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How post-Brexit bank account changes could affect British people in France

As the end of the Brexit transition period looms, the UK has so far failed to negotiate access to the European passporting scheme for banks - here's what that means if you are British and live in France.

How post-Brexit bank account changes could affect British people in France
Photo: AFP

Over the weekend it was reported that, with just three months to go until the Brexit transition period ends, the UK has so far not managed to negotiate a continuation of EU banking rules – known as passporting.

This means that all UK banks will need to apply for new banking licences to provide certain services in each of the 27 different EU countries.

And some banks have apparently decided that this is not worth the hassle in certain EU countries and have begun writing to their British customers registered as living abroad to inform them that they will be closing their accounts or cancelling their credit cards.

Tell us: Have you been affected by the closure of a UK account?

Here we take a closer look at the situation for British people living in France.

Is it all banks?

No, it's important to be clear that there is no blanket closure of accounts for all Brits living abroad, it depends on who you bank with and the type of account you have.

Essentially, applying for new licences will create a lot more admin for banks.

Banks already have to do this for many non-EU countries so clearly it is possible to do. But it seems that some banks are deciding that it's not worth the hassle of doing this for all 27 countries in the EU separately, especially ones where they only have a few customers.

As a country that has a large number of British people living here (estimates vary from 150,000 to 300,000) there is a good chance that banks will decided that it is worth their while to obtain a licence for France.

Is it all account types?

No. Again, this depends on the type of account you have, with straightforward current/checking accounts less likely to be closed.

It could also be the case that certain products become unavailable – for example many Barclaycard customers in France report being told that they will no longer be able to use their credit card.

Is it only if I use my French address?

Many British people living in France use a 'care of' address in the UK for their banking, for example the address of a family member who will forward on all correspondence they receive.

At this stage it seems that only people who have officially changed their address to a French one are receiving letters from their bank.

Can I challenge my bank's decision?

Banks are free to decide what products they offer and to who, but their decisions can be challenged via the Financial Ombudsman Service – find out more about the procedure to file a complaint here.

 

The UK government told British newspaper The Times that “the provision of banking services is a commercial decision for firms based on a number of factors” so Brits in France probably shouldn't hold their breath for any help from that direction.

Which banks?

We have asked all the major names in UK banking what their policy is for customers in France, here are the responses we have received so far. We will update this page as soon as we receive more responses.

Santander – the Spanish banking giant said it was keeping the situation under constant review but told The Local: “We have no current plans to close any of our retail [personal banking] or corporate accounts.”

Lloyds – the bank is understood to be closing business accounts – not personal accounts – of customers living in the Netherlands, Germany, Ireland, Italy and Portugal. However the bank said it had no current plans to discontinue any services for customers in France.

A spokesman said: “We have written to a small number of customers living in affected EU countries to let them know that due to the UK’s exit from the EU, regrettably we will no longer be able to provide them with some UK-based banking services. We want to keep customers informed and offer advice on next steps.”

HSBC – A spokesman for HSBC confirmed on Twitter that current accounts for customers in France would not be affected, provided they were used at least once every 12 months.

Barclaycard – numerous readers of The Local France have been in touch to say that they had received letters from Barclaycard telling them that their account would be closed. Barclaycard is separate to Barclays bank and it is understood that Barclays current accounts are not affected, although the company has not commented on the record so far.

Nationwide – a spokesman said no decisions had yet been taken on accounts held by UK nationals living in the EU. They told The Local: “We are closely monitoring all developments regarding Brexit and are prepared to deal with any outcome.

“Part of this preparedness includes reviewing the ongoing availability of products and services for those members who are resident in the European Union and the European Economic Area.

“Because the outcome of Brexit is not yet clear and the position continues to evolve, there is currently no certainty as to any actions we will be required to take. Regrettably we cannot provide any further detail on the impact on specific products and transactions at this point. However, we will communicate with members as soon as possible about any necessary changes that impact them.”

Member comments

  1. This article on UK bank accounts after Brexit is most imformative. However you mention the response of some of the banks, I wonder if you have had any response from any of the building societies such as the Nationnwide with whom I both bank and have a credit card registered with my French address.

  2. I saw a report elsewhere saying that NatWest had stated that they have no current plans to withdraw banking services from British people with EU addresses, but are keeping the situation under review.

  3. BARCLAYS HAVE NOTIFIED ME THAT THEY ARE CLOSING ALL MY ACCOUNTS WITH THEM, CURRENT AND SAVINGS, DESPITE HAVING BANKED WITH THEM FOR OVER 50YRS. AND NOT USING ANY ‘ADD-ONS’ (i.e. Travel ins., financial advice, mortgage, etc.). I HAVE BEEN TOLD IT IS A BLANKET CLOSURE ACROSS THE WHOLE OF THE EU OWING TO BREXIT, NO MATTER HOW MUCH MONEY IS HELD WITH THEM. I WONDER IF THIS IS ACTUALLY THE CASE.

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BREXIT

Is new court ruling the end for Britons fighting to remain EU citizens?

The Court of Justice of the European Union confirmed on Thursday that Brexit really does mean that Britons are no longer EU citizens. Claudia Delpero looks at whether there's any other way they can keep their rights.

Is new court ruling the end for Britons fighting to remain EU citizens?

The Court of Justice of the European Union confirmed on Thursday that Britons lost EU citizenship when the UK left the EU, on 1st February 2020. 

It is the first time the EU’s top court has rules on the matter, after a number of legal cases challenged this specific Brexit outcome. The decision also sets a precedent should other countries decide to leave the bloc in the future. 

What has the EU Court decided?

The Court of Justice decided on a case brought by a British woman living in France.

Before Brexit, she could vote and stand as a candidate in her town of residence, Thoux. But after the UK withdrawal from the EU, she was removed from the electoral roll and excluded from the municipal elections that took place in March 2020, during the transition period.  

As the mayor refused her appeal to restore the registration, she took the case to the regional court in Auch, which agreed to request an interpretation of the rules to the EU top court. 

Julien Fouchet, the barrister supporting her and several other cases on the EU citizenship of British nationals, argued that the loss of EU citizenship and voting rights was disproportionate. It would also be contrary to the EU Charter of Fundamental Rights, given that the woman also lost her voting rights in the UK, having lived abroad for more than 15 years.

Alice Bouillez, who has lived in France since 1984 and is married to a French national, could have applied for French citizenship, but did not do so because she said “this was not necessary” before Brexit and, as a former UK official, she had taken an oath of allegiance to the Queen.

On Thursday the Court of Justice announced the decision about her case. The court ruled that the “possession of the nationality of a member state is an essential condition for a person to be able to acquire and retain the status of citizen of the Union and to benefit fully from the rights attaching to that status.”

The court therefore confirmed that British nationals automatically lost their EU citizenship as a result of Brexit and, as a consequence, Britons also lost their voting and electoral rights in municipal elections in the EU (unless the country where they live set different rules). 

What is EU citizenship?

EU citizenship was introduced by the Treaty of Maastricht of 1992, when borders were opening and the bloc was integrating economically after the end of the Cold War. 

Under the treaty, every person holding the nationality of an EU member state is a citizen of the Union. EU citizenship is additional and does not replace nationality, the treaty specifies. But this creates the first form of a transnational citizenship that grants rights across borders.

EU citizens have the right to access each other’s territory, job market and services under the principle of non-discrimination. If they are economically active, they have the right to reside in other EU states and be joined by family members, access healthcare at the same conditions of nationals (for emergency treatment also when travelling temporarily), obtain social security benefits and see their professional qualifications recognised.

Beyond free movement, at the core of EU citizenship there are also political rights, such as participating in the European Parliament election, voting and standing as candidates in municipal elections when living in other EU countries, receiving consular protection from other EU states outside the EU, and taking part in European Citizens’ Initiatives asking to the EU to legislate on certain matters. 

Which EU citizenship rights have Britons lost with Brexit? 

For British citizens who were living in the EU before Brexit, the Withdrawal Agreement protects some of these rights. Britons covered by deal have their residence, access to work and education, healthcare, social security and qualifications secured, but only in the country where they were living before Brexit.

But the right to free movement in other EU states, consular protection in third countries, and the political rights attached to EU citizenship were lost, the Court confirmed. 

For British citizens in the UK, the trade and cooperation agreement has preserved some social security rights and, in theory, the possibility to have professional qualifications recognized when moving to an EU country. These provisions however lack details and may take a long time before they work in practice. 

As the “European Union” no longer features on British passports, the possibility to access EU lanes at airports to skip passport control queues has also vanished. 

“The loss of those treasured rights has been clear to those of us living in the EU from the early days of Brexit. But for Brits in the UK, the realities of life outside the EU, and the consequences of Brexit, are only just dawning. Long queues at the borders, roaming charges, obstacles to working abroad, etc. are the new reality,” said Sue Wilson, Chair of the group Remain in Spain. 

While she said the court’s decision was “no real surprise,” she argued that “this is not the Brexit the public were promised, or that the majority voted for.”

Can British citizens get some of these rights back?

Julien Fouchet was disappointed at the Court decision and promised to continue the legal fight, bringing the case at the European Court of Human Rights (which is not an EU institution). 

Other two cases on the matter of EU citizenship for British nationals are still pending at the Court of Justice of the EU. One of them aims to determine whether EU citizenship is a “fundamental status” that cannot be removed but Thursday’s decision could have already provided the answer.

Another option to reconsider some of the rights is the renegotiation of EU-UK trade agreement, when it will be reviewed in 2025. 

Meanwhile, the EU is revising the rules for non-EU citizens living in EU countries on a long-term basis, making it easier to move across borders. 

Applying for citizenship is so far the only option to regain voting rights, although not all EU countries allow dual nationality. 

Sue Wilson, who has long campaigned for the UK to stay in the EU, said: “There is only one way to restore the loss of our rights, and that’s to rejoin the single market, rejoin the customs union, and eventually, rejoin the European Union… Until that day, we will continue to be second class citizens whose rights have been diminished for the sake of an ideology.”

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