When the UK left the European Union, most of the headlines focused on travel, trade, and visas.
But for many people, the biggest impact of Brexit has been on their pensions.
At Arthur Browns Wealth Management, we work with UK nationals across Europe — in Portugal, Spain, France and beyond — who are now finding it harder to access or manage their UK retirement savings.
Here’s what’s changed, what’s still possible, and how to make sure your pension remains protected.
What’s Changed Since Brexit
Before Brexit, UK financial advisers could freely service clients across Europe under something called passporting rights.
This meant that a UK-regulated adviser could help a client living in France, Spain or Portugal without needing a separate licence there.
When the UK left the EU, those passporting rights ended overnight — meaning:
-
UK firms can no longer give ongoing regulated advice to clients who live in the EEA unless they have EU authorisation.
-
Some UK pension providers can no longer communicate with EU residents about drawdown or benefit access.
-
Many expats are being told their providers “can’t deal with them anymore.”
If you’ve received a letter like this, you’re not alone. It’s a compliance issue, not personal — but it does mean you’ll need an adviser who’s authorised in both jurisdictions.
You can read more about this regulatory change on the UK FCA’s Brexit guidance page.
Why Some UK Pension Providers Won’t Deal with EU Residents
When you access your pension (for example, taking income drawdown or tax-free cash), that’s a regulated event.
Providers are legally required to ensure you’re getting advice from a properly authorised adviser. But once you live in Europe, many UK firms can’t confirm this under EU law — so to avoid regulatory risk, they simply refuse service.
This has left thousands of expats unable to:
-
Move into drawdown.
-
Update investment strategies.
-
Consolidate old pension plans.
-
Receive income directly into EU bank accounts.
If this sounds familiar, the good news is there are regulated solutions available.
The Rise of Dual-Regulated Advice
The best way to overcome post-Brexit restrictions is to work with an adviser who is regulated in both the UK and Europe.
For example, at Arthur Browns Wealth Management, we are authorised in the UK by the FCA and partner with EU-licensed advisers for clients resident in Europe.
This ensures:
-
You remain fully covered under UK regulation for your pension.
-
You receive advice that also complies with local MiFID II rules.
-
Your investments and pension transfers are legally compliant and tax-efficient.
Dual regulation means continuity — you don’t have to worry about whether your advice is valid or your assets are protected.
The European Securities and Markets Authority (ESMA) sets out the MiFID standards for cross-border investment advice within the EU.
Reverse Solicitation: The Grey Area
Some UK firms claim they can still advise EU clients under a concept called reverse solicitation — meaning the client approached them voluntarily.
However, this area is highly restricted and varies from country to country.
For example:
-
France and Spain interpret it very narrowly.
-
Portugal has stricter enforcement post-Brexit.
-
Regulators can impose penalties if they view the advice as “actively marketed.”
So while reverse solicitation might allow occasional advice, it’s not a long-term or reliable solution.
If you’re living in the EU, you should ideally be working with a fully authorised adviser in your country of residence.
For reference, see the FCA’s statement on UK firms operating in the EEA.
How Brexit Affects Tax-Free Cash and Pension Withdrawals
If you’re over 55 and planning to take benefits, remember that:
-
The UK’s 25% tax-free lump sum isn’t always tax-free in Europe.
-
Local tax rules in Portugal, Spain, or France may treat withdrawals as taxable income.
-
You may no longer benefit from the UK’s personal allowance or income tax thresholds.
That means you could owe local tax on your UK pension withdrawals — even if your provider doesn’t deduct UK tax.
Always combine regulated financial advice with local tax advice to avoid double taxation.
The UK Government’s guidance on overseas pensions and tax is a good starting point.
The Case for International SIPPs
For many UK expats in Europe, an International SIPP is now the most practical option.
It allows you to:
-
Keep your pension under UK FCA regulation.
-
Access your funds globally in multiple currencies.
-
Continue working with a dual-regulated adviser.
-
Avoid the high costs and complexity of offshore QROPS structures.
You can read more in our full guide on International SIPPs.
Practical Steps for UK Expats in Europe
-
Check your provider’s policy — ask if they can still deal with EU residents.
-
Confirm your adviser’s regulation — ensure they hold both UK and EU permissions.
-
Review your tax position — local advice is crucial for withdrawals.
-
Keep UK pension documentation up to date — notify your provider of address changes.
-
Avoid unregulated offshore “solutions” — especially those promising “tax-free pensions” or quick transfers.
If you’re unsure, you can contact our cross-border team for a free review of your current position.
The Bottom Line
Brexit changed the rules of the game for thousands of UK expats — but it didn’t take away your right to access or manage your pension.
The key is to work with a firm that understands both sides of the border and holds the correct regulatory permissions.
That way, your pension stays safe, compliant, and optimised for where you live now — and wherever you go next.
At Arthur Browns Wealth Management, we specialise in UK-regulated, cross-border financial advice for expats living in Europe.
We help clients adapt to life after Brexit with clear, compliant strategies for pensions, investments, and long-term wealth planning.
Contact us
if you want to know more about how we can help, speak to a member of our team today.
Production