TL;DR

  • Ten years after the referendum, the practical UK-resident remote-work landscape has shifted in three big directions: cross-border services are harder, cross-border goods sales are harder still, and domestic UK employment law has moved in a more worker-protective direction.
  • Visa-wise, the door to Europe is not shut, but it now opens through national digital nomad and freelance routes (Spain, Portugal, Italy, Germany, Estonia, Croatia and others), each with its own income threshold and friction. UK passports retain visa-free Schengen entry, capped at 90 days in any 180.
  • Microbusinesses selling physical goods into the EU now operate under a fully changed VAT regime. The pre-2021 low-value exemption is gone, IOSS is the practical compliance route, and since 1 April 2026 HMRC has offered registration to act as an IOSS intermediary, an alternative to appointing an EU one.
  • On the home front, IR35 has hardened (2017, then 2021), the company-size thresholds have risen (with HMRC saying the earliest effect on IR35 is the 2027/28 tax year), and the Employment Rights Act 2025 brings day-one sick pay and a new Fair Work Agency. There is still no Code of Practice or timetable for a right to disconnect.
  • The planned UK-EU SPS Agreement (Common Understanding May 2025) signals a slow re-warming, with the government intending it to take effect in mid-2027.

When I first moved to Spain from the UK, years before serious talk about a referendum on leaving the EU, there was still a great deal to think about and plan. But visas and migration were simply not present on the very long list - while the UK had never been part of the Schengen zone, as British passport holders we had freedom of movement to settle anywhere in the EU, and only had to comply with local census registrations to be able to enter the workforce and social security system.

Of course we still kept close cultural and business ties with the UK, my only client at the time was based there, and I travelled back regularly to work as well as to see family and friends. We kept in touch with UK news and politics and always maintained our franchise via proxy. David Cameron’s promise made public in January 2013, to hold an in/out referendum on the UK’s membership of the European Union if the Conservatives were returned at the next general election was just another bit of background political news, that didn’t seem to affect anything in our day-to-day lives – until all of a sudden, it affected everything.

Ten years, four phases

It is worth setting the timeline straight before anything else, because most of what feels confusing today comes from the fact that the practical changes did not arrive in one moment. They arrived in four.

23 June 2016. The referendum. 51.89% leave, 48.11% remain. Consultative, not legally binding, but politically decisive.

29 March 2017. The UK triggered Article 50 of the Treaty on European Union, formally notifying the European Council of its intention to withdraw.

31 January 2020, 23:00 GMT. Exit Day. The UK ceased to be a member state, became a third country in EU legal terms, and entered the transition period during which EU law still applied.

31 December 2020, 23:00 GMT. Transition end. From 1 January 2021, UK citizens became third-country nationals for EU and Schengen purposes. The Trade and Cooperation Agreement (TCA) came into provisional effect the next day.

Remote Work Europe has tracked policy developments through every one of those phases. Most of the practical disruption that affects a UK-based remote worker or micro-business today flows from that fourth date, not the first. The vote was in 2016, but the new operating system came online in 2021.

Across expat social media groups, we still see post after post from people saying “I want to move to Spain/Italy/Greece,” etc., which sometimes seem to have no understanding of how much has changed. People who think they’re going to come over and start local businesses or find unskilled jobs, the way so many did in the past. But if you are reading this from inside the UK, the question is not really “what happened?” The question is “what environment am I now working in?” Three shapes matter: employment, goods, and mobility.

If you are a UK-based remote employee or contractor

Most of the change that affects you happened on the UK side, not the EU side.

IR35 / off-payroll working. The original IR35 rules date from 2000. Two reforms post-referendum reshaped the contractor market more than Brexit itself ever did. The 2017 public-sector reform moved the responsibility for determining employment status from the contractor to the public-sector client. On 6 April 2021, the same shift extended to the private sector for medium and large businesses (defined under Companies Act 2006 thresholds). Small businesses were exempted, and that exemption is about to cover more clients.

For financial years beginning on or after 6 April 2025, the Companies Act size thresholds rose: turnover from GBP 10.2 million to GBP 15 million, balance sheet from GBP 5.1 million to GBP 7.5 million, employee count held at 50. The government estimated that around 14,000 companies and LLPs would move from medium to small. Because the off-payroll test looks back at earlier financial years and requires two consecutive years, HMRC says the earliest tax year this can take a client out of the rules is 2027/28 – from then, contractors working with those firms would self-assess their own status. We covered the mechanics in detail in our IR35 threshold changes piece, including the umbrella company joint-liability rules that came in on 6 April 2026.

The headline is that the regulatory pressure on contractor status has not loosened. It has simply moved up the food chain.

Employment Rights Act 2025. Royal Assent on 18 December 2025, with phased commencement through 2026 and 2027. From 6 April 2026, employees get day-one Statutory Sick Pay (no three-day waiting period, and no lower earnings limit) and day-one paternity and unpaid parental leave. The Fair Work Agency launched on 7 April 2026 as a new enforcement body covering minimum wage, agency standards, and labour abuse. From 1 October 2026, the usual time limit for employment tribunal claims doubled from three months to six. We unpacked the lot in our UK April 2026 employment rights piece.

For the genuine self-employed, these changes do not apply directly. They matter sideways: they shift the calculation of contractor versus employee for anyone weighing the move in either direction, and they set the cultural temperature of what UK employers are expected to provide.

The right to disconnect. Not a statutory right, and not in the Employment Rights Act 2025. Commentators have suggested a Code of Practice instead, but the government has published no Code, consultation or timetable for one. Our UK right to disconnect piece covers where it stands.

Flexible working. Since 6 April 2024 the right to request flexible working has been a day-one right, and employers have had to respond within two months (down from three). From autumn 2027, a refusal will also have to be reasonable. Practical detail in our UK flexible working rights piece.

Cross-border employment. If you are a UK-resident employee working remotely for an EU employer, the rules around payroll, social security, and the EU’s cross-border telework framework matter to you. The post-Brexit remote work UK-EU piece lays this out, and Diana’s earlier guide on UK workers getting EU remote jobs covers the practical workarounds. The short version: it is doable, but the employer side carries non-trivial compliance overhead, and many EU employers default to Employer of Record arrangements to avoid registering for UK PAYE.

If you sell physical things internationally

This is where the post-Brexit reality is most operationally heavy, and most poorly understood.

The pre-2021 low-value VAT exemption is gone. Before 1 July 2021, goods valued under EUR 22 entering the EU were generally exempt from import VAT. That exemption was abolished EU-wide as part of the VAT e-commerce package. Every physical item shipped from the UK to an EU consumer, regardless of value, now incurs VAT at the point of import. A GBP 5 keyring shipped to a customer in Lyon is, in EU VAT terms, an import that needs handling.

You have three practical options:

  1. Register for the Import One-Stop Shop (IOSS) and collect EU VAT at checkout, then file a single monthly IOSS return. This avoids the parcel being held at the border and avoids the customer being hit with surprise fees. The IOSS rule applies to consignments valued at EUR 150 or less.
  2. Sell through a marketplace (Amazon EU, eBay EU, Etsy in many cases) that acts as deemed supplier under Article 14a of the EU VAT Directive and collects the VAT for you.
  3. Let the parcel hit the EU border without IOSS or marketplace handling, in which case the customer pays VAT plus a carrier handling fee on delivery. This works, but generates high cart-abandonment and customer-service costs.

For most one-person operations, option two or option one is the only realistic route.

IOSS just got more accessible for UK businesses. Until recently, a UK seller wanting to register for IOSS directly had to appoint an EU-based intermediary. Since 1 April 2026, HMRC has published guidance on registering with HMRC to act as an IOSS intermediary, so check whether a UK-registered intermediary can now act for you. The underlying scheme architecture has not changed. ICAEW’s March 2026 guidance is the clearest plain-English summary, and HMRC’s own guidance lives in the VAT IOSS intermediary collection on GOV.UK.

A bigger change is coming, but not yet. The EU has adopted Directive (EU) 2025/1539, part of a package of measures designed to push non-EU sellers and facilitating platforms towards IOSS, including by withdrawing the Special Arrangement (which lets the carrier collect VAT from the customer on delivery). Check the directive’s application dates before planning around it. Separately, the EU’s wider customs reform, including the future of the EUR 150 customs duty threshold, is still moving, so check the current position before pricing EU-bound parcels.

The mechanics on the UK side. Every EU-bound shipment now requires a customs declaration, lodged through the Customs Declaration Service (CDS), which fully replaced CHIEF for imports on 30 September 2022 and for exports on 31 March 2023. The EU’s Import Control System 2 (ICS2) requires advance electronic safety and security data on all parcels, with full coverage across all transport modes phased in from June 2024 and completed on 1 September 2025. For a single-person Shopify or Etsy operation, this is typically handled by the carrier (Royal Mail, DHL, FedEx, Evri), but the seller is responsible for getting the data right. Inaccurate data is the single most common reason for parcels being rejected at the border.

Rules of origin under the TCA. UK-EU trade is zero-tariff under the Trade and Cooperation Agreement only for goods that meet rules-of-origin requirements. For UK sellers drop-shipping from China direct to an EU consumer, those goods do not qualify for TCA preferences, and the EU consumer (or you, if you have priced in DDP terms) pays the EU’s Most Favoured Nation tariff. Specific rates vary widely by HS code and are best looked up at the point of sale in the EU’s TARIC database rather than asserted here.

Drop-shipping and “deemed supplier” rules. If you sell on Shopify and arrange for a non-EU supplier to ship directly to an EU consumer, in most cases EU VAT law treats you as the deemed supplier (Article 14a of the VAT Directive), making you liable for VAT collection. You do not delegate this to your supplier, and you do not delegate it to the platform unless the platform itself takes contractual control of the transaction (Amazon’s seller-fulfilled-by-Amazon-VAT setup does, a vanilla Shopify store does not).

Northern Ireland and the Windsor Framework. The Windsor Framework, which formally replaced the Northern Ireland Protocol from 1 October 2023, created a green-lane / red-lane structure for goods moving from Great Britain to Northern Ireland. Goods destined solely for NI move under the green lane with simplified declarations; goods at risk of moving onward into the EU Single Market via the Republic of Ireland move under the red lane with full EU customs and regulatory checks. The UK Internal Market Scheme (UKIMS) governs which businesses can use the green lane.

For a GB-based remote business that does not sell into NI, the Windsor Framework is mostly background noise. For one that does, the parcels arrangements for B2C goods movements (originally scheduled for 30 September 2024, then delayed) came into force on 31 March 2025. They introduced new declaration requirements that carriers handle on your behalf, but that you should understand exist.

The May 2025 SPS Common Understanding. This is the most encouraging recent development for anyone trading agri-food across the UK-EU border. On 19 May 2025, the UK and EU agreed a Common Understanding to negotiate a Sanitary and Phytosanitary (SPS) agreement, with implementation intended for mid-2027. Once it takes effect, Defra says export health certificates and phytosanitary certificates will no longer be needed for in-scope goods, and routine SPS border checks will be removed for goods such as dairy, fish, eggs, meat, plants and plant products. Exact timings depend on negotiations that are still ongoing. Defra’s SPS agreement guidance page is the primary source if you trade in this space. The price of admission is dynamic alignment with EU rules in scope, with the detail still under negotiation. Defra says it will publish further guidance as negotiations progress.

That is a real change of direction. It is also slow-moving and politically contingent.

If you want to keep being an employee in Europe

A particular version of this question turns up a lot: “I work in a really employable niche in tech, I’ll just fly over to Berlin or Amsterdam and pick up a job, right?” Respectfully, no. It does not work like that, and it has not worked like that for a UK passport holder since 1 January 2021. You are now a third-country national in EU and Schengen terms, which means a national immigration route, an employer who is prepared to sponsor you, and in most cases a salary threshold set by statute. The highly-skilled routes exist and they are well-trodden, sometimes very well paid. The harder part is the employer side of the deal.

Employer of Record. An EOR is a third-party company that legally employs you in a country where the company you actually work for does not have a local entity. You do the work for the EU employer; you sign with the EOR locally; the EOR runs payroll, handles tax withholding, registers you with social security, and provides statutory benefits. The EU employer outsources the compliance burden of becoming a registered employer in your country of residence, in exchange for a flat platform fee on top of the loaded employment cost. Deel publishes its standard EOR fee at USD 599 per employee per month plus salary, employer taxes and benefits, and the other major providers sit in roughly the same range. The friction is real on both sides. The EU employer has to want this and absorb the cost, and EOR arrangements have well-known limits on equity participation, because the legal employer is the EOR rather than the company whose shares you would be receiving. UK EMI options, in particular, cannot be granted to an EOR employee. If significant equity is part of your package, an EOR is not a clean fit.

The EU Blue Card and national highly-skilled routes. These are the work-permit categories most relevant to a UK-resident professional being directly hired by an EU company. Every country has its own version with its own salary floor, indexed annually. For 2026:

  • Germany. EU Blue Card threshold of EUR 50,700 gross per year for general occupations and EUR 45,934.20 for shortage occupations (IT, engineering, healthcare, STEM and others), with the lower figure also applying to recent graduates. The separate Chancenkarte, or Opportunity Card, is a points-based job-search visa, not a work permit.
  • France. Passeport Talent salarié qualifié set at EUR 39,582 gross per year for 2026, by ministerial order rather than indexed to SMIC. The French EU Blue Card route sits higher at EUR 59,373.
  • Spain. Under Ley 14/2013 (the Entrepreneurs’ Law), the Unidad de Grandes Empresas y Colectivos Estratégicos processes both the national Highly Qualified Professional permit and the EU Blue Card. The EU Blue Card threshold is set by Orden PJC/44/2026 at 1.4 times average gross annual earnings, which works out at around EUR 39,269.92 gross per year, with a reduced threshold of 80% of that (around EUR 31,415.94) in defined cases. Resolution is within 20 business days, with positive administrative silence in the applicant’s favour after that.
  • Netherlands. The Kennismigrantenregeling, or Highly Skilled Migrant route, runs through recognised sponsors. The 2026 monthly gross thresholds, excluding holiday allowance, are EUR 5,942 for applicants aged 30 and over and EUR 4,357 for under-30s.
  • Ireland. The Critical Skills Employment Permit threshold is EUR 40,904 gross per year for roles on the Critical Skills Occupations List, and EUR 68,911 for other CSEP-eligible occupations.

The “recruit locally first” rules. Several EU countries still operate a labour market test that requires the employer to advertise locally and show no suitable EU candidate exists before hiring a third-country national. For the highly-skilled routes above, that test is largely waived, but the detail varies. Germany’s Vorrangprüfung was abolished for EU Blue Card and Skilled Worker applicants under the Skilled Immigration Act. France’s opposabilité de la situation de l’emploi is waived for Passeport Talent applicants meeting the salary threshold, and waived more broadly for roles on the métiers en tension list (most recently revised by the arrêté of 21 May 2025). Spain’s Ley 14/2013 explicitly disapplies the situación nacional de empleo for highly qualified professional permits; for standard work permits, the Catálogo de Ocupaciones de Difícil Cobertura, published quarterly by SEPE, is the exemption list. The Netherlands waives the arbeidsmarkttoets entirely for the Highly Skilled Migrant route, provided the employer holds recognised sponsor status with the IND.

If you are above the salary threshold, in a clearly qualified role, and the employer is willing to use one of these routes, the labour market test is rarely the obstacle. The obstacle is finding the employer.

If you want to leave: the visa options now open to you

You can no longer turn up in Spain, Portugal or Germany and start working under freedom of movement. You have to do what every other third-country national has always had to do, which is apply through a national immigration route. The good news, ten years on, is that there are now more such routes specifically designed for remote workers than there have ever been.

Our complete digital nomad visas in Europe guide is the running compendium, updated quarterly. The headlines for UK passport holders considering a move from the UK in 2026:

  • Spain Digital Nomad Visa. Income threshold EUR 2,849/month for a single applicant (2026), at least 80% of income from non-Spanish sources, up to three years’ residency, Beckham Law access at the flat 24% employee tax rate. Full mechanics in our Spain digital nomad visa 2026 piece.
  • Portugal D8. Lower income threshold than Spain’s DNV but rising consulate scrutiny, with rejections clustering around predictable mistakes. Our Portugal D8 visa mistakes piece covers the most common ones.
  • Germany Freelance Visa (Freiberufler). Germany is unusual in that UK citizens can still apply from inside the country after entering visa-free, which most non-EU nationals cannot. Client letters of intent, a revenue forecast, a business plan, and a pension provision requirement for the over-45s. Detail in our Germany freelance visa for UK citizens post-Brexit piece.
  • Italy Digital Nomad Visa. Income threshold of EUR 28,000/year (about EUR 2,333/month) from foreign sources. One-year permit, renewable up to five years. The Italy DNV complete guide covers the rural-incentive overlay that makes Italy interesting for slower-moving applicants.
  • Croatia Digital Nomad Visa. Extended to 18 months in 2025, zero Croatian income tax during the visa period. Practical guide in our Croatia DNV 2026 piece.
  • Estonia Digital Nomad Visa. Europe’s first DNV, launched August 2020. Income threshold EUR 4,500/month gross with six months of prior income history. Up to 12 months under a long-stay D visa, with a separate second application taking you to roughly 18 months total. Detail in our Estonia DNV explained piece.

That is six of the most-used routes. There are more: Cyprus, Greece, Hungary, Malta, Montenegro, and various national freelance permits that pre-date the DNV wave. The complete DNV guide has the running comparison.

A practical point that catches UK applicants out specifically: a national digital nomad visa gives you residence in that country, not in the EU as a whole. Maya’s Brexit Schengen mobility paradox piece is the companion read for understanding what residence-in-a-country actually grants you in mobility terms. The short version: residence covers the country, not the continent, and the 90-in-180 Schengen rule still applies for travel outside your country of residence.

The other practical point: UK passport holders still enter the Schengen Area visa-free for short stays. From 12 October 2025, the EU’s Entry/Exit System (EES) began phased rollout at external borders, and the Commission says it has been fully operational across all Schengen countries since 10 April 2026. EES is biometric registration on entry and exit, with the data stored to monitor the 90-in-180 calculation. The European Travel Information and Authorisation System (ETIAS), the EU’s equivalent of the US ESTA, was scheduled by the Commission to start in the last quarter of 2026, with the exact date to be announced in advance – check the Travel Europe site for the confirmed date. The Commission has set the fee at EUR 20 (waived for under-18s and over-70s), and the authorisation will be valid for three years or until passport expiry, whichever comes first.

These are not work-permission systems. They are pre-travel and biometric registration systems. If you want to work in Europe, you still need a visa or residence permit. ETIAS just means you also need a pre-travel authorisation for the short-stay visits that fall under visa-free entry.

And in the other direction: what’s changed for EU nationals coming to the UK

If you employ or contract with EU nationals in the UK, or you are an EU national living in the UK, the UK’s Electronic Travel Authorisation (ETA) is now fully in force. EU nationals (Irish citizens excepted, under the Common Travel Area) now need an ETA to visit the UK. The fee is currently GBP 20, valid for two years or until passport expiry, multiple entries, stays of up to six months at a time. Strict enforcement began on 25 February 2026, when carriers started checking for an ETA before travel; dual British citizens are advised to travel on a valid British passport or certificate of entitlement. The ETA is not a work permit; UK-resident EU nationals are typically covered by the EU Settlement Scheme.

However as I noted on my piece reflecting on ten years of Brexit from the EU side, there are populist political players calling settled status into question for Europeans in the UK right now. I know of at least one couple who have applied for British citizenship just because they no longer feel secure in this status, which is supposed to guarantee them permanent residence in the country where they have built their lives, careers, and home. in volatile geopolitical times everybody has to keep an eye on future trends and decide according to their long-range planning and risk tolerance.

What’s coming

Two forward-looking pieces matter to a UK-resident remote worker or microbusiness, and one is notable by its absence.

Mid-2027: the UK-EU SPS Agreement. If you trade in food, plants, animals, or related products, this is the change to watch. The government intends the agreement to take effect in mid-2027, subject to negotiations that are still ongoing, and Defra says it will publish further guidance as they progress.

The EU’s IOSS push. Directive (EU) 2025/1539 phases out the Special Arrangement, nudging non-EU sellers and facilitating marketplaces selling distance-sold imported goods into the EU towards IOSS. Check its application dates before planning around it. The UK side of this is HMRC’s IOSS intermediary registration, available since 1 April 2026.

Not scheduled: a UK right-to-disconnect Code of Practice. Often reported as coming in 2027, but the government has published no Code, consultation or timetable, and it does not appear in the government’s implementation timeline (updated October 2026).

There are slower-moving threads underneath these. Horizon Europe association is bedded in. The UK and EU signed the agreement bringing the UK back into Erasmus+ on 15 April 2026, with UK participation from 2027. None of these alone changes the day-to-day of a UK-based remote worker. Cumulatively, they are evidence of a slow re-warming after the cold open of 2021.

Closing

Ten years on, the practical position of a UK-based remote worker or microbusiness operator is not the worst-case scenario that some predicted, nor the seamless continuity that others hoped for. It is a third thing. It is a regulated, paperwork-heavy, navigable operating environment in which the rules are stable enough to plan around but complex enough to require ongoing attention.

The visa routes to Europe are real. The customs and VAT regime is settled but operationally heavy. The UK employment-law direction of travel is more worker-protective than it was. The planned SPS agreement would be the first significant softening of a UK-EU goods border in five years.

What this means for you depends entirely on what you do. If you sell digital services to EU clients from a desk in Cardiff, your operating model has barely changed in five years. If you sell physical goods into the EU from a kitchen table in Bristol, you have a compliance stack to build. If you want to spend a year in Lisbon or Berlin or Tallinn, the visa routes exist and we maintain detailed guides on each of them.

The thing that has changed most, ten years on, is that there are now playbooks for each of these situations. Some of them are ours. Most of them are written by the slow accumulation of people who have done the thing and reported back.

Frequently asked questions

What changed in the four phases of Brexit for remote workers?

The 23 June 2016 referendum, the 31 January 2020 withdrawal, the 31 December 2020 end of the transition period, and the gradual rollout of border, mobility, and trade rules from 2021 onward each shifted the operating ground for UK-based remote workers in different ways. The first phase was political and currency turbulence; the second was the cliff edge that wasn’t (because the transition deferred change); the third was the actual operational hit, where customs, immigration, mutual recognition of professional qualifications, and short-stay travel rules all changed in parallel; the fourth is the slow-build phase we’re still in, where carve-outs (SPS, Windsor Framework) gradually soften some edges while ETIAS and EES tighten others.

What visa options are open to UK remote workers in 2026?

The headline routes are Spain’s Digital Nomad Visa (income floor €2,849/month in 2026, family multipliers apply), Portugal’s D8 visa (income range and conditions detailed in our D8 mistakes guide), Estonia’s Digital Nomad Visa (€4,500/month), Italy’s DNV (€28,000/year), Croatia’s DNV, Greece’s DNV, and newer routes such as Bulgaria’s. Thresholds and procedures change often, so check each one against our country guides before you apply. The Europe DNV Index 2026 compares all current programmes.

Can I still travel freely between the UK and the EU?

Yes for short stays, no for unlimited stays. UK passport-holders can spend up to 90 days in any rolling 180-day period across the Schengen area as visitors. ETIAS pre-travel authorisation was scheduled by the Commission to start in the last quarter of 2026, adding a EUR 20 fee and a short online application, with each authorisation valid for up to three years – check the EU’s Travel Europe site for the confirmed date. EES (Entry/Exit System) began rolling out in October 2025 and has been fully operational since 10 April 2026, replacing manual passport stamps. For longer stays, you need a national visa or residence permit, which is where the DNV options become relevant. The Brexit Schengen mobility paradox covers the longer-stay routes in detail.

What’s coming next for UK-EU remote work?

Three things to watch: the planned UK-EU SPS (sanitary and phytosanitary) agreement, which softens the goods border for food and agriculture and is the first significant UK-EU rapprochement of the post-transition period; ETIAS, which completes the short-stay regime now that the EES has been fully running since April 2026; and the slow expansion of EU-side DNV routes, which keep opening new options for UK residents who want to live in Europe without being employees of EU companies. The general trajectory is stable, paperwork-heavy, and navigable rather than dramatically tightening or loosening.

Our UK country guide covers the visa, tax and practical side of the UK in one place.