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Brexit FAQs

How Brexit affects Vitality, your plan or your contract with us

We’re committed to providing you with the best service. We’ve answered your questions about the UK’s withdrawal from the EU and how it affects Vitality.

The UK left the EU on 31 January 2020 and entered an implementation period. This will operate until 31 December 2020. During the implementation period, EU law will continue to apply in the UK. The UK and the EU have indicated, in a Political Declaration, which they intend to reach agreement by the end of 2020. We will continue to watch any Brexit developments and engage with regulators.

Will consumer rights be affected during the implementation period?

During the implementation period, EU law continues to apply until 31 December 2020. The current protection and rights consumers have are unaffected. This includes the Financial Ombudsman Services and the Financial Services Compensation Scheme (FSCS). The Financial Ombudsman Service helps settle disputes between customers and firms. The FSCS is designed to protect customers if a firm becomes insolvent.

If you're a VitalityHealth member, business or corporate scheme holder

VitalityHealth is a UK regulated firm offering Personal, Business and Corporate healthcare plans. VitalityHealth’s product and coverage is unaffected by the UK’s withdrawal from the EU.

Note to Republic of Ireland (RoI) members:
From January 2021, UK firms will likely lose 'passporting' in the European Economic Area (EEA). VitalityHealth provides cover to members of Northern Irish Business and Corporate Schemes.

VitalityHealth will lose its passport if 2020 ends with no agreement on financial services and passporting. If you are a RoI member, VitalityHealth will cover you. This is because we will use Part 8 of the Withdrawal of the United Kingdom from the European Union (Consequently Provision) Act 2019. We will inform the Central Bank of Ireland of our intention within three months of the UK’s exit from the EU, to do so. At the point of renewal, the employer can select which product best suits their needs. This approach will ensure service continuity in the event of a no-deal.

No. Eligible employees can add those:

• Aged 16 or over at their cover start date and subject to PAYE
• Living in the UK for at least 180 days in each plan year.

No. See eligibility requirements above.


If you have the travel add-on

Our travel insurance won't be affected during the implementation period or if an agreement is reached. Your right to travel to EU countries will also be unaffected. This may be subject to change based on any future agreement with the EU. 
If you have a valid UK driving license, you can drive your own car in the EU during the implementation period. From January 2021, these rules may change. You may need an international driving permit (IDP) or insurance.

No. These benefits are unaffected by Brexit either during or post the implementation period.

The EHIC gives you access to state healthcare in the European Economic Area, plus Switzerland. Holders are treated as a resident of that country. They get healthcare at a reduced cost or for free.
From January 2020 until December 2020, the EHIC will work as it works now. After December 2020, this will depend on the type of deal the UK negotiates with the EU.
Our Worldwide Travel Insurance Plan gives you comprehensive cover for emergency medical expenses. Some routine and non-urgent treatment will not be covered under the plan.

If you're a VitalityLife member

VitalityLife is a UK regulated firm offering pure protection products to UK residents only. VitalityLife’s products do not place geographical restrictions on members once a policy has been sold. They aren't affected by the UK’s withdrawal from the EU. If a member emigrates to the EU after getting VitalityLife, the policy will still be in force. VitalityLife does not need to seek EEA authorisation to service these contracts. This is from the European Insurance and Occupational Pension Authority (EIOPA).

If you're a VitalityInvest member

VitalityInvest offers Pension and ISA products to UK residents. The products do not place a geographical restriction on members once sold. They won't be affected by the UKs withdrawal from the EU. The Pension and ISA products are ‘life policies’. This means if a member emigrates to the EU, the plan will still be in force. VitalityInvest does not need to seek EEA authorisation to service these contracts in future. This is from the European Insurance and Occupational Pension Authority (EIOPA).

For intermediaries and introducers

No. The UK’s withdrawal will not affect our approach to intermediaries or introducers. All intermediaries and introducers must agree terms before conducting any business with us. Intermediaries must be authorised in the UK and hold the correct permissions. The UK’s withdrawal from the EU has not affected these requirements.

Vitality's outsourced providers

We’ve liaised with our EEA-based suppliers. Leaving the EU will not affect their ability to provide services to Vitality.

Vitality's contractors


The UK is no longer an EU Member State, the UK is classed as a ‘third country’. This does not affect us until the end of the implementation period. If a deal is not reached by 31 December 2020, we will have to rely on other safeguards, such as Standard Contractual Clauses. These are likely to mimic the EU Model Clauses which we currently use.

The UK intends to deem the EEA “adequate” for data transfers in the event that the UK withdraws without a deal. But transfers from the EU to UK will need a data export solution or derogation. This is until the UK is deemed adequate to receive EU Data.

Yes we do. For the time being, reliance on EU Standard Contractual Clauses will be permitted for UK transfers. A later proposal will have the Secretary of State approve “standard data protection clauses” UK transfers. This is subject to Privacy Shield recipients declaring their commitments will apply to UK exported data. This is in line with International Trade administration guidelines. The UK will also permit transfers to all countries currently recognised as “adequate” by the EU.