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National Insurance for Workers Coming from the EU to the UK
When you move to the UK from an EU country or certain other European nations for work, you'll need to understand which country's social security system you should pay into. The UK has agreements in place to make sure you only contribute to one country's scheme at a time, avoiding double payments.
When you move to the UK from an EU country or certain other European nations for work, you'll need to understand which country's social security system you should pay into. The UK has agreements in place to make sure you only contribute to one country's scheme at a time, avoiding double payments.
How the agreements work
The UK has social security coordination agreements with the EU, Gibraltar, Iceland, Liechtenstein, Norway, and Switzerland. These agreements ensure you only pay social security contributions — known as National Insurance in the UK — in one country at any given time.
As a general rule, you pay contributions in the country where you're actually working. This means if you come to work in the UK, you would normally pay UK National Insurance. However, there are important exceptions to this rule.
When you might continue paying in your home country instead of the UK
You can continue paying social security contributions in your home country (rather than UK National Insurance) if you obtain a certificate of coverage, also called a PDA1. This certificate proves you don't need to pay National Insurance in the UK.
You or your employer should apply for this certificate from the relevant social security institution in your home country if any of these situations apply to you:
Temporary work assignments: You're employed by a company in your home country that normally operates there, and they're sending you to work temporarily in the UK for up to 2 years.
Self-employed temporary work: You're self-employed in your home country and coming to carry out similar self-employed work in the UK temporarily for up to 2 years.
Working in multiple countries: You're working in your home country and the UK at the same time.
Government employees: You're a civil servant working for your home country's government.
Maritime workers: You work on board a vessel at sea with your home country's flag, you're resident in the UK, and you're paid by someone based outside the UK. Or you work on a UK-flagged vessel, live in your home country, and are paid by someone in your country of residence.
Flight and cabin crew: Your home base is in your home country rather than the UK.
Norwegian continental shelf workers: You live in Norway and work on the UK continental shelf exploring or exploiting natural resources, either as an employee of a Norwegian employer or as a self-employed person.
Special rules for EU workers covered by the Withdrawal Agreement
If you're covered by the social security provisions of the EU Withdrawal Agreement, you may have additional options. You're covered by these provisions if you're:
- A national of an EU country who was resident in or working in the UK before 1 January 2021 and continue to be resident here
- A UK national who was resident in or working in an EU country before 1 January 2021
- A family member of a UK national with residence rights in an EU country, and you're living in that EU country
- A family member of an EU national with status under the EU Settlement Scheme, and you're living in the UK
- Both a UK and EU national who was resident or working in the UK before 1 January 2021
- An EU national who worked in both the UK and one or more EU countries before 1 January 2021, continue to do so, and mainly work in the EU
If you're covered by the Withdrawal Agreement but don't meet the standard conditions listed above, you can still apply to remain liable for social security contributions in an EU country while working in the UK. However, both the EU social security authority and HMRC must agree to this, and they will only do so in exceptional circumstances.
Applying for a certificate of coverage
To get a certificate of coverage, you need to apply to the social security institution in the country where you live. This is something you or your employer can do.
If you already live in the UK and need to apply, you can use HMRC's interactive guidance tool to find out which application form you need.
Remember that a certificate of coverage is not the same as a work permit. You'll still need to check UK immigration rules separately to ensure you have the right to work in the UK.
What this means for employers
If you're a UK employer taking on workers from these countries, your obligation to pay social security contributions follows the employee's liability. This means if your employee has a certificate of coverage showing they should pay contributions in their home country, you won't need to pay UK employer National Insurance contributions for them either.
Sources
This article provides general guidance based on current HMRC rules. For advice specific to your situation, speak to your accountant.