What will happen to UK citizens living in the EU under a no-deal Brexit?

You may have missed it in the avalanche of Brexit coverage, but many British citizens living in other EU countries still don’t know what’s going to happen to them on 29 March.

In the case of a deal, some rights are protected – though some will still face disruption. But in the case of a no deal, which Theresa May says is still an option, many UK nationals living abroad are likely to face serious problems.

Here’s everything we know about what will happen to them.

There’s no certainty, and it varies by country. Brussels has advised member states to let British citizens stay on the same terms, but ultimately, in the absence of an EU-wide agreement, it is a matter for each individual government.

Some countries, such as France and Belgium, have been proactive and made clear what will happen to UK nationals. However, others haven’t announced or confirmed their plans – because they are waiting to see what the UK government does. Their approach is based on reciprocity.

Apart from the right legally to live and work in the applicable country, there are two main areas where no deal will cause a major problem: healthcare and pensions.

Currently British nationals are entitled to so-called S1 healthcare under EU rules. The British government has said it cannot guarantee that this will continue under a no deal – so many pensioners, posted workers and some students could lose their healthcare rights.

Some countries such as France have said S1 healthcare will continue for two years, while Denmark is also thought to be making plans to keep it. But most other member states haven’t given many clues as to what will happen.

European countries’ social security systems are coordinated at an EU level.

A no-deal outcome would call into question the payment of some pensions: specifically ones where a person has worked in a number of EU countries. Currently, EU member states recognise pension contributions made in other EU countries – but under a no deal people could see their pots effectively reduced or contributions derecognised. An agreement to resolve this situation would have to be done at an EU level.

One in five of the 1.2 million British citizens living in the EU are pensioners, and many who retired abroad have worked in various places – so this is not an insignificant problem.

The Costa amendment called for the ringfencing of the rights of EU citizens in the UK and British citizens living abroad.

It’s effectively an instruction on the government to say, no matter what happens with the rest of the withdrawal agreement, let’s enact the part about citizens’ rights to keep personal disruption at a minimum.

The prime minister wasn’t keen, and Alberto Costa lost his job as permanent private secretary for tabling it. But after significant confusion the government relented.

The reason Costa is important is because some protections for citizens cannot be negotiated on a country-by-country basis – such as pensions – but need to be done at the level of EU cooperation.

Still, the EU would have to agree on this as well – and so far they’ve been reluctant to make what they call “side-deals”.

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