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The difficulties of moving to Sweden as a non-EU spouse… even if you marry a Swedish princess

Sweden's Princess Madeleine and her British-American husband, Chris O'Neill, are returning to Sweden after living in Florida since 2018. But how can Chris move to Sweden as a non-EU citizen?

Published: 16 March 2023 14:30 CET
Updated: 18 March 2023 15:15 CET

The difficulties of moving to Sweden as a non-EU spouse... even if you marry a Swedish princess

Chris O'Neill and Princess Madeleine at Crown Princess Victoria's 40th birthday party in 2017. Photo: Christine Olsson/TT

Princess Madeleine and Chris O’Neill are moving back to Sweden with their three children in August. We hope they like it here.

Unfortunately for O’Neill, some things have changed since he left Sweden in 2015. Brits are no longer EU citizens, which means he’ll have to apply for a residence permit like all the other non-EU citizens planning a move to Sweden.

Unlike before, when O’Neill could live in Sweden as a self-sufficient EU citizen with comprehensive health insurance, there’s no such option for non-EU citizens, meaning he’ll have to fulfil the criteria for a non-EU residence permit (uppehållstillstånd), apply from abroad, and potentially wait for his permit to be processed before he can enter Sweden.

With waiting times well over a year for both family reunification permits and work permits, planning a move to Sweden in just a few months might be a bit… optimistic.

What options does Chris O’Neill have?

The most obvious route for O’Neill to take is a residence permit for moving to someone in Sweden, sometimes also referred to as a sambo permit.

O’Neill qualifies for this, as he is married to a Swedish citizen. His wife must also be able to support him and his three children. According to the Migration Agency, this maintenance requirement is fulfilled if the family member in Sweden has enough money to pay for their home, as well as living costs for the family.

The Migration Agency states more specifically that the Swedish family member must earn 9,445 kronor per month to support a couple living together, plus 3,055 kronor per month for each child under the age of six and 3,667 kronor for each child aged between 7 and 10 years old.

The couple’s children are aged 5, 7 and 9, meaning that Madeleine will need earnings of at least 19,834 kronor a month (after tax) on top of housing costs in order to fulfil this requirement. She can also fulfil this requirement by having enough savings to support the entire family for at least two years – so a mere 476,016 kronor, plus whatever their housing costs will be for the two-year period.

Let’s assume that she can cover the family’s living costs – she’s a member of the Swedish royal family, after all.

Next, Madeleine needs to have a home “of a suitable size and standard” for the family to live in together.

The Swedish Migration Agency states that a family consisting of two adults needs to have an apartment with a minimum of one room and a kitchen or kitchenette, with more rooms necessary if the family has children. Two children can share one room, it states, meaning that O’Neill and Madeleine need a room with at least three rooms, one kitchen and one bathroom for them and their three children.

The family’s seven-room apartment by Nybroplan in Stockholm is definitely “of a suitable size”, and after a six million kronor renovation a few years ago we can assume that the standard is up to scratch.

O’Neill will also have to provide proof of identity with a valid passport. He’s a citizen of the US and the UK, so here he can choose whichever passport he prefers.

Great, so Madeleine and Chris O’Neill easily fulfil the requirements.

What are the next steps?

Firstly, as Madeleine is a Swedish citizen planning on moving to Sweden with a family member who does not hold EU citizenship, the couple will need to prove that they are planning on moving to Sweden “within the near future”. They can do this by providing a housing contract or a job offer, or presumably a press statement from the Swedish royal family stating their plans to move over in August.

O’Neill can’t move to Sweden until his application has been processed, but he is allowed to visit Sweden for up to 90 days at a time, and, as a citizen of a visa-free country, he doesn’t need a visa to do so.

He may also need to visit a Swedish embassy abroad in order to undertake an interview before his application can be processed.

With the family planning on enrolling their children in Swedish schools this autumn, it looks like Chris and Madeleine – like many couples consisting of a Swede and a non-EU citizen – will have to live apart, with Chris separated from his children for months at a time.

In that time, he won’t be eligible for a Swedish personal number, Swedish healthcare, or any other benefits such as sick leave or VAB.

He’ll also have trouble getting BankID or opening a Swedish bank account (unless he already has one from last time they lived in Sweden), and may struggle to get a gym membership, phone contract, or even a membership card at the local ICA (do husbands of princesses do their own food shopping?)

As a British citizen applying for a residence permit for the first time to move to someone in Sweden for the first time who he has been living together with outside Sweden for at least two years, O’Neill can expect to wait around 15 months. Now, that figure isn’t a guide – technically, only 75 percent of recently closed cases matching those criteria were concluded within 15 months – so he could have a much longer or much shorter wait before he’s reunited with his family.

You may be thinking ‘but he’s a successful businessman, can’t he just apply as a self-employed person’? Well, yes, if he wants, but then he’ll be waiting even longer – 75 percent of recently closed cases for permits as a self-employed person got an answer within 29 months.

Member comments

jennykjellqvist - 16 March 2023 at 22:38 CET

A very well written article as well as a good chuckle Becky.
So sad and all so true.
What a stressful time this is after Brexit.
James - 17 March 2023 at 07:32 CET

Call me cynical, but I can’t imagine he won’t be granted a permit before he’s even applied for one.

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What Brits in Sweden need to know if they move back to the UK post-Brexit

Moving countries is a time-consuming process – but if you’re British and living in Sweden you might think that moving back to the UK would be simpler? Well, there won’t be a language barrier and as a UK citizen you won’t need any immigration paperwork (although if you’re bringing a Swedish partner you with then that gets complicated) – but you will still face administrative hurdles around pensions, healthcare, driving and taxes.

Some of these issues existed before Brexit, while others are as a direct result of the UK leaving the EU. Here are the most common questions from Brits thinking of moving back to the UK.

Do I still qualify for NHS treatment?

You are entitled to NHS treatment if you are “ordinarily resident” in the UK – there is no minimum time limit so as soon as you are back in the UK on a permanent basis, you can use the NHS. You will need to register for a GP in your local area in order to access non-emergency treatment, and to get an NHS number if you do not already have one.

You may need to provide proof of a UK address in order to use NHS services – although in reality UK citizens are rarely asked for this, apart from when registering with a GP.

If you have been an S1 holder while living in the EU you should cancel that, just so there is no confusion over where you are getting your healthcare.

If you go back to Sweden for a visit, remember that you are now a tourist and will need a GHIC card to get European healthcare, while travel insurance is also advised in case of accident or illness while visiting an EU country.

Can I drive on my EU licence in UK?

If you have been living in the EU you may have had to change your UK licence for a French or Spanish one for example.

Once you’re back living in the UK you can continue to drive on you EU licence until the age 70 or if you move to the UK when you are 67 or over you can drive for three years. After this time you’ll need to change your licence.

If your licence or photocard has an expiry date – once it’s time to renew, you should swap it for a UK licence. You’ll need a valid photocard licence to drive in the UK.

You can find details on the swap process for UK licences here, and if you’re in Northern Ireland here.

UK residents with an EU licence can if they want exchange their licence for a UK one, if they wish to do so, without the need for a re-test.

Can I bring my Swedish partner with me?

If you’re returning alone you won’t need to do any kind of immigration paperwork, your UK passport is enough. However if you are bringing a partner with you who is not a UK citizen, it becomes complicated.

After the end of the Brexit transition process there was an “amnesty” period in which Brits with EU partners could move back to the UK under the old immigration rules. This is now ended and EU partners face the same immigration process as all other foreign spouses.

Essentially either your partner will need to have already secured a relatively high-paying job in the UK, or you will need to prove that you have a large amount of money to support them. They will need to go through the process of getting a UK visa (which is expensive – between £1,000 and £1,500 just for the visa fee) and there is no guarantee that their application will be successful simply because they are married/in a civil partnership with a Brit. They will also need to take an English-language exam.

Here are full details.

What about my pension contributions from the EU?

If you have been working in Sweden, you will probably have been contributing to the Swedish pension system. Pre-Brexit, UK and EU pension contributions could be blended into a single pension – but this is no longer the case.

Brits still living in the EU who are covered by the Withdrawal Agreement are theoretically covered by blended pensions if they had made pension contributions in the UK before moving to the EU, but the same does not apply if you move back to the UK.

The good news is that EU countries still practise this – so if for example you have paid into pensions in France, Germany and Italy, your contributions will be totted up and paid out as a single pension – you apply in the last country you worked in. Bear in mind, however, that different countries have different pension ages.

The country that is paying your pension may require you to have an EU bank account to pay into – and you should check with the country paying your pension whether there are any other conditions to observe.

When it comes to a pension from the UK, it depends on how long you worked there – the basic rule is that you need 10 years of National Insurance contributions in order to get a state pension.

However the UK government states that periods of work done in the EU or EEA “may” count towards your qualifying period. That said, even if they do, they don’t count towards the total pension amount – so for example if you worked for seven years in the UK and the remaining 35 years of your career in the EU, you can qualify for a UK state pension, but it will only be based on the seven years of work in the UK (in other words, the payment per month will be tiny).

Here are further details on UK pension entitlement.

Do I need to hand back my residency card, health card etc before I leave the EU?

Most countries require that you hand back residency cards before you leave, but in truth this is rarely strictly enforced. Check with the Swedish Migration Agency about what you should do with your residence permit (be it an uppehållstillstånd or a card proving your uppehållsstatus), as they may want you to post it back.

If you do end up keeping residency or healthcare cards – don’t use them on trips back to the EU. Tempting as it might be to avoid border queues or healthcare fees, you will create a confusing official record if you are claiming to be resident of two countries at once.

If you have taken Swedish citizenship, that is a different matter and of course you are entitled to keep and use your Swedish passport when visiting the EU.

Do I still have to pay Swedish taxes?

It’s highly likely that you were paying taxes in the country you lived in. Generally, tax declarations concern the previous year, so you will have to do at least one tax declaration and payment after moving back to the UK.

In Sweden, you usually get your tax declaration at the beginning of March, with the deadline for declaring in May, and it concerns the previous calendar year. So if for example you move back to the UK in April 2023, you will have to complete a tax declaration in May 2024, covering the time you spent in Sweden in 2023.

If you still own property in Sweden you will pay property taxes there, and if you have any earnings in your former home you will likely still have to pay taxes there – check with the Tax Agency.

When you left the UK, you will likely have informed HMRC that you were leaving the country, so you will now have to tell them that you’re back. Whether you have to fill out a UK self-assessment form depends on whether you are a salaried employee or self-employed/retired.

Can I keep my Swedish bank account? Do I need a new UK account?

This one depends on the policy of your bank, but most banks in Sweden require you to have a Swedish address.

It’s possible that your UK bank may have closed your account while you were living outside the UK, in which case you will need to open a new one.

A practical option while you are moving and still have interests in both countries is to open an internet bank account with a company like Wise or Revolut – these offer accounts in pounds, euros, and a range of other currencies including the Swedish krona and give you a European IBAN and a UK sort code, so you can use it in both countries.

Will my EU qualifications be recognised?

If you were studying or gaining professional qualifications while living in the EU, don’t assume that these will be recognised in the UK. Brexit ended the mutual recognition of qualifications – check with the professional or academic body that issued them whether these are recognised in the UK, you may need to acquire a certificate of recognition.

It’s a good idea to check this point before you start job-hunting in the UK.

Be prepared for hassles

The advantage of moving back to the UK is that you’re not starting from scratch and at least you know how things like council tax, electricity billing and healthcare work.

However, don’t assume that it will all be plain sailing – if you don’t have a recent UK address, you might be an anomaly in many companies’ systems and you’re likely to be forced to have several long and annoying conversations with call centres while you explain that while you are a UK citizen, you have not recently been living in the UK.

There are likely to be other niggles too – many UK car insurance companies won’t recognise a no-claims bonus built up abroad, so you’ll be back to paying full premiums on your car insurance, while banks might request extra money laundering checks due to your foreign associations.

A lot of people in the UK also seem to be confused about the difference between citizenship and residency, so be prepared to have the following conversation a lot: “I’ve recently been living in Sweden. No, I’m not Swedish, I’m British, I was just living in Sweden. Yes, I am a UK citizen.”

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