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How Comprehensive Sickness Insurance can trip up your application

Comprehensive Sickness Insurance (CSI) has been given little thought by many EU citizens during their residence in the UK. However, it may prove a disastrous omission in many cases of British naturalisation applications by EU nationals and their family members.

Comprehensive Sickness Insurance

Lawful residence in the UK and comprehensive sickness insurance

EU nationals and their family members, just like all other applicants for British citizenship, have to provide evidence of lawful residence during the most recent 5 years immediately before the date of British citizenship application. However, this is not the only requirement to meet. All applicants for British citizenship by Naturalisation must also meet the good character requirement. When assessing the good character the Home Office looks at the most recent 10 years (or from the date of Applicant’s first arrival in the UK, if it was less than 10 years before application).

The good character requirement is frequently overlooked by applicants who do their application themselves without legal support.

Assuming that during the 10 years before the application the applicant was working in the UK with some short breaks between the jobs there is likely to be no problem with their Naturalisation application, as workers and self-employed did not need to have the CSI.

The problems with CSI may appear when the applicant spent time in the UK as a student or lived in the UK relying on own funds but without working (i.e. when the applicant was self-sufficient). Those EU nationals who resided in the UK as students or self sufficient were required to hold a Comprehensive Sickness Insurance (CSI) in order for their residence in the UK to be considered as legal. Their family members would also require CSI.

Why Comprehensive Sickness Insurance (CSI) is a problem

Until Brexit for EU nationals it was sufficient to show the EU passport to be allowed to enter the UK and to live here. For this reason, many EU nationals were not aware of the need for the Comprehensive Sickness Insurance (CSI). EU nationals and their family members could use the National Health Services in the UK and nobody asked them if they held CSI. However, the CSI requirement existed for Students and Self Sufficient individuals.

When EU national or their family members applied for their Permanent Residence (PR) status confirmation, at that point the Home Office required evidence of CSI and PR applications were refused for lack of CSI. PR status was equivalent to the Indefinite Leave to Remain (ILR) in the UK. In the same way as previously for the PR application, the Home Office is now checking the CSI at the time of Naturalisation applications.

What is accepted as Comprehensive Sickness Insurance (CSI)

The Home Office guidance explains that they will accept an EEA national or their family member as having CSI if they hold any form of insurance that will cover the costs of the majority of medical treatment they may receive in the UK. The below types of insurance are listed by the Home Office as sufficient:

• a comprehensive private medical insurance policy document
• a valid European Health Insurance Card (EHIC) issued by an EEA member
state other than the UK (or its predecessor form E111)
• form S1 (or its predecessor forms E109 or E121)
• form S2 (or its predecessor form E112)
• form S3

Conclusions on CSI for Naturalisation

EU nationals and their family members who did not have Comprehensive Sickness Insurance (CSI) when they lived in the UK as Students or self sufficient, cannot purchase the CSI now and backdate it. Those applicants would have to think if there is any way around the CSI requirement for them. Therefore, it is essential to look carefully at one’s history of residence in the UK (i.e. activities) before applying for Naturalisation as British Citizen.

For example, in some cases applicants might have acquired Permanent Residence (PR) many years ago and once the PR was acquired there is no longer the need to have the CSI. Others might be able to rely on their family member who worked in the UK. Some might have studied and worked in the UK at the same time, and may qualify as ‘workers’.

The matter of CSI is important for Naturalisation application and should be approached with care as the Naturalisation application fees are significant at £1,349.20. All that money and effort can easily be wasted and application refused by the Home Office if careful consideration is not given before the application is made.

Home office policy

Home Office gives some explanation of their policies relating to good character and Comprehensive Sickness Insurance (CSI) requirement here and here. The Home Office guidance is not particularly detailed and unfortunately does not provide much clarity on how they will assess Naturalisation applications by applicants who failed to obtain the CSI.

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