The withdrawal of the United Kingdom (UK) from the EU leads to far-reaching changes and restrictions under employment law for future business trips or for long-term vocational deployment of UK citizens to Germany and German citizens to the UK.
As from 1 January 2021, UK citizens are no longer treated as EU citizens but as nationals of third countries, which means that they no longer benefit from the free movement of workers.
The affected workers therefore need an appropriate residence and work permit. Employers are obliged to check this in order to ensure that their employees are legally entitled to work in paid employment.
In this article we provide an overview of the main changes and explain what must be taken into account in future in connection with any periods when workers from the UK work in Germany and vice versa.
We also provide information about the special provisions which apply to citizens of Germany/the UK who already worked in the UK/Germany on the cut-off date of 31 December 2020.