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UK-Spain Social Security Agreement

Understanding social security coordination between the UK and Spain after Brexit: Withdrawal Agreement, Trade and Cooperation Agreement, posted workers, pensions, and healthcare.

After Brexit, UK-Spain social security coordination is governed by two separate agreements depending on when you moved and your circumstances. This guide explains which agreement applies to you and what it means for your social security contributions, healthcare, and pension rights.

Two Agreements: Which One Applies?

Your social security rights depend on when you moved to Spain:

1. Withdrawal Agreement (WA)

Applies to: UK nationals who moved to Spain before January 1, 2021

  • Protects rights for UK nationals who were already living in the EU before Brexit
  • Provides permanent protection similar to pre-Brexit EU coordination rules
  • Covers healthcare, pensions, social security coordination, and aggregation of periods
  • If you moved before 2021 and continue living in Spain, you're protected by the WA indefinitely

2. Trade and Cooperation Agreement (TCA)

Applies to: UK nationals who moved to Spain on or after January 1, 2021

  • The new agreement governing UK-EU social security coordination post-Brexit
  • Provides similar (but not identical) rights to the WA
  • Covers posted workers, multi-state workers, pensions, and healthcare in some situations
  • Does not cover all the same scenarios as EU coordination rules (e.g., no European Health Insurance Card for tourists)

Not sure which applies to you? See our guide on which agreement applies by move date.

Before January 2021: Withdrawal Agreement Rights

If you moved to Spain before January 1, 2021, and registered as a resident, you're protected by the Withdrawal Agreement.

Key rights:

Healthcare access:
  • If you worked in the UK and moved to Spain before 2021, you can use an S1 form to access Spanish healthcare (the UK pays)
  • If you're a UK state pensioner living in Spain, you can also use an S1 form
  • If you work in Spain, you're covered by the Spanish healthcare system
Pension aggregation:
  • Your UK and Spanish social security contributions are aggregated when calculating pension entitlement
  • If you worked 10 years in the UK and 10 years in Spain, both countries will count all 20 years towards your pension eligibility
  • Each country pays a proportion of the pension based on how long you worked there
Social security coordination:
  • If you work in multiple countries, you're covered by one system (usually where you work most)
  • Unemployment benefits can be exported for up to 3 months while looking for work in Spain
  • Family benefits can be claimed from the country where you work, even if your family lives in the other country

After January 2021: Trade and Cooperation Agreement

If you moved to Spain on or after January 1, 2021, you're covered by the TCA.

Key differences from the WA:

Healthcare:
  • No EHIC for tourists: The European Health Insurance Card is no longer valid for UK nationals visiting Spain (except those covered by the WA). You need private travel insurance.
  • S1 still available: UK state pensioners living in Spain can still use an S1 form to access Spanish healthcare
  • Workers: If you work in Spain, you're covered by Spanish healthcare as before
Pension aggregation:
  • Still available: UK and Spanish contributions are still aggregated under the TCA
  • If you worked in the UK before moving to Spain, those years still count towards Spanish pension eligibility
Posted workers:
  • If your UK employer sends you to work temporarily in Spain (up to 24 months), you can continue paying UK social security instead of Spanish
  • You need an A1 certificate (see below)
What's NOT covered by the TCA:
  • Unemployment benefit export (you cannot transfer UK benefits to Spain while looking for work)
  • Family benefits coordination (e.g., child benefit)
  • Some sickness and maternity benefits

Posted Workers (Temporary Assignments)

If you're a UK employee temporarily working in Spain (or vice versa), you can continue paying social security in your home country instead of the host country.

Requirements:

  • You must be sent by your employer (not moving of your own accord)
  • The assignment must be temporary (up to 24 months)
  • You must have been paying social security in the sending country before the posting
  • Your employer must remain your employer during the posting

A1 Certificate:

To prove you're still covered by your home country's social security, you need an A1 certificate (previously E101).

  • From UK to Spain: Apply to HMRC before you leave
  • From Spain to UK: Apply to TGSS (Tesorería General de la Seguridad Social)
  • Processing time: 2-6 weeks
  • The A1 allows you to continue paying social security in the UK/Spain and exempts you from contributions in the host country

After 24 months:

If your assignment extends beyond 24 months, you must switch to the host country's social security system unless you apply for an extension (granted in exceptional cases).

Self-Employed and Multi-State Workers

Self-employed working in both countries:

If you're self-employed and work in both the UK and Spain, the TCA allows you to pay social security in one country only.

  • Main rule: Pay in the country where you reside, if you carry out a substantial part of your activity there (25%+)
  • Exception: If you work mostly in the other country, you may pay there instead
  • Apply for an A1 certificate to prove which system you're in

Employed + self-employed in both countries:

If you have an employment contract in one country and self-employed work in the other:

  • Generally, you pay in both countries
  • Exception: If the employment is marginal (less than 25% of your total activity), you may only pay in the self-employment country
  • Complex cases require specialist advice from social security authorities

Pensions and Healthcare

UK State Pension in Spain:

  • Your UK state pension is paid in full to Spain (transferred to your Spanish or UK bank account)
  • The pension is uprated annually (increased in line with UK inflation) under both the WA and TCA
  • You must declare the pension in your Spanish tax return (IRPF) if you're a Spanish tax resident
  • The UK-Spain double taxation treaty allows you to claim a tax credit in Spain for any UK tax paid

Spanish State Pension:

  • To qualify for a Spanish state pension, you generally need 15 years of contributions
  • Under the WA and TCA, your UK contributions count towards the 15-year minimum (aggregation)
  • Each country pays a proportion of the pension based on how many years you contributed there
  • Example: 10 years in UK + 10 years in Spain = eligible for pensions from both countries

Healthcare for pensioners (S1 form):

UK state pensioners living in Spain can access Spanish healthcare using an S1 form.

  • Apply to NHS Overseas Healthcare Services (UK)
  • The S1 allows you to register with Spanish healthcare (the UK pays Spain for your care)
  • Your dependents (spouse, children) are also covered
  • This applies under both the WA and TCA

Key Documents: A1 and S1

A1 Certificate (Social Security Coverage)

Proves which country's social security system you're paying into.

When you need it:

  • Posted worker (temporary assignment to Spain/UK)
  • Self-employed working in multiple countries
  • Multi-state worker (employed in both countries)

How to apply:

  • UK: Apply to HMRC (www.gov.uk)
  • Spain: Apply to TGSS (Tesorería General de la Seguridad Social)

S1 Form (Healthcare Coverage)

Allows you to access healthcare in Spain while the UK pays for it.

Who can get it:

  • UK state pensioners living in Spain
  • Posted workers (temporary assignments) and their families
  • Some early retirees who previously worked in the UK

How to apply:

  • Apply to NHS Overseas Healthcare Services (www.gov.uk/healthcare-in-spain)
  • Once issued, register the S1 at your local Spanish health center (centro de salud)
  • You'll receive a Spanish health card (tarjeta sanitaria)

UK-Spain Social Security Quick Reference

  • Moved before 2021? Withdrawal Agreement protects your rights indefinitely
  • Moved after 2021? Trade and Cooperation Agreement applies (fewer rights)
  • Posted workers: A1 certificate allows you to keep paying UK social security for up to 24 months
  • UK state pension: Paid in full to Spain, uprated annually
  • Pensioners: S1 form gives access to Spanish healthcare
  • Pension aggregation: UK + Spain contributions count towards eligibility in both countries

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