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Governments in the UK and EU accept skilled workers from outside their territories to boost economic growth and reverse the trend of their ageing societies. At the same time, populations are sceptical about sharing welfare state rights with newcomers. To square this circle, governments have restricted social rights for new immigrants in many European countries. However, while EU governments must observe Treaty legislation, the UK is no longer bound by such constraint. Little research exists on how much the rights of working migrants born outside the EU and their dependents diverge between countries and between immigrants and citizens and how the difference can lead to inequality between the two groups and nations.

This paper will take stock of the rights of such third-country nationals (TCNs) who come to work in the EU and the UK and their dependants during their first five years. Analysing EU- and national legislation will show that the UK is now an outlier in Europe. While most EU governments are moving towards granting TCNs the same or similar rights as EU migrants and citizens in the UK, after Brexit, many more are now excluded from essential benefits. The paper will assess what this difference means for the income of a TCN household with a skilled worker, a partner and children compared with a citizen-household in the UK, Germany and Ireland as EU countries with a similarly large intake of TCNs.

Dr Traute Meyer is a professor of social policy at the Department of Sociology, Social Policy and Criminology at the University of Southampton. She has researched the social rights of immigrants in Europe, including in the UK after Brexit.