How The Brexit Will Affect Luxembourg Dual Citizens

When I went to register in East London, the officer asked me a lot of skeptical questions about how I had Luxembourg citizenship even though I was born in America. Ten days later, I got a rejection letter

A Luxembourg Dual Citizen on Brexit

To read a Luxembourg Dual Citizen’s first hand account of moving to the UK during Brexit, click here.

Brexit Background

Luxembourg Dual Citizens probably know that as a Luxembourg citizen, they are also a citizen of the European Union. As a European Union citizen, Luxembourg dual citizens are free to live, work, study, retire, and conduct business across all the countries of the European Union.


The Brexit was delayed from October 31, 2019 to January.

On June 23rd, 2016, the United Kingdom voted in a referendum to leave the European Union. This is often called the Brexit.

After two dramatic extensions, the United Kingdom left the European Union at 11:00 p.m. local time, January 31st, 2020.

After Brexit Day, Luxembourg Dual Citizens and all European citizens’ rights each changed. At the same time, British people’s rights to live in Luxembourg and the European Union also changed. We want to provide both groups with the information they need.

What Will Change For Luxembourg Dual Citizens

One surprising thing about the Brexit is that the details are not all in place yet. Due to European Union rules, the UK had to leave the European Union before negotiations on its future relationship with Europe could start. So that negotiations can take place, there is an 11-month transition period. During the transition period, all European laws, rules and regulations still apply in the UK. This transition period is from February 1, 2020-December 31st, 2020.

Because the future relationship is not yet negotiated, we do not know yet how everything will work in the future. The below is a general guide applicable in 2020. As a Luxembourg citizen, if you ever wanted to live in the UK now is the time to take action.

Working in the UK After Brexit

Before the Brexit, European Union citizens could look for a job in the UK and use their Luxembourg passport as proof of their right to live and work in the UK. After that, the next step was to register for a National Insurance Number. A national insurance number works like a Social Security Number in the US. It is used for filing taxes and accessing the National Health Service, among other things. European Union citizens now have until June 31st, 2021 to use their EU passport as proof of eligibility to work in the UK. After June 31st, 2021, European Union citizens will need to show that they have “settled or pre-settled status” to live and work in the UK. This is also called “leave to remain.”

EU Settlement Scheme

Letter granting pre-settled status.

To obtain settled or pre-settled status in the UK, you need to apply to the EU Settlement Scheme.  You can apply to the EU Settlement Scheme from now until June 31st, 2021. Applicants new to the UK will get Pre-Settled status which is valid for 5 years, is renewable or changeable to settled status, and ensures the right to work and use the National Health System.

To apply, you need to download the EU Settlement Scheme app to an iPhone or Android phone. There have been complaints about bugs with the app. Our contacts have had better luck mailing their Luxembourg identity cards into the EU Settlement Scheme. If you are moving to the UK after the Brexit Day, you should immediately apply for your National Insurance Number. Once you have that, apply for the EU Settlement Scheme. It is possible but more difficult to apply to the EU Settlement Scheme without a National Insurance Number.

After June 31st, 2021

After June 31st, 2021, European Union citizens will no longer have the right to freely move to the UK, look for work, and apply to the EU Settlement Scheme. EU Citizens will need to apply for authorization to move to the UK. This authorization will be based on points. The UK government has not announced how this point system will work. In summary, if you already have an EU passport and want to move to the UK one day, you should take action in the next year.

Studying in the UK

Unfortunately, the UK has not announced its policies on how studying in the UK will change for EU students after the Brexit. What we do know is that as a part of Brexit, the British Parliament voted against maintaining the official European Union study abroad program Erasmus. Currently, European Union citizens studying in the UK can apply to the EU Settlement Scheme until June 31st, 2021. The British Government currently states the following (click link for more details):

  • EU Students’ rights will not change until December 31st, 2020
  • EU Students will be able to access student finance in England if their studies start in the 2020 to 2021 academic year
  • Erasmus placements will continue in the 2020 to 2021 academic year
  • EU Resident Students will continue to benefit from UK domestic (“in-state”) tuition rates in 2020-2021

Retiring in the UK

While more retirees are probably concerned about recent changes to taxation in Portugal, you may have considered retiring in the UK. If you are concerned about how your rights are affected, please contact LuxCitizenship.

More Information & Next Steps

If you are a Luxembourg Dual Citizen concerned about how your rights are affected by the Brexit, you can contact LuxCitizenship. We are working with several individuals in this case. You can also consult the Luxembourg Government’s Brexit Resource Center. For a first-hand account of a Luxembourg Dual Citizen moving to the UK during Brexit, see below.

Luxembourg Dual Citizen: Brexit Experience

This is an first-hand account of a Luxembourg Dual Citizen moving to the UK during Brexit. The individual does not want to disclose their identity.

“I moved to London in October 2019. When I went to register for my National Insurance Number, the interviewer asked me a lot of skeptical questions about how I had Luxembourg citizenship even though I was born in America. Ten days later, I got a rejection letter for my application. They will not explain why they reject you.

Because the Brexit was coming, I started to register for the EU Settlement Scheme instead. But the app gave an error after it scanned my Luxembourg passport. I still don’t know if this was random or because I didn’t have a National Insurance Number. No one could provide me answers at the telephone support center. I re-applied for a new National Insurance Number appointment. This time, I came better prepared for the questions of the interview. The new interviewer was very understanding about my Luxembourg Citizenship through ancestry. The appointment felt completely different, luck of the draw, I guess. One month later, I received an approval of my National Insurance Number. Then all of a sudden, the EU Settlement Scheme App also started to work. My leave to remain was approved after 4 days, the day of the Brexit.

Settling In

I am ‘settled’ now. It’s a huge relief because I really like London. Now, I know confidently that I can stay in the UK for 5 years, work here, and use the NHS (free national healthcare system). The Brexit makes me really sad, but I am so thankful to my Great Grandmother that she got me here.

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