A total of some 115,000 British citizens live and work in Germany; around 262,000 Germans have settled in the UK. The withdrawal agreement stipulates that citizens who were already living in the respective other country before 31 December 2020 (the "Cut-off Date") will in principle not suffer any disadvantage in future.
Germans in the UK
Nationals of an EU country who have been resident in the UK for five years before the Cut-off Date can apply for "Settled Status" (permanent residency right) under the "Settlement Scheme". EU nationals with Settled Status can continue to work in the UK after the transition period.
EU nationals who have not been resident in the UK for five years can apply for "Pre-settled Status" by the end of the transition period, which entitles them to work in the UK for a further five years. They can then apply for "Settled Status".
If EU citizens move to the UK after the Cut-off Date, they will have to apply for a visa. This will be granted on the basis of a points system. Factors such as level of income and industry will be taken into account here.
Brits in Germany
Brits who were already living in Germany before the Cut-off Date must register with the competent foreigners registration office by 30 June 2021 and will then receive a residence card ("Residence Document GB"). The procedure varies from region to region. This way, they secure their permission to reside and work in Germany even beyond 30 June 2021.
British nationals entering the country after 1 January 2021 will need a residence permit entitling them to work once they have found an employer.