Access to Means-Tested Benefits for Low-Income EU Nationals Before and After the Withdrawal Agreement: A French-UK Comparison

This article investigates how UK and French governments process claims related to social assistance for EU citizens. Whilst the Citizen Rights Directive (CRD) limits the right to reside for benefit purposes, Member States have extensive leeway as to how they interpret and implement the CRD. The comparison between France and the UK shows that whilst public authorities in both countries have adopted a routine denial of social assistance for low-income EU citizens, these policies appear to have been more systematic in the UK than in France. There have also been significant differences in how French and UK governments have implemented the provisions of the Withdrawal Agreement, the legally binding international treaty that sets out the terms of the UK departure from the EU. Part 2 of the Withdrawal Agreement protects the post-Brexit residency rights of EU and UK nationals.