Moving from Britain to France after Brexit does not leave a British citizen without a route to French healthcare simply because there is no UK-issued S1. An S1 is the certificate that identifies the state responsible for the cost of a resident’s healthcare. It is essential for some pensioners, posted workers and other cross-border situations, but it is not the only possible legal basis. A person who is not covered by the United Kingdom and who works or resides in France may instead need French affiliation under PUMa, the protection universelle maladie (France’s universal health-protection scheme).

The difficult cases are practical as well as legal. A Caisse primaire d’assurance maladie (CPAM, the local French primary health-insurance fund) may treat a resident as a visitor, ask for evidence that was already supplied, reject an application because the residence period is unclear, or open French rights while another authority is still responsible under an S1. A new issue also matters in 2026: French law now provides for a participation by certain non-working residents covered through residence, while the implementation details are still awaiting a decree. This guide explains the route, the evidence, the CPAM appeal and the separate contribution questions for a British reader settling in France.

I. Can a British citizen without an S1 use PUMa in France after Brexit?

A. Is PUMa available after Brexit, and what do the three-month and six-month residence rules mean?

Start with the competent state, not with the form. The United Kingdom, France or another state may be responsible for the cost of healthcare even though treatment is delivered in France. A British national who was already lawfully living in France before 31 December 2020 may fall within the EU–UK Withdrawal Agreement. A person who moved from 1 January 2021 is normally considered under the later EU–UK Trade and Cooperation Agreement and French domestic rules. The dates, residence status, work, pension and benefits must be recorded before deciding whether the file is an S1 registration or a PUMa application.

The French government’s official PUMa guidance separates the residence-based healthcare route from the question of which state remains financially responsible under an international arrangement. A British pensioner whose healthcare is funded by the United Kingdom should request an S1 from the British authority and register it with the French fund. A British national installing in France from 1 January 2021 must also hold a residence document as a third-country national. That immigration document is not, by itself, proof that the United Kingdom remains financially responsible for healthcare.

The UK side uses the same distinction. GOV.UK guidance on healthcare for UK nationals living in France identifies French social-security contributions, a registered S1 and PUMa as different routes. It says that a person can apply to the French system after being resident in France for at least three months, and that a person who is not employed may have to contribute to PUMa. A GHIC, the Global Health Insurance Card, and an EHIC, the European Health Insurance Card, are principally temporary-stay documents. They should not be presented as a substitute for ordinary resident registration after France has become the household’s usual home.

PUMa is a legal framework, not a private insurance policy. The central rule is in Article L. 160-1 of the French Social Security Code. The text begins: « Toute personne travaillant ou, lorsqu’elle n’exerce pas d’activité professionnelle, résidant en France de manière stable et régulière bénéficie […] de la prise en charge de ses frais de santé ». In English, a person who works in France, or who does not work but resides there in a stable and regular manner, falls within the statutory healthcare cover, subject to the rest of the Code and applicable international instruments. Nationality alone neither grants nor removes the right.

For a person who is not already covered by another compulsory scheme, Article L. 160-5 is the more specific entry point. It states that a person who declares to a CPAM that he or she does not receive the healthcare cover referred to in Article L. 160-1 benefits from that cover once identity and stable, regular residence are proved. Its wording includes: « dès qu’elle justifie de son identité et de sa résidence stable et régulière ». The application is therefore evidence-led. It is not a promise that a GHIC, a French tax number or a private policy will automatically produce a French social-security number.

“Stable and regular residence” contains two separate ideas. Stable residence is about where the person actually lives and for how long. Regular residence is about the immigration or legal document that allows the person to remain in France, unless a specific international route changes the analysis. Article R. 111-3 of the Social Security Code refers to people who are French nationals or are « en situation régulière au regard de la législation sur le séjour des étrangers en France », and excludes a person who is already covered by another state under European rules or an international convention. For a British citizen arriving after Brexit, a valid visa or residence permit and the absence of another responsible foreign scheme must be addressed expressly.

The ordinary residence evidence for a non-working applicant is more than a single recent bill. Article D. 160-2 says: « Les personnes qui demandent à bénéficier de la prise en charge des frais de santé en application des dispositions de l’article L. 160-5 doivent produire un justificatif démontrant qu’elles résident en France de manière ininterrompue depuis plus de trois mois ». The rule has exceptions for listed categories, including certain family members and students. A worker can have an immediate activity-based route, whereas a person with no French work must normally prove the three-month residence period before rights are opened on the residence basis.

There is also an ongoing presence test. The current public guidance explains that a non-working resident must live in France for at least six months of the year for the rights to remain open. This should not be confused with a crude “183-day rule” borrowed from tax law. The CPAM is looking at the social-security residence conditions and the relevant evidence. Travel to Britain does not automatically destroy French residence, but repeated or lengthy absences should be recorded and explained. A dated calendar, travel records, French household bills and evidence of ordinary life are more reliable than an assertion that France is the main home.

The Service-Public page on PUMa, verified on 13 May 2026, confirms that the regularity and stability conditions are cumulative. It also explains that a working applicant can be affiliated immediately when the application is accepted, while a non-working applicant normally waits three months in France. The same page now carries a warning about a new financial participation for certain non-working PUMa beneficiaries. That 2026 change must be kept separate from the older CSM, or cotisation subsidiaire maladie, which is a separate sickness contribution calculated by URSSAF in particular income situations.

Article L. 160-1-1, inserted by the 2026 Social Security Code provision, applies subject to international agreements and European rules. It covers a person who resides in France in a stable and regular manner, does not work in France and is not already liable for specified French social contributions under an international convention. The text makes healthcare conditional on « une participation financière » and says that non-payment can lead, after verification and notification, to suspension of healthcare rights. The implementing decree must determine the amount, notification and collection rules. When the official Service-Public page was checked for this article, it still stated that the decree setting the amount was awaited. Do not invent a figure or treat a future bill as though the amount had already been published.

This new provision is particularly relevant to a British resident without an S1, but it does not mean that every British resident will receive the same bill. A pensioner with a valid UK S1 may be in a treaty-coordination situation rather than the domestic residence-only category. A French employee usually contributes through employment. A person with French or foreign pension income may have a different social-contribution position. The words “without an S1” must therefore be accompanied by a careful statement of work, pension, benefits, residence date and other healthcare cover.

A British citizen can also move from one route to another. A person may arrive with private insurance, begin French employment, later stop working, then claim a UK State Pension and become eligible for an S1. A spouse may have an S1 while the other spouse has a French activity or residence-based entitlement. A child may have a separate status. PUMa should not be used as a label for the whole household without listing the legal basis for each person.

For the S1 route itself, see the British desk’s guide to registering an S1 and challenging a CPAM refusal. The present article addresses the gap that guide cannot resolve: the British resident who has no operative S1 route and must prove a French PUMa basis, or who has been wrongly placed in the PUMa category while the United Kingdom remains responsible.

B. Which documents prove lawful, stable and regular residence for CPAM?

Build the file around five questions: who is the applicant, what is the legal route, when did the route begin, where has the applicant actually lived, and which other state or scheme could be responsible? Put the answers on the first page, then number the supporting documents. A CPAM officer should be able to see the applicant’s status without reconstructing the move from a pile of unrelated scans.

For a PUMa request, start with the current S1106, the French form used to request opening of healthcare rights. The Ameli explanation of PUMa, updated in January 2026, directs applicants to complete the form and send it with the evidence requested for their personal situation. The form should be sent to the CPAM for the place of residence. Keep a complete copy of the signed form and every attachment. If the CPAM provides a local checklist, retain that checklist as well.

Identity evidence normally begins with the British passport. Add civil-status documents where the name differs between the passport, residence document, French tax record, employment record or bank account. If a person has married, changed a middle name or uses an abbreviated name in Britain, explain the connection rather than leaving the CPAM to assume that two records belong to different people. A certified translation may be needed for a marriage, birth or divorce document. Keep the English original beside the translation and do not translate a legal status into a broader expression.

Regular residence evidence for a British citizen who moved after Brexit normally includes the relevant visa, residence permit or other document accepted by the immigration rules. A titre de séjour means a French residence document; it answers the question whether the person may remain in France, not the separate question of which state pays for healthcare. A person protected by the Withdrawal Agreement should provide the document and dates supporting that status. A person who arrived later should state the category of visa or permit, the date of entry and the date the French home became the ordinary residence.

Stable-residence evidence should cover the relevant period. A lease, home-insurance certificate, utility bills, local tax correspondence, French bank activity showing ordinary expenditure, school or family documents, medical appointments, a French employment record and consistent travel records can all help. The weight of each item depends on the circumstances. A property deed alone does not prove that the owner lives in the property, just as a single electricity bill does not prove three months of continuous residence. Explain gaps, hosted accommodation and periods spent in Britain in a short chronology.

A person who is employed in France should add the employment contract, employer certificate, first payslip and evidence of the start date. A self-employed person should add registration and evidence of the activity. The activity route can be different from the residence route, so the letter should say which one is being relied upon. A person who works for a UK employer from France should not assume that the UK contract decides the social-security position. That situation can involve payroll, posting, the Trade and Cooperation Agreement and a possible French affiliation analysis.

A person who is retired or receives a UK benefit should request a written decision from the UK authority on S1 eligibility before claiming that no foreign scheme applies. The award letter, benefit category, payment statement and correspondence about the S1 should be included. If the UK authority refuses an S1, attach the refusal and explain why French residence-based cover is being requested instead. If an S1 has been issued but not registered, do not file a PUMa application as though the S1 did not exist; ask the CPAM to register or correct the certificate and preserve the two routes as alternatives only if the facts justify that approach.

For each adult and child, prepare a separate status sheet. State nationality, date of birth, date of arrival, residence document, work or pension status, S1 position, private cover and the requested effective date. A spouse’s S1 does not automatically settle the other spouse’s French status. A child may be a dependant under one system but a separate insured person under French rules. The CPAM needs a clear family map, especially where surnames, addresses or dates differ.

Submit the file in a traceable way. If the CPAM directs the applicant to an online account, keep the upload confirmation, date, file names and screenshots. If it requests post, use delivery evidence and retain the receipt. If documents are handed over in person, request a dated acknowledgement. A telephone conversation can be useful for identifying a missing page, but it should be confirmed in writing. Ask for the application reference and for a written list of any remaining documents.

When a CPAM asks for evidence of residence or regular stay during a control, do not ignore the letter because the applicant already holds a social-security number. Article R. 114-10-1 of the Social Security Code provides that, after a control reveals a possible failure of the conditions or insufficient evidence, the person is notified that he or she has one month to produce documents and make observations: « il dispose d’un délai d’un mois […] pour produire tout document attestant du respect de la stabilité de la résidence et de la régularité du séjour et présenter des observations ». The practical deadline is usually described as 30 days. Reply before it expires, even if some evidence is still being requested from another authority.

The same control provision requires the decision to identify the checks, the date from which the conditions were no longer established, the date of closure and the available remedies. In some situations, the card cannot be invalidated before a 45-day period after the notification. The exact consequences depend on whether the problem concerns stable residence, regular stay or another condition. Read the notice rather than relying on a general internet summary. If the CPAM demands repayment of costs, request the calculation, dates and legal basis at once.

Before the French health card arrives, ask how the applicant will receive an attestation de droits, the certificate confirming healthcare entitlement and the French social-security number. A carte Vitale is the French health-insurance card used by providers. A feuille de soins is the paper treatment form used in some reimbursement situations. A mutuelle is supplementary private health insurance that may cover part of the patient contribution left after the state scheme. These documents and terms should not be treated as interchangeable. A temporary number, a certificate, a card and a private policy each prove a different thing.

The current GOV.UK guidance warns that a carte Vitale can take six months or more and says that a person may need to use the social-security number and submit a feuille de soins while waiting. It is sensible to keep private cover for the interim period where the visa, policy or medical risk makes that necessary. Keep invoices and prescriptions, and ask the provider for a clear statement of what was paid. A future PUMa affiliation does not automatically guarantee reimbursement of every earlier bill.

Finally, prepare the evidence in English and French where necessary, but write the legal explanation in one consistent voice. Identify “stable and regular residence”, “French employment”, “UK-funded healthcare” and “no other compulsory scheme” as separate propositions. A letter saying only “I live in France and pay French taxes” leaves the CPAM to guess which rule is being invoked. A letter that cites the route, date, document and requested decision creates a record that can later support a CRA appeal.

II. What can you do if CPAM refuses PUMa or URSSAF sends a contribution notice?

A. How do you challenge a CPAM refusal, closure or delay?

First identify whether there is a formal decision. A CPAM may send a refusal, a request for further documents, a closure notice, a provisional number, an S1 mismatch message or no answer at all. A telephone agent’s statement that the computer has rejected the application is not a sufficient substitute for the written decision, its reasons, the date of notification and the appeal instructions. Ask for those items in writing and preserve the envelope, email or online notification. The date can decide whether an appeal is in time.

Common errors can be corrected only if they are named. The CPAM may have treated a resident as a short-term visitor relying on a GHIC, treated a UK pensioner as a PUMa applicant when an S1 should govern, counted the three-month period from the wrong date, overlooked a valid residence document, or failed to link a corrected S1 to the French file. The appeal should answer the actual reason, not repeat that the applicant is British. Nationality, tax residence, immigration status and healthcare responsibility are related facts but different legal tests.

For a non-medical decision about affiliation or healthcare rights, the preliminary remedy is the commission de recours amiable (CRA, the amicable-appeal commission within the social-security body). Article L. 142-4 states: « Les recours contentieux formés […] sont précédés d’un recours préalable ». That preliminary appeal is not an optional complaint to customer services. It is the procedural step that normally must precede a court claim for matters within the provision.

Article R. 142-1 gives the CRA rule and says: « Cette commission doit être saisie dans le délai de deux mois à compter de la notification de la décision ». Treat two months as a hard deadline. Send the appeal through a method that proves receipt, address it to the CRA of the correct body and label it clearly as a recours préalable. A message to a general CPAM mailbox may not be recognised as a timely CRA appeal unless the authority can identify its nature and date.

The appeal should include the decision, the application, delivery proof, all material identity and residence evidence, the S1 or UK refusal if relevant, the family status documents, the chronology and the remedy sought. Ask for a specific result: registration of the S1, correction of the affiliation basis, opening of PUMa rights, recognition of the correct effective date, issue of an attestation de droits, or a written identification of the missing document. If the CPAM has closed rights, ask for the closure date, the calculation of any recovery and the continuation or restoration of care pending the dispute.

Use the statutory route that matches the facts. If the person has no foreign cover, explain why Article L. 160-5 applies and prove identity and stable, regular residence. If the person is working, explain the employment start date. If the person is a pensioner, explain why the United Kingdom is or is not competent and attach the S1 decision. If the person is protected by the Withdrawal Agreement, identify the acquired-rights status. A long list of provisions unrelated to the person’s status can weaken the point; three accurate provisions and a complete record are more useful.

Silence is not neutral. Article R. 142-6 provides: « Lorsque la décision […] n’a pas été portée à la connaissance du requérant dans le délai de deux mois, l’intéressé peut considérer sa demande comme rejetée ». The starting date can depend on receipt of the appeal and, where documents are supplied later, the date those documents are received. Keep the delivery record and proof of any later upload. If two months pass, ask for a written status but also obtain advice on the next court step instead of waiting indefinitely for an informal answer.

The Court of Cassation has addressed PUMa affiliation in Second Civil Chamber, 3 June 2021, no. 20-10.687. The decision refers to provisions that apply « sans distinction de nationalité » to a person without professional activity who can satisfy the healthcare conditions. That case concerned different facts and an earlier legal context; it does not create a blanket post-Brexit entitlement for every British visitor. It is nevertheless a useful reminder that the administration and court must examine the statutory residence and coverage conditions rather than substitute nationality for analysis.

A closure notice is a different emergency. Under Article R. 114-10-1, a person who receives a control request should answer within the stated one-month period with residence and regular-stay evidence and observations. If the person has moved out of France, the correct response is not to manufacture evidence; it is to explain the date of departure and the final treatment claims. If the person remains in France, provide the six-month presence evidence and the residence documents that cover the period examined. If the closure is wrong, challenge it within the notification’s route and deadline.

If a decision includes a medical assessment, read its remedy carefully. An administrative affiliation dispute and a medical dispute can have different preliminary bodies. Do not send a generic CRA letter that ignores a medical appeal instruction. If the refusal combines both elements, separate the facts and request the full administrative record. A social-security court claim should identify the decision, the applicable route, the evidence and the exact relief sought; it should not merely say that a carte Vitale has not arrived.

Keep treatment continuity separate from the legal appeal. A pending CRA appeal does not automatically make private cover unnecessary and does not necessarily guarantee payment of treatment received before the effective date. Tell the provider that the French registration is pending, show the S1 or application reference, obtain itemised invoices and retain prescriptions. Contact the UK Overseas Healthcare Services if the issue is an S1 transmission or replacement. An urgent medical need may require the hospital’s social service or a payment arrangement while the legal file is being decided.

B. How do you check the 2026 PUMa participation and the CSM?

Separate three questions: the right to healthcare, the new 2026 participation under Article L. 160-1-1, and the older CSM assessed through URSSAF. The existence of a French health-insurance right does not, by itself, prove that a particular contribution is due. Conversely, a contribution notice does not prove that the CPAM correctly chose the French route. Check the responsible state, the period, the household status, the income and the international agreement before accepting the calculation.

The CSM is the cotisation subsidiaire maladie, a supplementary sickness contribution collected by URSSAF, the French body responsible for collecting many social contributions. Article L. 380-2 of the Social Security Code targets people within Article L. 160-1 who have low French professional income, have not received specified replacement income such as a pension or unemployment allowance, and have income from property, investments or certain non-professional activities. The assessment uses the legal categories and household facts, not just the balance of a British bank account.

The calculation is not a simple percentage of every asset. Article D. 380-1 states the formula: « Montant de la cotisation = 6,5 % × (A-0,5 × PASS) × [1-R/ (0,2 × PASS)] ». Here, PASS is the annual French social-security ceiling, A is the defined income base subject to the statutory cap, and R is the professional-income amount used by the rule. The thresholds and ceiling can change. A calculation should therefore identify the tax year and the applicable PASS rather than copy an old internet example.

Some British residents wrongly receive a CSM notice because the file does not reflect a pension, an S1, French employment or a convention-based exemption. Others receive a notice because the French tax administration transmitted income data and URSSAF applied the statutory formula. Ask URSSAF for the source data, the income categories, the household allocation, the professional-income figure, the period covered and the exemption analysis. If the person is married or in a PACS, explain that a pacte civil de solidarité is the French civil partnership and provide the joint-tax evidence used for the allocation.

The timing of the call matters. Article R. 380-4 says that the CSM is called no later than the last working day of November in the year following the year for which it is due and is payable within 30 days of the call: « La cotisation mentionnée à l’article L. 380-2 est appelée au plus tard le dernier jour ouvré du mois de novembre de l’année suivant celle au titre de laquelle elle est due. Elle est exigible dans les trente jours ». The same provision allows the insured person to communicate probative evidence when the notice does not accurately reflect the situation.

The Court of Cassation, Second Civil Chamber, 28 January 2021, no. 19-25.853, examined a CSM call for 2016 and stated that the call had to occur before the statutory November deadline. The case is a warning to check the date and the version of the rules, not a licence to ignore a current notice. Later decisions have addressed different effects of late calling, recovery and information. A British resident should identify the exact tax year, date printed on the call, date of receipt and legal provision before relying on the case.

Substantive objections also need proof. The Court of Cassation, Second Civil Chamber, 27 February 2025, no. 22-17.970, considered the CSM’s income base and held, in the relevant reasoning, that the contribution is « la contrepartie légale du bénéfice des prestations en nature » served under Article L. 160-1. The decision also examined data transmission and the proportionality of the contribution. It does not mean every notice is correct. It means that an appeal should attack the applicable conditions, the data, the calculation, the exemption or the procedure with evidence.

The CSM appeal should begin with a written request to URSSAF through the dedicated account or the channel named on the notice. Ask for correction and attach the UK pension decision, S1, French payslips, unemployment evidence, tax return, foreign-income statements, household information and proof of any treaty-based healthcare responsibility. If the first response confirms the assessment or a mise en demeure, meaning a formal demand to pay, the URSSAF guidance indicates a two-month route to the CRA. Article R. 142-1 also fixes a two-month period for the relevant preliminary social-security appeal.

Do not confuse a request for a payment plan with a challenge to liability. A payment plan can protect cash flow while the substantive question is reviewed, but it may not suspend every enforcement consequence. Ask in writing whether the collection continues, whether late increases apply and what evidence is required for a correction. If the notice is disputed, say so expressly and preserve the appeal deadline. If the amount is payable on the current record but the household needs time, request an instalment arrangement without abandoning the legal objection.

The new 2026 participation is different from the CSM. Article L. 160-1-1 applies to a person who has stable and regular residence, no French professional activity and no liability for the specified CSG, CRDS or healthcare contributions under an international convention. CSG means the generalised social contribution; CRDS means the contribution for repayment of the social debt. The law says the right to healthcare is conditional on paying a financial participation and that a director may notify the person of a future suspension after non-payment. The amount, notification and collection mechanism require the implementing decree.

As of the official Service-Public update checked for this article, that amount had not been fixed in the published guidance. A British resident should therefore keep the notice, identify whether it refers to Article L. 160-1-1 or to the CSM, and request the legal calculation before paying or challenging. A pensioner with an S1 or a person whose healthcare contributions are governed by a convention may fall outside the new participation, but the exception must be tested against the actual certificate and status. Do not assume that the word “PUMa” on a letter resolves that question.

A complete financial challenge has at least seven sections:

• the person’s French residence date, immigration status and work or pension position;
• the healthcare route used, including whether an S1 exists, was refused or remains unregistered;
• the period and date of the notice;
• the exact legal category of every income included;
• the income and household facts that should reduce or remove liability;
• the international agreement or foreign scheme that may change responsibility; and
• the requested correction, cancellation, recalculation or payment arrangement.

Keep the French and British sides aligned. If the UK authority changes the S1 decision, asks for a replacement certificate or confirms that it has no responsibility, send the written answer to the CPAM and URSSAF. If the French tax return is corrected, ask whether the social-contribution calculation will be amended automatically or whether a separate claim is required. If the person leaves France, report the departure and ask for the closing date of French rights. A health-insurance dispute can create repayment issues if the administration later decides that the conditions ended earlier than the applicant believed.

Recent official case material shows why dates and status matter. A court decision published through the Cour de cassation portal in Tribunal judiciaire de Lille, RG no. 25/01909, considered a refusal where the applicant’s residence and jobseeker status did not meet the applicable PUMa analysis at the relevant date. The judgment is not a British Brexit precedent, but it illustrates the risk of assuming that physical presence alone satisfies every condition. The British file must state the residence document, the person’s status and the applicable international route for the exact date in dispute.

The wider lesson is to appeal the administration’s reasoning, not a label. “PUMa refused” may conceal a residence problem, an immigration-document problem, a three-month timing problem, an S1 coordination problem or an income question. “CSM due” may conceal a missing pension exemption, a wrong income category, a household allocation error, a late call or a notice that does not distinguish the 2026 participation from the older contribution. Each error needs a different document and a different remedy.

Conclusion

A British citizen without an S1 may still obtain French healthcare through PUMa when the person works in France or proves stable and regular residence and is not already covered by another responsible scheme. The post-Brexit date matters: the Withdrawal Agreement protects a different group from the later Trade and Cooperation Agreement, and a residence document does not by itself determine healthcare responsibility. A GHIC or EHIC is normally a temporary-stay tool, not a substitute for resident registration.

The practical file should contain the S1106 application, identity and residence documents, the visa or residence status, a dated French-residence chronology, work or pension evidence, the S1 decision or proof that no foreign scheme applies, and traceable proof of submission. If CPAM refuses, closes or delays the application, request a written decision and use the CRA route within two months. If a contribution arrives, separate the 2026 participation under Article L. 160-1-1 from the CSM under Article L. 380-2, check the year and calculation, and preserve the relevant URSSAF appeal deadline.

A British resident should not wait for a missing card, a contradictory telephone answer or a large contribution notice to become a crisis. The strongest position comes from identifying the competent state, proving each date, keeping the British and French authorities aligned and asking for a precise written outcome. For the related S1 route, read the British desk’s S1 and CPAM refusal guide.

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