BREXIT – Currently your rights and entitlements as EU citizens continue unchanged.
Please click HERE for updates on the future implications of Brexit.

Frontier Workers – State Pensions

The purpose of this information sheet is to provide a useful guide explaining how frontier workers can claim a state pension.  Have a look at the Retirement FAQs for some further insight.

The existence of different Social Security systems on either side of the border raises a number of important issues for frontier workers and their families.  Under EU regulations a frontier worker can be defined as someone who lives in one member state and works in another, returning home at least once a week. Therefore people who live in the Republic of Ireland and work in Northern Ireland and vice versa are considered to be frontier workers.

With differences in both legislation and provision between jurisdictions it can be of no surprise that much confusion exists over what social welfare payments a frontier worker is entitled to. For many people it is not until they approach retirement age that these issues become apparent and this is reflected in the large number of enquires received by the Citizens Advice t and Citizens Information Centres from frontier workers who have queries regarding pension entitlements.

EU legislation generally governs the rules relating to social welfare payments for frontier workers. Generally speaking European Institutions seek to co-ordinate social security systems between member states in order to facilitate the free movement of people within the EU. Therefore, the same rules apply regardless of which member states you live or work in. For the purposes of this article we will use the example of frontier workers living and working between the two parts of Ireland.

EU directives state that frontier workers who have paid social insurance contributions in two or more EEA member states may be entitled to a pension or partial pension from each country awarded on a pro rata basis. This will be decided when they reach State Pension age, taking into account their country of residence.

Frontier workers approaching retirement age should normally claim for a pension in their country of residence. Therefore a person living in the Republic Ireland and working in Northern Ireland should apply to the Department of Social Protection in the south. The Department must then determine whether or not sufficient social insurance contributions have been made to qualify for either the State Pension (contributory). Where insufficient contributions have been made European Union legislation allows contributions from other member states to be combined this is known as aggregation. Therefore contributions made in different member states to be combined on a pro-rata basis. As such contributions made in Northern Ireland could enhance the rate of an Irish pension and vice versa. This same procedure applies in reverse if a claim for pension is made by a frontier worker living in Northern Ireland who has worked in the South.

When making a pension claim workers should list all countries where they have paid social insurance contributions. Generally, in whatever country you make the original pension claim the appropriate body will then contact all relevant authorities in other jurisdictions in order to work out the final pension entitlement.

Simply put, if you have worked in Ireland and one or more other EU state (including the United Kingdom) your social insurance contributions from each EU state will be added to your Irish social insurance contributions. This is done so as to help you qualify for a pro-rata pension based on a combination of contributions you have paid in these different jurisdictions. A worker should normally make a pension claim in their country of residence. However, if a worker has spent a significant part of their working life in another EU County, or in a country where Ireland or the UK has a Bilateral Social Security Agreement, they may qualify for a pension claimed in and based solely on contributions made in that country. In this case it is possible to go directly to the relevant authority in that country to apply for a pension.

Contribution based state pensions are an exportable benefit under EU legislation. Therefore, frontier workers who are receiving retirement benefits in the South may be able to transfer them to the North should they decide to retire there.   This means that if you live in the Republic of Ireland you may transfer your State Pension, both transitional and contributory, if you relocate to Northern Ireland. In general the non-contributory State Pension is not transferable under EU rules but there are special arrangements for people moving to Northern Ireland from the South. Similarly frontier workers living in Northern Ireland may transfer their retirement benefits to the Republic of Ireland should they decide to move there.

Workers who have made contributions under the legislation of both the United Kingdom and Ireland should apply for a retirement pension initially to the country in which they live.  The Department for Work and Pensions (DWP) in the United Kingdom and the Department of Social Protection in Ireland then work out how much you get from each.

If you have worked in the United Kingdom you can get further information and a pension forecast from:

State Pension Forecasting Team
The Pension Service
Tyneview Park
Whitley Road
Newcastle upon Tyne
NE98 1BA

Telephone:  0845 3000 168 or +44 191 218 3600

Website : www.hmrc.gov.uk

If you have worked in the Republic of Ireland you can get further information and a pension forecast from:

Department of Social Protection
Social Welfare Services Office
College Road
Sligo

Telephone: +353 (0)71 915 7100

Website: www.welfare.ie