What’s Different After Brexit For French Mortgage Holders
The Situation Going Forward
After all the Hype, Bluster, Posturing and Stretched Truth we at BestFrenchMortgage.com thought it would be useful to publish a post to simplify and clarify what has changed for UK citizens with, or hoping to obtain, a French property and/or a French mortgage. following the UK’s departure from the EU.
As a Third Country, under the EU definition, the UK and its citizens / subjects are is now in a very similar position vis a vis the EU to nationals from other third countries such as Australia, North Korea and Zimbabwe.
Beyond The Obvious Changes
Beyond the obvious changes, or rather losses as no additional rights have been gained, there are specifics that you will need to understand regarding French Visas and the French Carte de Séjour: This is covered in more depth at the foot of this post.
Additionally you might need to brush up on your French language because, and this surprised us, we noticed that as of this morning (31st December 2020) the EU had already removed the English language version of the document covering the changes entitled RELATIONS ENTRE L’UNION EUROPÉENNE ET LE ROYAUME-UNI: changements majeurs par rapport aux avantages de l’adhésion à l’UE though the document is still available in other European languages.
See also this post – Brexit Consequences for French Mortgages – Things to Consider
Working in France Post Brexit
This will be the topic of a further post as it is a substantial subject in its own right. However two things are already abundantly clear:
A UK citizen / subject will have no right to work in France without a Visa and Carte de Séjour which each explicitly mention that the holder has the right to work in France.
As UK professional qualifications will no longer be recognised in France, any UK citizen / subject wishing to work in France, even if they have a Visa and Carte de Séjour which grants them the right to work, will need to hold appropriate qualifications that are recognised in France.
In the case of many professional qualifications, such as law, medicine and accounting this is obvious.
What is less obvious is that, in France, many professions that are not regulated in the UK – for example, estate agency, running a B&B and commercial gardening – are regulated in France and thus, even with a right to live and work in France, will come the need to obtain the appropriate French qualification.
Financial Services – The Elephant in the Room
Financial services of all types were excluded from the Brexit agreement.
Of most immediate concern for anyone with a French property and / or a French mortgage will be the urgent need to review their banking arrangements in France, because there are already numerous instances where UK based banks, previously offering banking services in the EU, have forcibly closed Euro bank accounts having failed to obtain an EU banking licence.
It is imperative that you check your French banking arrangements to ensure that you can still execute financial transactions in France.
Key To What Has Changed
|Rights You Will Continue to Enjoy|
|Rights You Have Lost|
|Rights Limited or Curtailed|
Free Movement of People
|After Brexit||Before Brexit|
|Absence of Border Controls|
|Validity of Pet Passports|
|Short Stay Visa Exemption|
(Visits of up to 90 days in a rolling period of 180 days)
|Long Stay Visa Exemption|
(Visits over 90 days)
|Right to Work, Study or Live in an France|
|Abolition of Roaming Charges|
Free Movement of Goods
|After Brexit||Before Brexit|
|Free Exchange of Goods|
|Quota Free Access|
|Absence of Customs Formalities|
|Exemption from sanitary and phytosanitary controls|
|Exemption From Rules of Origin|
|Right to fish|
|Access to EU International Trade Agreements|
Trade in Services
|Financial Services Passporting|
|Recognition of Qualifications|
|Single Internal Market for Airlines|
|Third Country International Air Freight Operations|
|Single Internal Market for Hauliers|
|Third Country International Transport Operations|
|Single Internal Energy Market|
|EU Energy Trading Platform|
To stay in France and the EU area (Schengen Area) for a period of time beyond 90 days in any rolling period of 180 days you will need a French and later Schengen visa.
The safest source of information on visas for France is the French government website France-Visas.
French Carte de Séjour
The French Carte de Séjour is a document with a long history, which predates France’s membership of the EU. It is essentially the French residence permit for foreigners and comes in various forms, each with specific conditions and permissions.
Since France’s accession to the EU it has been a somewhat moot point as to whether an EU citizen from outside France needed to be in possession of a current Carte de Séjour or whether the document had been superseded by EU citizenship.
However, now the UK is outside the EU, possession of a current and appropriate Carte de Séjour is mandatory for any UK citizen who does not hold dual citizenship of an EU country.
We are currently in touch with the French Diplomatic Service and Service-Public de France to try and establish how the two documents, French Visa and Carte de Séjour relate to each other, but it seems likely that both will be needed – and that they will need to have matching durations.
The safest source of information regarding the French Carte de Séjour is the French government website.