Blogpost by Dr Robert Harrison.
London Calling is the European Liberal Forum’s column aimed at bridging the Channel.
I woke up on the morning of 24th June 2016 after only a few hours sleep, went downstairs, turned on the TV to BBC World and heard the news: the UK had decided to leave the European Union. A few hours later the local public broadcasting TV station, Bayerischer Rundfunk, phoned up and asked me how I felt and came over to my office for an interview. As they noted, I looked tired and stressed out. Not only had I only had a few hours sleep, but I’d spent the previous week phone canvassing and trying to help UK citizens in the EU get their postal votes back home on time to be counted.
The exact numbers of British citizens who now live in the member states of the European Union is unknown. The UK keeps no records but it is estimated that there are around 1.3 million – and probably a large number of further unregistered residents. Some counts suggest that there could be as more than 2 million British nationals living in the EU. Most are not the typical stereotype favoured by the British tabloid press of the wine-drinking pensioner on the Algarve or the Costa Brava. The majority – like myself – are working people with families to support who moved for study, job opportunities, or to join their life partners. They have taken advantage of the rules on freedom of movement to find employment and contribute economically and socially to their new countries.
The question I was asked several times over the following days was: what happens now?
The European Parliament and Commission were clear in their own minds – there were three issues that needed to be agreed with priority: the withdrawal bill, the border in Ireland and Citizen’s Rights. The ALDE group (now Renew Europe) were massive advocates of the need to make arrangements for citizens. And not just for EU citizens living in the UK, but also for Britons resident in the EU.
EU governments were also aware of the need to make not just arrangements for their own citizens in the UK, but also to support Britons on their territories. Chancellor Merkel, for example, acknowledge in speech to the German Bundestag the contribution that British citizens make to German society and in a question that I put to her during the 2017 election campaign promised that I would not be bundled back to Birmingham!
The Withdrawal Agreement signed in 2019 provided a measure of comfort to many. Our rights to live and work in our countries of residence were retained. Pensioners could keep their health insurance and our previous national insurance contributions would continue to be recognised in calculating our local pensions. Rights, such as the opportunity to move to other EU countries or provide cross-border services, were never addressed. Much of my work, for example, involves providing services from Munich to companies in Austria, Portugal, Spain and France. Many translators, musicians and artists have similar issues.
For some of us the option of taking dual nationality was available. Germany allows dual citizenship for EU citizens and it was soon clarified that anyone who requested dual German/UK citizenship before the UK finally left the EU would be allowed to retain both citizenships. Unsurprisingly British citizens who had previously not filed a request for naturalisation soon put in their applications – I was among them and received my German ID card in 2018. Ironically, many civil servants working for the commission in Brussels also requested and were granted Belgian nationality.
Other countries such as Spain, Austria or the Netherlands do not in most cases allow dual nationality and whereas some Britons chose to renounce their British nationality, many did not do so. This leaves them in a difficult position – they can continue to work and live where they do at present, but cannot easily move to a different country. Many are still in limbo. Registration documents have yet been processed – partly because of the corona pandemic and partly because arrangements have not been put in place. UK citizens in Germany, for example, have already been refused boarding to flights by Lufthansa because of their lack of documents.
Companies, such as Airbus, in which employees commonly work on cross-border projects need to make special arrangements to allow their personnel to work legally. Smaller SME’s just do not bother – and avoid employing British citizens.
The Partnership Agreement between the EU and the UK brought little help. Arrangements on working visas and residence rights are often left to the member states which will mean a piecemeal approach. UK citizens will only be allowed to stay for 90 days in any 180 days in the EU which for those with second homes could be a massive problem. Some in the British press have suggested that this is “unfair” and “punishment” by the EU, but it reflects current policies of the EU to any third country nationals. The rights of their citizens has never been a priority for the UK government.
As for me, I’ve probably got the best of both worlds. I can work and live in the UK and in the EU. My children have both a German and a UK passport, but their friends have lost many opportunities that I enjoyed to develop my career as a young physicist. Theresa May in a speech to the 2016 Conservative Party conference called us “citizens of nowhere”. Her “Little England” attitude did not acknowledge that most British citizens living in Europe still hold their country of birth or descent with a large amount of affection. Rather than ignoring the British diaspora, the UK should be seeing them as a means of soft diplomacy to increase and improve international contacts.
I gave the speech at the local citizenship ceremony and concluded that getting dual citizenship was not just an honour but conferred an obligation on us to work to improve relations between both countries. It’s difficult with the current British government to uphold that commitment, but I’m still trying.
Dr Robert Harrison is the former Chair of the Liberal Democrats in Europe and was an European Parliament Candidate in 2019 for the German FDP. He is a former President of LYMEC. Rob lives with his family including two children in the Munich region and works as a shareholder and managing director for an intellectual property consultancy and attorney firm. Rob studied Physics at Oxford and holds a Ph.D. from Sheffield University before moving to Germany in 1990.