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Maître Reda KOHEN, avocat au Barreau de Paris
Maître Reda KOHEN
Avocat au Barreau de Paris

British Early Retiree in France After Brexit: Join PUMA, Check Your CSM Bill and Challenge a CPAM Refusal

You retired early, sold up or simply decided that life would be better in France, and you now live most of the year in your house in the Dordogne, Brittany or the Luberon. You are too young for a United Kingdom State Pension, you do no paid work in France, and you live on savings, rental income or a private pension. Then two letters arrive that you did not expect. The first, from the Caisse primaire d’assurance maladie (CPAM, the local French health insurance fund), questions your right to French state healthcare. The second, from the URSSAF (the French body that collects social security contributions), demands several thousand euros of cotisation subsidiaire maladie (CSM, the subsidiary health contribution paid by inactive residents). This article explains, for a British reader living in France after Brexit, how the French universal health system covers you, when you owe the CSM, how to check the bill line by line, and how to challenge a refusal or a wrong assessment within the time limits. Every French term is explained the first time it is used, and every decisive legal statement is linked to its official source.

I. How do you join PUMA as an inactive British early retiree in France?

A. Are you resident in France on a stable and regular basis after Brexit?

The gateway to French state healthcare is the Protection universelle maladie (PUMA, the French universal health protection scheme). The statute expresses the principle in deliberately wide terms: “Toute personne travaillant ou, lorsqu’elle n’exerce pas d’activité professionnelle, résidant en France de manière stable et régulière bénéficie, en cas de maladie ou de maternité, de la prise en charge de ses frais de santé dans les conditions fixées au présent livre”. In plain English, anyone who works in France, or who lives in France on a stable and regular basis without working, is covered for illness and maternity. An early retiree with no professional activity therefore comes under the second branch of that sentence: residence, not work, is the basis of the right. The official English-language page of service-public.fr, the French administration’s public information service, confirms the logic in everyday language: “To qualify for the Puma, you must work or reside in France on a stable or regular basis” (service-public.fr, “What is the universal health protection (Puma)?”). The ameli.fr portal of the French health insurance system says the same thing from the insurer’s side (ameli.fr, “La protection universelle maladie”).

Stability and regularity are two separate tests, and a British file after Brexit must satisfy both. Stability is a question of fact. The regulation provides that “sont considérées comme résidant en France de manière stable les personnes qui ont leur foyer ou le lieu de leur séjour principal” on French territory. In practice the CPAM looks for the centre of your everyday life: the house or flat where you normally live, continuous presence in France, and the familiar bundle of proof — a lease or title deeds, electricity and water bills, French tax notices, bank statements showing daily spending in France, and, where relevant, school certificates for children. Short absences for family visits to the United Kingdom do not by themselves break stability, but a file that shows more nights in Kent than in Charente will struggle. As a rule of thumb used on the ground, three months of continuous presence is the minimum before an application for inactive residents is examined, so keep dated proof — travel tickets, the moving company’s inventory, the first electricity bill — from the day you arrive.

Regularity is a question of immigration status, and this is where Brexit changed everything. Before 2021, a British passport was enough. Today a British national who was not covered by the Withdrawal Agreement needs a visa and then a titre de séjour (a French residence permit) to live lawfully in France, while a person protected by the Withdrawal Agreement holds the specific carte de séjour (residence card) marked “accord de retrait du Royaume-Uni de l’UE”. The CPAM will ask for a copy of that card or permit, and it is entitled to do so: regularity of stay is part of the statutory test. This is also why the order of your administrative steps matters. Arrive on the correct long-stay visa, validate it online on arrival, apply for the residence permit at the préfecture (the local office of the French state) before the visa expires, and only then file the health-cover application with proof that your stay is lawful. A file lodged while you are out of status invites a refusal that is difficult to overturn, however genuine your French home may be.

The practical application itself is made to the CPAM of your place of residence, on the standard “demande d’ouverture de droits” form, with your passport, your residence permit or Withdrawal Agreement card, evidence of address, birth certificates with a certified translation where needed, and details of any health cover in the United Kingdom. Ask for a dated receipt for everything you hand over. If the file is complete, the CPAM issues an attestation de droits (a certificate of entitlement to health cover) and then the famous green plastic carte Vitale (the French health insurance card presented at the doctor’s surgery and the pharmacy). Keep the paper attestation even after the card arrives: hospitals, laboratories and the reimbursement claims discussed later in this article still ask for it. If the CPAM stays silent or refuses, do not simply reapply with the same papers; the refusal letter sets a two-month clock running, and the challenge procedure in Part II below must be used.

One final point on this first test. French law also organises cover for people who work: employees and self-employed workers are affiliated to a compulsory scheme whatever their place of residence. If you take even modest paid work in France — a part-time salaried job, a registered self-employed activity — you move out of the inactive-resident box into the worker box, with contributions deducted at source and no CSM. That is sometimes a deliberate choice for early retirees who do consultancy or gîte management, but it has tax and social consequences of its own and should be weighed with advice, not stumbled into.

B. Where does an S1 certificate fit, and when are you purely a PUMA member?

Many British readers arrive in France with two acronyms in their luggage — S1 and EHIC — and a vague hope that one of them replaces French health cover. Neither does, but each has a precise role that an early retiree should understand, because the wrong assumption here is the single most common cause of the refusals and double bills seen in practice.

The S1 certificate is a portable document by which the United Kingdom, as the state that pays your pension or certain benefits, accepts financial responsibility for your healthcare in France. The British government’s own guidance for nationals living in France explains the mechanism: pensioners and some other groups can obtain an S1, register it with the French system, and receive a French social security number on that basis — “This confirms your right to French state healthcare and your French social security number” (GOV.UK, “Healthcare for UK nationals living in France”). The same guidance notes that a person who starts drawing a United Kingdom State Pension may acquire the right to apply for an S1 at that point. In other words, the S1 follows the pension; it does not precede it. An early retiree in their fifties, living on savings, dividends or a private pension that is not yet in payment from the British state system, is normally not entitled to an S1 at all. For that person, there is no British certificate to register, and PUMA as an inactive resident is the only route to French state cover.

The distinction matters financially as well as administratively. A pensioner whose S1 is registered is treated, for healthcare funding purposes, as a charge of the British system: France provides the care and the United Kingdom reimburses it under the coordination rules. Such a person is not in the same contribution position as a purely PUMA-affiliated inactive resident, and the CSM analysis in Part II below starts from a different place. By contrast, the early retiree with no S1 is covered by France alone and falls squarely within the French contribution logic, including the possible CSM bill. The practical lesson is simple: do not apply for an S1 you are not entitled to, and do not delay your PUMA application while waiting for a pension that is years away. Conversely, the year you do reach State Pension age, or the year a qualifying British benefit begins, contact both the British issuing authority and your CPAM promptly, because registering the S1 changes who pays for your care and can change which contributions you owe from that year onwards.

The European Health Insurance Card (EHIC), and its post-Brexit successor the Global Health Insurance Card (GHIC), cause even more confusion and deserve a blunt clarification. These cards cover medically necessary treatment during a temporary stay — the holiday, the family visit, the short trip back to see grandchildren — and nothing more. A British resident of France cannot use a United Kingdom-issued EHIC or GHIC as a substitute for French residence-based cover, and presenting one at the CPAM in support of a PUMA application proves nothing about stability or regularity of residence. Keep the card for your trips, by all means, but build your French file on French evidence: the lease, the bills, the residence card, the tax notices.

One related safety net should be mentioned while the household budget is under discussion. French law gives persons covered by the universal scheme a right to complémentaire santé solidaire (C2S, the French means-tested top-up health cover that pays the share the state scheme leaves to patients), free of charge below a resource ceiling and for a modest fixed contribution just above it: “Les personnes mentionnées à l’article L. 160-1 ont droit à une protection complémentaire en matière de santé” under the conditions that follow. An early retiree whose capital is tied up in property but whose declared income is modest is sometimes eligible without realising it. The application is made to the CPAM alongside the PUMA file, and a refusal of C2S has its own appeal route identical to the one described in Part II. It does not reduce the CSM, but it can substantially reduce the family’s remaining health spending, which is often the other half of the same worry.

II. How do you check your CSM bill and challenge a CPAM or URSSAF decision?

A. Is the CSM amount on your URSSAF notice correct?

The shock of the CSM bill comes from a misunderstanding: PUMA membership is free at the point of affiliation, but it is not free of contributions for everyone. The statute states the chargeable position directly: “Les personnes mentionnées à l’article L. 160-1 sont redevables d’une cotisation annuelle lorsqu’elles remplissent les conditions suivantes”, and the two conditions that follow define the classic early-retiree profile. First, professional income earned in France during the year concerned must be below a threshold fixed by decree — and where the person is married or in a civil partnership, the spouse’s or partner’s French professional income must also be below that threshold. Second, the person must have received no retirement or invalidity pension, no annuity and no unemployment benefit during that year, and the same must be true of the spouse or partner. A couple in their fifties living on dividends, rental income and savings interest, with no French salary and no pension yet in payment, meets both conditions precisely, and that is why the bill arrives. Note the couple-wide test carefully: one spouse’s return to part-time work, or the other’s first pension payment, can take the whole household out of the charge for that year.

The base of the contribution is then defined on capital income, not on salaries: the statute lists land income, income from movable capital, capital gains on the sale of property or rights of any kind, and non-professional business profits, assessed under the methods of the French tax code, with a reserve provision sweeping in benefits in kind and the value of assets held anywhere in the world where they do not already appear in the tax return. In practice the URSSAF works from the figures the tax administration sends it after your French income tax return, which is why a household that files late, or that omits foreign accounts and income on the mistaken belief that “British income stays in Britain”, tends to receive an estimated or inflated assessment first and an argument afterwards. File the French return fully and on time, declare worldwide income as a French resident, and keep the avis d’impôt (the French tax assessment notice) next to every CSM notice you receive: the two documents must tell a consistent story.

The rate and formula sit in the regulation. The decree provides that “Le montant de la cotisation mentionnée à l’article L. 380-2 est déterminé selon la formule suivante : Montant de la cotisation = 6,5 % × (A-0,5 × PASS) × [1-R/ (0,2 × PASS)]”, where A is the capital-income base capped at eight times the annual social security ceiling (PASS, the plafond annuel de la sécurité sociale, the reference figure revised each year) and R is professional income, so that the charge falls as activity rises and disappears when earnings reach the threshold. The URSSAF publishes the current PASS, the abatement and the worked examples each year on its dedicated PUMA page (urssaf.fr, “Bénéficiaire de la protection universelle maladie (PUMa)”), and your first check should always be against that page for the year of the notice, not against a blog post or a forum thread about a different year. Where cover lasted only part of the year, the regulation requires a pro rata reduction, and the statute provides that the contribution is recovered in the year following the year assessed — so the notice received this autumn normally relates to last year’s income, and last year’s pension start date or return to work can already defeat it.

The courts have examined this contribution repeatedly, and three rulings give the honest picture: the charge is lawful in principle, but its calculation has been tightly policed. In April 2025 the Second Civil Chamber of the Cour de cassation (the French supreme court for civil matters) recorded a typical dispute in these terms: “l’URSSAF du Limousin (l’URSSAF) a adressé à Mme [W] (la cotisante), le 26 novembre 2018, un appel de la cotisation subsidiaire maladie pour l’année 2017, au titre de la protection universelle maladie”, before rejecting the policyholder’s challenge — “REJETTE le pourvoi” (Judgment No. 348 F-D, Appeal No. 22-24.759, 10 April 2025). A few weeks earlier the same chamber had dealt with the previous vintage year in identical fashion: “l’URSSAF du Centre – Val de Loire (l’URSSAF) a adressé à M. [M] (le cotisant), le 15 décembre 2017, un appel de la cotisation subsidiaire maladie pour l’année 2016, au titre de la protection universelle maladie”, and again the appeal was rejected (Judgment No. 157 FS-B, Appeal No. 22-21.800, 27 February 2025). Behind both rejections stands the constitutional settlement: by Decision No. 2018-735 QPC of 27 September 2018 the Constitutional Council declared the core of the CSM legislation constitutional subject to an express reservation, recalled by the Conseil d’État (the French supreme administrative court) in these words: “la seule absence de plafonnement d’une cotisation dont les modalités de détermination de l’assiette ainsi que le taux sont fixés par voie réglementaire n’est pas, en elle-même, constitutive d’une rupture caractérisée de l’égalité devant les charges publiques. Toutefois, il appartient au pouvoir réglementaire de fixer ce taux et ces modalités de façon à ce que la cotisation n’entraîne pas de rupture caractérisée de l’égalité devant les charges publiques” (CE, 1st and 4th Chambers combined, 10 July 2019, No. 417919). The executive then complied from 1 January 2019 with a lower rate and a cap, while the courts upheld the earlier years’ notices computed under the 2016 scale. The consequence for your file is practical, not philosophical: do not expect a court to annul the CSM on principle, but do verify the year, the rate, the cap, the base and the household test for that exact year, because errors there succeed where attacks on principle fail.

Run the following checks on every notice before paying or contesting. First, the year and the scale: which assessment year, which decree version, was the cap applied for 2019 onwards, was the pro rata applied for a mid-year arrival or departure. Second, the household: were you married or in a partnership that year, did either member receive any pension, annuity or unemployment money, however small or foreign, and did either member earn French professional income above the threshold. Third, the base: reconcile each line of the notice with the corresponding box of the French tax return and the tax assessment notice, including British rental income, dividends and gains once declared in France, and challenge any “train de vie” lifestyle add-on that the fund cannot document. Fourth, the status: were you an S1 holder for all or part of that year, or did you start a pension mid-year, which may remove or reduce the charge for the period concerned. Put each discrepancy in writing with the supporting document attached; a telephone objection leaves no trace and stops no clock.

B. How do you challenge a refusal or a bill, and within what time limit?

French social security disputes follow a compulsory two-stage path, and missing the first step is fatal to the second. Contentious claims against a decision of a social security body must first go to the fund’s internal review board, the Commission de recours amiable (CRA, the amicable appeals commission of the fund): the regulation states that “Les réclamations relevant de l’article L. 142-4 formées contre les décisions prises par les organismes de sécurité sociale […] sont soumises à une commission de recours amiable”, and it adds the sentence that governs your diary: “Cette commission doit être saisie dans le délai de deux mois à compter de la notification de la décision contre laquelle les intéressés entendent former une réclamation”. The statute behind it makes the prior claim the gateway to any court action: “Les recours contentieux […] sont précédés d’un recours préalable, dans des conditions prévues par décret en Conseil d’Etat”. In ordinary language: within two months of receiving the CPAM refusal or the URSSAF assessment, send a reasoned written claim to the CRA of that exact body, by recorded delivery or by a tracked online channel that produces a receipt, setting out each ground separately and enclosing every supporting document. A letter to the wrong body, or a phone call to the right one, does not preserve your rights.

Draft the CRA claim as if the judge will read it, because the judge may. For a PUMA refusal, attach the residence permit or Withdrawal Agreement card, the dated evidence of continuous presence, the lease or deeds, the utility bills, the tax notices and the birth certificates, and answer precisely whatever ground the refusal letter gave: missing document, disputed stability, disputed regularity. For a CSM bill, attach the tax assessment notice for the year concerned, proof of any pension start date or professional income, the S1 registration certificate where relevant, and a recomputation showing the correct figure under the year’s scale. Ask expressly, in the same letter, for a detailed statement of the calculation where the notice gives only a total. Keep copies of everything, diary the date of sending, and chase a written decision: silence kept beyond the regulatory period can in some configurations be treated as an implied rejection that opens the court stage, but you should never rely on that without advice on the current text.

If the CRA rejects the claim, or upholds only part of it, the dispute moves to the Tribunal judiciaire (the French civil court), social division, of your place of residence, again within a short time limit stated in the CRA’s decision letter — read that letter the day it arrives and calendar the deadline immediately. Representation by a lawyer is not compulsory at this stage but is strongly advisable where the sums are significant or where a point of legality, such as the yearly scale or the household test, is in play; the judgments quoted in the previous section show how strictly these cases are pleaded. Bring the complete chain: the original decision, the CRA claim with its proof of sending, the CRA decision, and the documents in indexed order. Ask the court registry about legal aid (aide juridictionnelle, the French means-tested funding of court cases) if the household budget is tight, and about the mediation service where the court offers one. Throughout, continue to meet the deadlines of parallel procedures: a residence-permit renewal, a tax return correction or an S1 registration each runs on its own clock, and winning the health dispute while losing the immigration status would be a hollow victory.

Conclusion

An inactive British early retiree is fully within the French health system after Brexit, but on French terms. Stable and regular residence opens PUMA membership; the absence of a United Kingdom State Pension normally means there is no S1 to register, and the EHIC or GHIC in the wallet covers holidays rather than residence. The same inactive profile that opens the door to PUMA can trigger the yearly CSM bill, computed on capital income at the regulatory rate for the exact year assessed, couple-tested and recovered the following year by the URSSAF. The case law upholds the mechanism while policing its arithmetic, so the winning posture is methodical rather than defiant: prove residence with dated French evidence, register any S1 the year it arises, reconcile every CSM notice with the tax assessment for that year, and challenge refusals and bills through the CRA within two months with a documented file. Handled that way, the two frightening letters become two manageable procedures, and the early retirement in France can proceed on the calm footing it was meant to have.

Need a quick opinion on your case.

If you have received a CPAM refusal or a CSM assessment and the two-month deadline is running, arrange a telephone consultation within 48 hours with a lawyer of the firm. Call +33 6 46 60 58 22 or write via our contact page with a copy of the decision letter and your latest French tax assessment, and you will receive a clear view on your residence evidence, your S1 position and the exact correction or challenge to file.

Source : Cour de cassation – Base Open Data « Judilibre » & « Légifrance ».

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Thank you to Maître KOHEN for his analyses of recent case law regarding fraudulent concealment in real estate sales. This reinforces my decision to pursue an action for rescission that I am considering after acquiring a house affected by serious defects intentionally concealed by the seller and not reported by the real estate agent; also defects (rising damp) characterized by progressive through-cracks and damp patches, not reported by the real estate agent… Worse, defects concealed by the latter or on his initiative under a coat of paint and polystyrene tiles glued to the ceiling of a bedroom. And said real estate agent was the drafter of the preliminary contract, which naturally contains no information regarding any of these defects. I would just add that, being 77 years old and suffering from cognitive impairment, I am certain the real estate agent thought I would not be able to uncover the deception and, above all, characterize fraudulent intent, let alone initiate legal proceedings given the complexity and length of the process... That is why I am opting for criminal proceedings, insofar as the intentional concealment of defects by the seller and then by the real estate agent

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Paul MALIK (powlo)
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Maître Reda KOHEN assisted me in a dispute concerning a sale agreement with a defaulting party. He provided professional and responsive support, and I highly recommend him.

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The return of the security deposit is a more common rental dispute than one might think; glad that the situation was resolved quickly. Thank you for this feedback.

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5 months ago

Excellent support from Maître Kohen in a case combining business law and real estate law. Clear legal analysis from the first meeting, right through to the hearing. Professional and accessible lawyer, I highly recommend his firm in Paris 17.

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Cases at the intersection of business law and real estate law require a comprehensive overview — that's the core of the firm's practice, from the initial meeting to the hearing. Thank you for this precise recommendation.

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Collecting unpaid rent requires a procedure handled from start to finish, without downtime — glad to have seen yours through to completion. Thank you for this testimonial.

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5 months ago

As a young student living in an apartment, my landlord tried to make me leave my accommodation even though he had sent me no termination notice. I therefore contacted Mr. Reda Kohen to help me as I couldn’t handle the situation alone. In just 3 days everything was resolved, Maître Kohen defended me and accompanied me with an irreproachable level of commitment and efficiency. I can only recommend his professionalism!

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Thank you very much, Miss Maazaz, for this feedback. Analytical rigor and responsiveness are essential commitments of our law firm specializing in real estate law in Paris, where each case requires a tailored approach. Delighted that we were able to achieve a favorable outcome. The firm remains at your disposal. Best regards.