One of the benefits of being an EU citizen is the right to live and work in any of the EU or EEA member states, and many UK citizens also benefitted from this prior to Brexit. However, if you’ve worked and paid taxes and social security contributions in more than one country throughout your life, this also likely means that you’ve contributed to more than one state pension scheme. So, what does this mean when you reach retirement age?
EU State Pensions: How Does it Work
There is no ‘EU pension scheme’ as such, but EU coordination rules regarding freedom of movement and state pensions mean that any pension contributions you make in an EU country (or EEA countries, i.e. Iceland, Liechtenstein, and Norway) will count towards your overall pension.
This means that if you work in several different EU countries throughout your life and contribute to state pension schemes in each one, you may accumulate pension rights in different countries. For example, say you worked in France for several years, then spent a few years working in Spain, then finally moved to Italy, where you worked until retirement; you may be entitled to a French, Spanish, and Italian pension.
EU coordination rules also cover contributions paid in countries prior to them joining the EU, and also for British citizens residing in the EU prior to Brexit (more on that later).
However, each country still sets its own rules regarding pension payments and retirement age, so it’s important to consider this when it comes to claiming your pension.
Supplementary pensions in the EU
Supplementary pension schemes in EU countries are also bound by these coordination laws. Essentially, this means that a supplementary scheme cannot treat a pension holder that moves to another EU country any differently to one who stays in the same country but stops paying contributions. See here for some examples of how this works in practice.
Retiring in the EU: How to Claim Your Pension
The first thing to know is that your pension records in every EU country where you have worked will be kept until your retirement age. If you have worked in a country for at least one tax year, then it will count towards your old-age pension when you reach pensionable age.
You will receive a separate old-age pension from every country in which you have worked.
How to apply for your EU State Pension
You apply for your pension in the country in which you live or in which you worked up until retirement age. So, for example, if you currently live and work in France, you will apply for your pension in France when you reach retirement age. However, if you worked all your life in Italy, then retired to France (without ever working or paying pension contributions/social charges in France), you would apply for your pension in Italy.
The country in which you apply is responsible for calculating your record of pension payments in the EU and will issue you with a summary of all your pension rights.
EU Retirement Ages
One important thing to note is that EU countries have different retirement ages, and you are not entitled to pension payments until you reach the retirement age of the country in question.
For example, the minimum retirement age in France is 62, so you would not be able to apply for your French pension until you reach this age. However, in Greece, the retirement age is 67, so if you had worked in Greece prior to moving to France, you would still not be able to claim your Greek pension until you reach 67.
If you have various pension rights that become available at different ages, it’s a good idea to seek advice on when you should claim your pension—claiming one pension before another may affect the payment calculations.
You’ll find more FAQs on state pensions in the EU here.
Am I entitled to a French pension?
In France, the minimum period of work to claim a French pension is 15 years. However, if you have worked in other EU countries (including France) for a total of 15 years or more, you may still be able to access a state pension.
How much pension you can claim will depend on a number of factors, but it will typically be calculated based on the EU-equivalent rate, taking into account the number of years worked in France and the total years worked within the EU.
As outlined above, you would generally apply for your pension in your EU country of residence, and your French pension contributions would then be calculated at the same time.
Pension Rights for British Citizens Resident in the EU After Brexit
For British Citizens resident in the EU, there are further questions regarding pension rights post-Brexit. The good news is that for UK nationals resident in the EU, EEA, or Switzerland before 31 December 2020, nothing has changed. Your rights are protected under the UK’s Withdrawal Agreement, and EU member states will take into account all contributions made to UK or EU state pension schemes.
For those who moved to the EU after this date, or those hoping to move or retire to France or another EU country in the future, there have been some changes regarding certain UK benefits. However, rest assured that if you are entitled to a UK state pension, it is still possible to claim this if you move abroad (read more about this in our guide to Pension Options When Retiring to France).
Read more about the rules regarding UK pensions for expatriates here.
Retiring to France?
From applying for residency and understanding your pension options, to life in France for the over 60s – FrenchEntrée is here to help! Let our Essential Reading articles guide you through the whole process, then visit our French Tax, Healthcare, Wills & French Inheritance, and Life in France zones for everything else you need to know.