Germany applied a different system for recognizing Britons’ rights after Brexit — The Local Germany
In Germany, British citizens who were living in the country before December 31, 2020, and meet the criteria of the UK’s Withdrawal Agreement from the EU have the residence rights provided for by it without having to obtain status in advance. Unlike Sweden, Germany has applied a declaratory system for recognizing these rights, The Local Germany reports.
Declaratory system in Germany
Britons who meet the criteria of the Withdrawal Agreement automatically have the rights provided for by it, even if they have not contacted authorities to obtain documentary confirmation. They can receive the Aufenthaltsdokument-GB document and, after five years of residence, the right to permanent residence.
In countries with a constitutive system, including Sweden, people must apply for residence status in order for their rights to be officially recognized. Matt Bristow, a representative of the British in Germany group, said that the declaratory model is one of the main reasons why Germany has not faced refusals and demands to leave the country on a scale similar to Sweden’s.
The situation in Sweden and difficulties in Germany
According to Eurostat, 2,500 British citizens in Sweden received deportation orders, while 458 people were reportedly deported or forcibly removed after Brexit. The UK Foreign Office estimated that 27.5% of Britons in Sweden were refused post-Brexit residence status, while the EU average was less than 4%.
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The publication noted that Sweden strictly interprets EU residence requirements. In addition, since 2022, the country has raised minimum salary requirements for work permits, as well as maintenance and housing requirements for family reunification. This makes it more difficult to renew temporary permits for Britons who do not have highly paid jobs.
In Germany, Britons also face bureaucratic problems. Immigration authorities sometimes provide contradictory explanations regarding permanent residence or advise people to apply for a regular residence permit instead of recognition of rights under the Withdrawal Agreement. Bristow said that British in Germany is not aware of a significant number of Britons who have been ordered to leave the country.
Germany’s Interior Ministry stated that it does not keep separate statistics on refusals of residence permits. At the same time, the number of British citizens required to leave the country did not change significantly in 2015–2025 and remained in double digits at the end of each year. At the end of 2025, about 77,500 UK citizens were living in Germany.
