Post-Brexit UK vs EU immigration

Post-Brexit UK vs EU Immigration: What’s Changed for Workers

More than four years since the United Kingdom formally left the European Union, the divergence between UK and EU immigration rules continues to reshape the decisions of workers, employers, and job seekers on both sides of the Channel. For anyone considering a move to work in the UK or relocate within Europe, understanding what has changed — and what continues to evolve — is now more critical than ever.

Freedom of Movement: A Right No Longer Shared

The most significant shift since Brexit is the end of free movement between the UK and the EU. Prior to January 2021, citizens of any EU member state could live and work in the UK without a visa, and British nationals enjoyed the same right across the 27 EU countries. That reciprocal arrangement no longer exists. Today, EU citizens wishing to work in the UK must navigate the country’s points-based immigration system, while British nationals seeking employment in EU member states must comply with the individual immigration rules of each country — rules that vary considerably from one nation to another.

The UK’s Points-Based System

The UK introduced its points-based immigration system in December 2020, applying the same framework to EU and non-EU nationals alike. To qualify for a Skilled Worker visa — the most common route for overseas workers — applicants must have a confirmed job offer from a licensed UK employer, meet a minimum salary threshold (currently set at £38,700 per year for most roles following a 2024 increase), and demonstrate a required level of English language proficiency. The salary threshold rise has drawn widespread criticism from employers in sectors including hospitality, social care, and retail, who argue it limits their ability to recruit internationally.

Working in the EU as a British National

For British workers looking to the continent, the picture is more fragmented. EU member states retain sovereignty over their own immigration policies, meaning a British national seeking work in Germany faces a different process than one applying in France, Spain, or the Netherlands. Most EU countries now require British workers to obtain a national work visa or permit before taking up employment. Many states demand evidence of a job offer, proof of qualifications, and in some cases, language competency. Short-term work or business travel may also trigger permit requirements that would not have applied pre-Brexit, creating additional complexity for contractors and consultants operating across borders.

Implications for Job Seekers and Employers

The practical consequences are substantial. EU nationals who have previously worked freely in the UK must now plan their move well in advance, securing employer sponsorship before arriving. British professionals eyeing opportunities in Europe must research country-specific requirements carefully, as assumptions carried over from the pre-Brexit era can lead to costly delays or legal complications. Employers on both sides are also absorbing increased administrative burdens, with sponsorship licences, compliance obligations, and longer hiring timelines now standard parts of international recruitment.

For skilled workers in high-demand sectors — technology, engineering, healthcare, and finance — opportunities remain strong across both the UK and EU markets. However, the pathway to securing those roles now requires strategic planning and expert guidance at every stage.

Expert Advice Is Essential

Navigating post-Brexit immigration rules without professional support is a risk few workers or businesses can afford to take. The regulatory landscape continues to shift, with policy updates in both the UK and individual EU member states emerging regularly. Whether you are an EU national planning a UK career move, a British professional seeking opportunities in Europe, or an employer managing cross-border talent, working with an experienced immigration and employment consultancy is the most effective way to stay compliant and competitive.

GVMC Global specialises in UK and EU immigration guidance and international employment solutions. Contact the GVMC Global team today to discuss your individual circumstances and receive tailored advice for your next career or business move.