We are leaving France to live in Rep of Ireland. We wish to retire there. One of us is British the other dual Brit /Irish (NI born). We have lived and worked in France for 19 years, but worked much longer in UK with full UK state pensions. I have opted to take my UK pension after deferring it. I have deferred my French pension as I want to sort this out first.
As the majority of our working life was in UK, who would be responsible for the S1 when we move to Ireland. I cannot get a definitive answer from UK or Ireland. If France, who do I contact to obtain this ?
Please no criticism.
I think this is a special case covered by the UK-Eire arrangements (the Common Travel Area) that date back to partition in the 1920s - not an EU thing, so no S1 needed.
From the UK Gov website:
If youāre a UK national living in Ireland, youāre entitled to state healthcare in Ireland on the same basis as an Irish citizen.
You can access state health services if youāre āordinarily residentā in Ireland. This means that you have lived or you intend to live in Ireland for at least a year.
Youāll need to pay a fee for some services. The amount you pay for healthcare depends on your circumstances.
More info: Healthcare for UK nationals living in Ireland - GOV.UK
UK citizens donāt need visas to live in the Irish Republic, and vice versa.
Not sure why there should be any criticism?
Anyway the general principle is that the last State in which you worked is your competent state for healthcare. The complexity is that S1s are for State pensioners and you are not taking your French pension, so are not a pensioner of your competent state.
However if you have taken your UK State pension then they may well accept you.
The easiest is probably to phone the DWP overseas team and ask. But as Chris says maybe you donāt need one at all!
Thanks Jane and Chris, I will be taking my French Pension, but only after I have sorted this all out. If UK citizens as Chris says have a reciprocal arrangement in Ireland, then maybe itās quite simple. I will give DWP a call before I go further into this.
Re the criticism comment. I have encountered quite some vitriol on other sites before when asking about the admin required to move away, and I have seen some really nasty comments on FB when others have expressed a wish to move from France for whatever reason. Itās almost like one is being accused of disloyalty, when it ismerely a personal choice. Thank you both for your very constructive comments. I will move forward on them.
Hi Tab
Iām from Belfast and thinking of leaving France too, so youāll get no criticism from me!
This is probably completely irrelevant but I happened to be speaking to the overseas department of the Irish health service yesterday. I was trying to get written confirmation that my husband isnāt eligible for an S1 from Ireland (so he can join the SĆ©cu).
Took me a while to track down the department that deals with S1s but when I did, they were terribly nice and very helpful. Hereās the tel number in case itās ever of use to you:
00353 1 778 5127
The number works and a real live human actually answers the phone.
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This is off topic and may or may not apply to you depending on your status here- but if you are resident here under EU FOM it (FOM) still applies when you are returning to your EU home country.
Thank you for this information, but I donāt know what this is. Iāve never heard of it. Husband is here under Irish Passport and Iām on a 10 year professional CdS. Lived and worked here since late 2005. My home country is UK. Husband although having Irish Citizenship through birth on the Island, has only worked in UK and France.
FOM = āFreedom of Movementā - which we all had prior to Brexit, allowing UK citizens to live and work in any EU state.
But as I mentioned in my earlier reply I think the EU aspect is irrelevant since UK citizens have a right to live and work in the Republic of Ireland that predates the formation of the EEA, EEC, and EU.
The Common Travel Area (CTA) is a long-standing arrangement between the UK, the Crown Dependencies (Bailiwick of Jersey, Bailiwick of Guernsey and the Isle of Man) and Ireland that pre-dates both British and Irish membership of the EU and is not dependent on it.
Under the CTA, British and Irish citizens can move freely and reside in either jurisdiction and enjoy associated rights and privileges, including the right to work, study and vote in certain elections, as well as to access social welfare benefits and health services.
Iām sure that you are much more informed on UK/ROI aspects than I, but if husband is in France exercising EU FOM, he is entitled to use FOM in immigrating to his next EU country, including Ireland.
Itās a pretty obscure perk, IMO. Just as I , a US/IT dual, here in France under EU FOM, can move to Italy and continue to exercise FOM, even though itās my ānativeā country (when normally national immigration laws would apply). And I might just do it someday.
Which is great - but as already mentioned, my understanding is that he doesnāt need to invoke any EU rights or bureaucratic mechanisms like the S1.
I may be wrong, but the UK Gov web pages linked to above seem pretty clear on how this works.
At one point I looked into moving to Ireland as a possible step to getting Irish citizenship and therefore EU FOM, but you have to live there for five years before you can apply, unless you were born on the island of Ireland.
Thank you everybody. This is really appreciated and Iām a lot more clear on this matter now.
I did know however that as a spouse of an Irish citizen I will wait 3 years to get my own Irish citizenship if I choose. Weāll see as it isnāt actually necessary if I donāt intend to live in yet another EU countryā¦now thereās an idea 
I understand that the S1 only applies if the UK is your competent state. If you last worked in France and take a French pension, then France is your competent state and responsible for your healthcare, not the UK
Iāve finally got the definitive information from both UK, France and Ireland. Thank you to everybody who posted advice for me. Everyone was correct in slightly difference circumstances.
As we are moving to a third EU country, the health care will be funded from where we paid the most social security contributions. In our case the UK. It matters not that we have a French pension as it is the country where we paid into for fewer years. I checked with Overseas Healthcare Services in the UK, they do the S1ās, only took an hour of hanging on the phone. CPAM in France and HSE in Ireland and got the same answer each time. I even got it in writing from CPAM! Wondersā¦ surely not good customer service? Iāve got the process by which to get the S1 from UK as and when we have a moving date.
So I can almost tick that one off. Keeps the brain matter occupied however!
Thank you everybody.
Iām glad youāve got it all sorted out. However lest one might mislead others Iād like to clarify 
The last state you worked in is your competent state, not the one you have paid most contributions to.
However for UK citizens that doesnāt matter when moving to Ireland, or vise versa. You are availing of along established reciprocal agreement between the UK and Ireland on health care
Could you provide a comprehensive source for this please, because I do not think it is always the case.
That may be the ādefaultā stance but actually it is more complicated, you have to look at the specific situation.
For instance if a person works in the UK for 30 years, then works in France for 10 years, then retires, claims pensions in both countries , and moves back to the UK, then the UK will always become the competent state even though France was the last state they worked in. Not because of the number of years paid in to each system, but because the person is receiving a pension from the country they live in.
I have a feeling there may be other situations also where it is not simply the last state worked in.
S1s are applicable throughout the EU and are issued by whichever your competent state is. The S1 is an EU form not a UK form.
In the situation you describe does that assume the person is a UK national and if so by returning to the country of nationality naturally that would be the state that looked after them rather than the state they last worked in and were not a national of but simply an approved resident.
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I do not think nationality makes any difference. The hypothetical person in the example could be British or French or another nationality. As I understand it, quite simply if you live in country A and you are in receipt of a benefit from country A, that is where the healthcare buck stops.
I could be wrong, I am no expert but I am pretty certain that it is not as cut and dried as, the last state you worked in is always your competent state. As I understand it, the person in my example would be covered by the UK if he lives in the UK, and by France if he moves back to France. Which country would cover him if he moves to Spain? I do not know. If the last country worked rule applies then he would get an S1 from France, but if it is the greatest contributions he would get it from the UK.
Goodness Sandcastle Iām not going to give myself too much of a headache about a theoretical scenario.
But 
the person you describe doesnāt need a S1 (ie competent state) in either France or the UK, do they? They are entitled to cover in both countries on their own merits.
However (and hereās the rub) if they were living in France and had a S1 from the UK then they wouldnāt pay health social charges, would they? A UK S1 can save one a lot of money. But if it was the other way around, would they have to pay French social charges on their income?
A Dutch friend living here once explained that a Dutch S1 did involve paying social charges there and it was a matter of deciding whether French or Dutch ones were more expensive. All his pension income came from the Netherlands however.