Based on the Protocol on Social Security Coordination, which is part of the Trade and Cooperation Agreement concluded between representatives of the UK and the EU, similar rules are maintained for migrants between the Czech Republic and the United Kingdom after 1 January 2021 as for EU citizens. The protocol preserves the principle of one insurance country as well as the basic rules for determining the insurance country. Also, the standard posting of an employee between the EU and the UK within 24 months or simultaneously performing activities in several countries are regulated in the Protocol in a similar way as if the UK were still in the EU. Compliance with social security regulations will continue to be confirmed by form A1. According to the previous exit agreement, the standard EU Regulation (including A1 forms and their extension) continues to apply to employees posted from/to the UK before the end of 2020, even after 1 January 2021, until their situation changes.
In order to determine jurisdiction and the right to benefits, it is therefore crucial to correctly assess whether the migrant is covered by the EU Regulation, the exit agreement or the provisions of the Protocol.
