Comments on the Commission Implementing Decision

On 4 March 2020, Jane Golding and Jeremy Morgan, QC, compiled the attached paper on behalf of British in Europe commenting on the Commission Implementing Decision of 21 February 2020. It has been sent to the Task Force unit responsible for Citizens’ Rights and will be circulated to other interested parties.

“As a prescribed document intended “to evidence rights provided under Title II of the Agreement” the proposed format fails to include an essential element, namely whether or not the holder has the status of permanent residence.”

This has important ramifications as laid out in the paper.

Read the paper in full here.


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The announcement by the Commission on the format was lauded by many as a great step forward, some people mistakenly believed it gave additional rights. We need experts who understand the implications of the details to review every decision made and call out when they are lacking.