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BREXIT – Iceland, Liechtenstein, Norway and UK Agree on Citizens’ Rights After Brexit [UPDATED]

The UK has reached a separation agreement with Iceland, Liechtenstein and Norway (‘the EEA EFTA States’), including a deal on citizens’ rights.

On citizen’s rights, the separation agreement largely mirrors the withdrawal agreement agreed with the EU. It protects rights in relation to residency, social security and the recognition of professional qualifications which are currently provided by the EEA Agreement. The UK will remain bound by the EEA Agreement, for the duration of the transition period which is part of the withdrawal agreement.

The separation agreement will be concluded before exit day and, alongside the withdrawal agreement, it will be legislated for through the EU (Withdrawal Agreement) Bill.

The separation agreement does not cover a no-deal scenario.


On 8 February 2019, the UK, Iceland, Liechtenstein and Norway reached an EEA EFTA No Deal Citizens’ Rights Agreement to protect the rights of UK nationals living in the EEA EFTA states and EEA EFTA nationals in the UK, in a no deal scenario.

What rights are protected?

  • All UK nationals and their family members lawfully residing in an EEA EFTA state by the end of the withdrawal agreement's transition period (31 December 2020) or by Brexit day (in a no-deal scenario) will be able to stay, as will all EEA EFTA nationals lawfully residing in the UK.
  • Individuals in scope of the agreement can be joined by close family members (spouses, civil and unmarried partners, dependent children and grandchildren, and dependent parents and grandparents) who live in a different country at any point in the future, if the relationship existed by by the end of the transition period (or by Brexit day in a no-deal scenario) and still exists when the person wishes to come to the UK.
  • Any child born to an individual in scope is also protected if the individual has custody of the child.
  • The agreements also protect the rights of those citizens who reside in one state and work in another (‘frontier workers’).
  • In the UK, EEA EFTA nationals and their family members can apply for a residence status through the EU Settlement Scheme. The EEA EFTA states have a choice whether to require UK nationals and their family members to apply for a residence status or not.
  • EEA EFTA professionals resident or frontier working in the UK, or vice versa, will continue to have their professional qualifications recognised, where they obtained or applied for a recognition decision before the end of the implementation period.

Action Items

  • Employers who may be affected are encouraged to contact their immigration provider for case-specific advice.
DISCLAIMER: The information contained in this immigration alert has been abridged from laws, court decisions, and administrative rulings and should not be construed or relied upon as legal advice. If you have specific questions regarding the applicability of this information, please contact Peregrine © 2021 Peregrine Immigration Management Ltd.