HRMC A1 Certificate Expiring?

Since Brexit, UK citizens no longer have automatic rights to live and work in the EU. For remote workers in Spain employed by UK-based companies, this shift has created legal uncertainty — especially once the A1 Certificate of Coverage expires.

If you’re currently residing in Spain under the A1 regime, here’s what you need to know about what happens next and how to stay compliant.

Note: This situation affects holders of Spain’s Digital Nomad Visa and intra-company transfer residence permits when they initially relied on an A1 certificate.

What Is the A1 Certificate and Who Can Use It?

The A1 Certificate is a document issued by the social security authority in your home country — in the UK, that’s HMRC. It certifies that the worker remains subject to the UK’s National Insurance system while temporarily working from another country with which the UK has a social security agreement — in this case, Spain.

Legal Basis

The A1 certificate is governed by the UK–Spain Bilateral Social Security Agreement, introduced after Brexit. It replicates key coordination principles from former EU rules (Regulation 883/2004) and ensures that posted workers do not contribute to two social security systems simultaneously.

Who Qualifies for the A1 Certificate?

The A1 certificate is intended for posted workers, meaning:

• You are employed by a UK-based company,
• You are temporarily assigned to work from another country (like Spain),
• You remain under a UK contract and are paid in the UK,
• You continue to be integrated into the UK company’s operations.

In practice:

• You work remotely from Spain under a UK employment contract,
• Your salary is paid into a UK bank account,
• Your employer deducts UK National Insurance and tax.

Note: The certificate does not apply to freelancers or self-employed individuals — unless they qualify under specific provisions for posted self-employed workers, which are rarely used and more limited in scope.

Key Benefits of the A1 Certificate

• No Spanish social security contributions for up to 24 months
• Continued accumulation of UK pension and social benefits
• Simplifies paperwork when registering for tax or residency in Spain (especially when combined with a Digital Nomad Visa)

Limitations of the A1 Certificate

• It is valid for a maximum of 24 months
• It must be requested by your UK employer — you cannot apply yourself
• Extensions beyond the 24-month limit are rarely approved by HMRC, even if working conditions remain the same
• Applications for a second A1 certificate — to restart a new 24-month period — are routinely rejected, especially if the worker has not left Spain

After the 24-month period ends, you will need to either:

• Return to the UK, or
• Join the Spanish social security system, which requires holding a valid residence permit in Spain.

This is where most UK citizens must change their legal status in Spain — especially if they want to continue working remotely for their UK employer.

What Are Your Options After the A1 Certificate Expires?

If you want to remain in Spain after your A1 expires, you’ll need to transition to a different residence and work permit. These are the main pathways:

1. Become an Independent Contractor (Autónomo)

If your employer is willing to reclassify you as a contractor, you can apply as a self-employed digital nomad.

• Flexibility to work with other clients (if allowed)
• Lower social security contributions during the first year

Considerations:

• You must invoice your UK company as a freelancer
• Responsible for Spanish tax filings and monthly social security contributions
• May need help from a gestor (local accountant) to stay compliant

2. Apply for a Non-Lucrative Visa

If you’re taking a break from work or retiring early, the non-lucrative visa may be an alternative.

Requirements:

• Proof of sufficient financial means (approx. €30,000+ per year)
• Full private health insurance coverage in Spain
• A declaration that you will not engage in any work, including remote work

Important: This visa must be applied for from the UK, through the relevant Spanish Consulate (London, Manchester, or Edinburgh). The process can take up to three months.

This option is generally not compatible with remote work, but it may work for those stepping back from professional life.

Practical Tips for Planning Ahead

• Begin planning 3 to 4 months before your A1 certificate expires
• If considering self-employment, confirm your UK company supports the shift
• Understand your tax position: You’ll become a Spanish tax resident after 183 days, even if you’re still paid from the UK