at the Finnish Immigration Service by March 29. U.K. nationals who have resided in Finland for an uninterrupted period of five years are eligible to apply for a certificate of permanent residence as an EU citizen.

Analysis & Comments: The government’s proposals provide some certainty to employers and U.K. citizens in Finland. The changes will allow U.K. citizens registered with the immigration authorities to continue their right of residence in Finland until the end of 2020, after which they may be required to obtain residence permits. While the proposed measures will ensure that registered U.K. citizens and their family members will retain their residence rights during a temporary period, it is not clear how U.K. nationals would be covered after the transition period.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.