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Since 1 January 2021, UK nationals who want to work in the EU will be considered third-country nationals and a work permit may be required.

This may seem like a simple question, but it’s far from straightforward. The end of the transition period on 31 December 2020 signalled the end of free movement between the UK and Europe. The implications of this are wide-reaching, not least from the perspective of those who may wish to visit Europe for business purposes and/or short term work.

A new Trade and Cooperation Agreement was agreed between the UK and EU on 24 December 2020, to govern the future trading and security relationship following the UK’s departure from the EU. This contains some welcome provisions around business mobility, e.g. concerning defined categories such as business travellers, contract service suppliers and independent professionals. Still, these do not provide a meaningful substitute to free movement.

Under the visa-waiver regime, UK nationals holding a valid passport (with at least 6-months' validity) can travel for up to 90 days in a 180-day period in the Schengen area. However, since 1 January 2021, UK nationals who want to work in the EU will be considered third-country nationals and a work permit may be required to do so.

Permitted business activities are not uniform across all of the EU Member States. Where work permission is required, obtaining a work visa or residency permit can take some time, so careful forward planning is now also key. The rules are set by each member state and business travellers from the UK must meet the domestic laws of their destination EU country, so these need to be checked well in advance.

From 2022, the European Travel Information and Authorization System (“ETIAS) - a visa waiver pre-screening program for visa-exempt visitors who wish to enter EU territory - will come into force.  British citizens will be required to apply for an ETIAS to enter participating European countries for short term visits of under 90 days for general tourism, business, transit or medical purposes. To enter Europe for over 90 days, or for other purposes than those allowed under the ETIAS program, a Schengen visa will be required.

For now, as a starting point, here is an overview of the different requirements for short-stay work permits of each member state. Please note that the information below is a brief summary of a very complex issue and for reference only.

It is vital to seek immigration advice to determine exactly what can and cannot be done as a business visitor from the UK to Europe and to establish whether or not a work permit is required. We recommend that relevant local immigration laws are consulted well in advance, to avoid delays and disappointments.

Austria

British workers travelling to Austria are subject to the following rules:

  • British Passport holders do not need a visa for business travel (without gainful work in Austria) for up to 90 within a rolling 180-days-period.
  • Short-term business trips (e.g. for business meetings, contract negotiations) are covered by the 90-day visa-free period.
  • Longer-term posting of workers is also visa-free for up to 90 days.
  • Postings from 90 days up to 6 months require a visa; longer postings require a residence permit.

Austrian Embassy

Schengen Visa Info, Austria

Belgium

 A number of conditions must be met to work in Belgium. These conditions depend on the following:

  • your nationality and country of residence;
  • the length of your stay in Belgium;
  • your professional status (employee or self-employed) in Belgium.

The rules differ in the regional areas of Belgium. Only the regions are competent to decide and issue a work permit, single permit, professional card or exemption. A work permit may be needed, even to spend less than 90 days within 180 days.

The consulate website provides information on regional work permit requirements.

Czech Republic

For short-term stays (not exceeding 90 days during any 180-days period), UK citizens will only have to apply for a visa if they travel to the territory of the Czech Republic to perform “profit-making activities”. Permission to work will be generally always needed, however there are some work permit exemptions for artists and for other specific persons or groups.

Embassy of the Czech Republic

Czech Republic Ministry

Denmark

UK nationals must generally have a residence and work permit to work in Denmark. There are some exemptions that may apply, such as business travel for meetings or training that can be carried out without a work permit within the 90 days in any rolling 180-day period time limit. To work, or to stay in Denmark longer than 90 days, you should apply for a residence permit.

There are some work permit exemptions specific persons or groups. 

Ministry of Foreign Affairs of Denmark

The Danish Immigration Service

Estonia

Business visitors can enter and stay for a maximum of 90 days in any rolling 180-day period. However, even though permitted to enter and stay visa-free, you would only be allowed to work in Estonia for a maximum of 5 days in any 30-day period under such visa-free arrangement.

Otherwise, prior to arrival, registration of short-term employment is required. Once registered, no permit is needed for up to 90 days. Further information on registration of short-term employment can be found here.

Embassy of Estonia 

Finland

No permit is required for up to 90 days if ‘you have been invited to work in Finland or you have signed a contract to work in Finland’.

Right to work without a resident permit

France

A visa is not required for business travel of up to 90 days in a 12-month period in France.

For longer stays, a permit will be required:

  • temporary worker residence permit (fixed-term employment contract)
  • seasonal worker residence permit (seasonal employment contract)
  • employee residence permit (permanent employment contract).

Consulate General of France

Germany

A visa is not required to engage in permitted business activities for up to 90 days in a 12-month period in Germany. However, during this period, visitors are not permitted to carry out paid work. If you wish to enter Germany for a longer stay, and/or for purposes like medical treatment, study, work, employment, you will have to obtain a visa.

Germany Visa

Greece

For any business activities falling out with those permitted (i.e. business visitors for establishment purposes and short-term business visitors in accordance with the Trade and Corporation Agreement) or exceeding the 90 days in any 180 days rolling period, a residence permit or national visa will be required. The application for the residence/work permit is made within 30 days of arrival in Greece.

Greek Embassy

Hungary

Those wishing to stay and/or work in Hungary for more than 90 days (in 180 days) will require a residence and work permit. This is obtained via a single application procedure encompassing both permissions to work and to reside in Hungary for more than 90 days. The type of permit will depend on the purpose of the stay in Hungary.

Hungarian Government

Iceland

If you are planning to visit Iceland to work, you may need a work permit. Read the Directorate of Immigration’s guidance on how to get a work permit and the Directorate of Labour’s guidance on exemptions for short-term projects.

Certain groups are exempt from requiring a permit to work in Iceland for short term appointments up to 90 days. Where an exemption applies, it is necessary to notify the directorate about the intended employment in Iceland before it commences to be able to determine if the requirements are fulfilled.

Directorate of Immigration – residence permits based on work

Directorate of Labour - short term work permit exemptions

Ireland

The Common Travel Area (“CTA”) is an established arrangement between the UK, the Crown Dependencies and Ireland. Under the CTA, UK and Irish citizens can live, work, study and move freely in each other’s countries. A visa or residency permit is not required.

Further information on the CTA can be found here.

Italy

For visits to Italy of less than 90 days (within a total period of 180 days), an entry visa will not be required. This exemption from the requirement for a short-stay visa also applies in cases where British citizens enter Italy to perform paid work, subject to reciprocal arrangements for Italian citizens in the UK.

British citizens undertaking paid work, or planning to stay in Italy for more than 90 days within 180 days, will be subject to National visas requirements according to the Italian immigration rules applied to third country nationals.

Italian Ambasciata   

Latvia

You may visit Latvia for business purposes for 90 days in any rolling 180-day period. However, business activities must be limited to:

  • attending internal meetings, discussions or conferences;
  • attending client meetings;
  • undertaking sales or marketing activities, such as making sales calls to potential clients, or negotiating a business deal or contract;
  • exploring business opportunities.

For a period of less than 14 days within 180-day period, any activity can be undertaken - including work activities.

To live and work in Latvia for more than 14 days, you will require additional permission to work, i.e. a residence permit with work permit.

Office of Citizenship and Migration Affairs Republic of Latvia

Lithuania

You may visit Lithuania for 90 days in any rolling 180-day period. If you wish to undertake work, a visa for work purposes must be obtained before entry.

Obtaining a visa for work purposes

Liechtenstein

For visits to Liechtenstein exceeding 90 days in a 180-day period and for visits for the purpose of gainful employment, a short-term residence permit is required for up to 12 months.

Liechtenstein Government Service Portal

Luxembourg

You may visit Luxemburg for the permitted 90 days (in 180 days) but if you wish to carry out paid activity during this period, you must have a work permit.

There are some exceptions. Those in the following groups will not require a work permit, provided they work in the country for less than 3 months per calendar year:

  • staff from fairground attractions, circuses and other travelling establishments;
  • workers in the entertainment industry without regular employment;
  • athletes;
  • invited researchers, conference speakers and university lecturers;
  • persons on business trips, such as travel to visit business partners, to explore and develop professional contacts, to negotiate and conclude contracts, to participate in fairs, shows and exhibitions as well as to take part in meetings of the board of directors and general meetings of the company;
  • all persons carrying out a service within the same group of companies (excluding any work carried out in the framework of subcontracting).

Luxembourg Government

Work permit exemption

Malta

You may visit Malta under the Schengen exemption, i.e. 90 days in any rolling 180-days period. However, if you want to work in Malta, you must obtain a permit under the single permit or key employee initiative procedures.

Identity Malta

Netherlands

If you wish to work in paid employment in the Netherlands, you will need a residence permit. Conditions are dependent on the type of work you will perform.

Netherlands - Government Guidance

Work in paid employment

Norway

If you are a posted worker from a British company, you will require a residence permit as a skilled worker to be allowed to work in Norway.

In some cases, you do not need a residence permit to work in Norway for up to 14 days. This applies to Artists, musicians or performers or those who are employed by an organisation that carries out international humanitarian work.

The Norwegian Directorate of Immigration (UDI)  

People who can work in Norway for 14 days without a permit

Poland

You can make permitted visits for up to 90 days in any 180-day period without a visa. To stay longer, to work or study, for business travel or for other reasons, you will need to meet the Polish government’s entry requirements.

There are exemptions from work permit requirements for artists and for other specific persons or groups of persons, for a maximum of 30 days if the performance takes place in one year.

Polish Embassy

Work permit exemptions for artists for up to 30 days

Portugal

For visits to Portugal of less than 90 days (within a total period of 180 days), an entry visa will not be required. A temporary stay visa is required for work and the duration will depend on the purpose.

Temporary stay visa for independent work purposes

Applying for a residence permit as a worker in Portugal

Slovakia

Despite the 90 days in 180 days exemption, a work permit and temporary residence will usually be required for the purpose of carrying out paid activity.

For short-term business activity, such as meetings, visits, business meeting, a work permit is not required.

If you want to stay in Slovakia for more than 90 days and/or want to carry out paid activity, you must obtain a single permit or a work permit and a residence permit for employment purposes.

Ministry of the Interior of the SR

Slovenia

If you will be carrying out paid work in Slovenia, an appropriate permission (single permit) will be required, unless you can rely on the exemptions under the Employment, Self-Employment and Work of Foreigners Act, e.g.:

  • You are attending business meetings or establishing business contacts for not more than 90 days within a period of six months, counted from the date of first entry into the country.
  • You have temporary residence permission due to family reunification with a Slovenian national;
  • You have permission for permanent residence;

If you are not generating income or directly performing sales or services in Slovenia for up to 90 days, then no permission is expected to be required.

Republic of Slovenia - entry-and-residence

Spain

For British citizens and their family members, a visa is required for journeys to Spain for the purposes of work, professional, artistic or religious activities.

Consulate of Spain - entry for UK nationals

Sweden

You can carry out limited activities in Sweden within the permitted visit period of 90 days in a 180 days rolling period. In order to work in Sweden, or you want to stay in Sweden for more than 90 days, a work permit or a residence permit will be required. To enter, you will require proof of the duration and purpose of your stay, as border control may ask additional questions concerning this.

There are special rules for certain occupations: performer, au pair, berry picker, seasonal work, researcher, athlete or coach, trainee (traineeship through international exchange and traineeship with ties to higher education), volunteer and those applying for an EU Blue Card or an ICT permit.

Working and studying in Sweden

Special rules for certain occupations and citizens of certain countries

Switzerland

British Passport holders do not need a visa to enter Switzerland for a short stay of up to 90 days within a 180-day period where certain limited business activities will be performed, for example, to participate in a conference or cultural event, etc.

Otherwise, you would have to meet the terms of the Foreign Nationals and Integration Act. For longer visits, or to work in Switzerland, you need a work permit and these are subject to a quota for UK nationals. To stay in Switzerland for more than 90 days, a residence permit is also required. The required authorisations are obtained from the competent cantonal authorities in Switzerland.

The Services Mobility Agreement (SMA) between Switzerland and the UK now regulates the mutual access and temporary stay of service suppliers. The agreement provides that workers sent by UK companies for a short-term project, for up to 90 days per year, will not require a permit.

Visa – Entry to and residence in Switzerland  

Switzerland and the UK agreement on mobility of service suppliers


For further advice please complete the form below or contact us directly.

 

It is vital to seek immigration advice to determine exactly what can and cannot be done as a business visitor from the UK to Europe and to establish whether or not a work permit is required. For guidance, contact our immigration solicitors.

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