Ten groups representing British citizens in continental Europe have sent an “alternative white paper” to MPs and peers demanding their rights be prioritised in the UK’s EU exit talks and firmly guaranteed in the future divorce agreement.

“These are real people, with real lives and real problems, who moved to other EU countries legitimately believing their EU citizenship rights were irrevocable,” said Jane Golding, a lawyer based in Germany, who co-wrote the paper. “They cannot be left in this situation.”

On the day the government published its formal Brexit white paper, the document, drawn up by groups in Germany, France, Belgium, Spain and Italy, urged it to recognise as its key principle that UK citizens currently in the EU must be “expressly treated as continuing to have the same rights as they did before Brexit”.

Those rights should not be confined to residence but must include the continued rights to acquire citizenship, study, have academic and professional qualifications recognised, work, run a business, move freely between EU member states, and receive healthcare, pensions and other social benefits, they said.

“The EU citizens’ rights we have now are indivisible,” said Golding, who has lived and worked for more than 20 years in France, Belgium, Italy and Germany. “That’s what they must remain – you can’t really take away any one of these rights without the operation of the others being affected.”

Golding noted that a continued right to permanent residence would plainly be critical for all the estimated 900,000 UK citizens living in other EU countries who wanted to stay there, but that beyond that, priorities often differed.

“For some, the right to residence will be worthless without the right to work, receive equal treatment as nationals of the country they are in, be self-employed, own and run a company, even commute across an EU border,” she said.

“For others, particularly people who have retired, the continued right to receive reciprocal cross-border healthcare, and of course an index-linked state pension from the UK, will obviously be the biggest things weighing on their minds.”



The report gives two examples of very different cases to illustrate the wide range of rights that it argues will need to be addressed in Brexit discussions and explicitly agreed in the article 50 deal on the UK’s divorce from the EU.

One is that of a UK professional in their 40s – for example, a doctor or architect – whose professional qualifications are recognised under EU mutual recognition agreements, working in Italy, with a mortgage and a young family born there.

“Recognition of qualifications falls away upon Brexit, and requalification under Italian regulations is required – a full-time, three-year course,” the paper suggests. “How does a right of residence alone help if this person is without an income during that period and cannot maintain him/herself and family?”



Another case imagines a British pensioner living in Spain, entirely dependent on a state pension – which may no longer be automatically uprated after Brexit. Imagine, the paper said, they “become seriously ill, and are not entitled to healthcare under the Spanish system. Then what avail is right of residence?”

Dave Spokes of ECREU, a group in France which represents more than 6,000 UK citizens in 25 EU countries, said people were frightened, with healthcare and pensions members’ biggest concerns. “Pensions are a huge, ticking time bomb of an issue,” he said.

“We have people who have spent most of their working lives abroad, in several different EU countries, and have accrued pension rights in all of them – what’s going to happen to those? How is the Department for Work and Pensions going to deal with them? It’s crucial that gets settled and pensions are assured.”

Golding said she had heard “encouraging noises”, and was reassured by the House of Lords’ Europe committee’s assertion last year that UK citizens’ EU rights must be safeguarded in the withdrawal agreement and frozen at the date of Brexit. But, she said, “Nothing is guaranteed until it is guaranteed.”