Health Insurance Hungary

Prior to Brexit (and after, if we have an EU spouse), the Directive which applied is the Directive for EU citizens and their family members.

After Brexit (and after 5 years in a particular EU country) the Directive which applies (to us Brits) is the one I gave above for "third-country nationals" (non-EU citizens).

...- @gwynj

The EU Blue Card is a whole other thing for skilled (and highly paid) migrants from non-EU countries. (But you have to have a job offer/employment contract, and there's a specified minimum salary to qualify.) No connection at all to Brexit (although a UK citizen who didn't get to the EU earlier could use this option now, if they qualify). There's no reason for a Brit with a long-term residence permit to apply for a Blue Card.

If you've only got the initial temporary (5 years) permit in Bulgaria, but now want to work in Germany, then you could choose to use the Blue Card route (subject to qualifying as above). But most would be better off continuing in Bulgaria until they get the PR, and then relocate to Germany on the easier EU citizen/long term residents basis (no job offer required, no minimum salary required).

As to getting back to the UK with one's spouse... on that I totally agree, it's a right pain the proverbial.

- @gwynj

@fluffy2560 and @Cynic

I get that EU Directives are long and boring, but all the info is there! :-)

The Withdrawal Agreement is about the UK's exit from the EU. It doesn't really modify EU directives/laws. There are some "residence rights" that the Agreement conferred to British passport holders who had already moved to an EU country before Brexit. But then you had to go through a process to have your EU country recognize your residence rights (perhaps with some proof you actually lived there), and to formalize such rights (by issuing a temporary residence permit, or, if you'd already been there more than 5 years, a long term residence permit).

Prior to Brexit (and after, if we have an EU spouse), the Directive which applied is the Directive for EU citizens and their family members.

After Brexit (and after 5 years in a particular EU country) the Directive which applies (to us Brits) is the one I gave above for "third-country nationals" (non-EU citizens).

This includes multiple references to "freedom of movement" and "equality of treatment" with EU citizens. So I'm not so sure why you're both so skeptical! :-)

Freedom of movement is not freedom of movement if you can't work. Of course, it would be possible that the EU specified (in this directive) that freedom of movement specifically excluded working. But it doesn't.

Specifically, under Article 11 Equal Treatment it says:

1. Long-term residents shall enjoy equal treatment with nationals as regards:
(a) access to employment and self-employed activity, provided such activities do not entail even occasional involvement in the exercise of public authority, and conditions of employment and working conditions, including conditions regarding dismissal and remuneration;
(b) education and vocational training, including study grants in accordance with national law;
(c) recognition of professional diplomas, certificates and other qualifications, in accordance with the relevant national procedures;
(d) social security, social assistance and social protection as defined by national law;

Which includes both employment and social security (as discussed elsewhere).

More importantly, there is a whole section devoted to what happens if you want to move from Hungary (in @fluffy2560's case), or Bulgaria (in mine), after you get your long-term residence permit. This is CHAPTER III - RESIDENCE IN THE OTHER MEMBER STATES.

You should like this one:

A long-term resident may reside in a second Member State on the following grounds:
(a) exercise of an economic activity in an employed or self-employed capacity;
(b) pursuit of studies or vocational training;
(c) other purposes.

And this includes the "Conditions for residence in a second Member State". Which are substantially the same as for EU citizens (in the other Directive), in that you should provide proof of funds/income, and proof of health insurance.

- @gwynj

The former (national) says that you get the national PR after only 3 years (and it has also been issued early for various reasons). The latter (EC) says after 5 years, but otherwise seems to have very similar requirements. The key issue would therefore seem to be what happens if Brits with national PRs apply for the EC PR. I don't know, I'm not there, and I didn't try it. But I'd love to know what happens if you do! :-) If you're saying that Hungary refuses to grant EC PRs to Brits, and hence locks us out of EU freedom of movement... well, that is indeed unfortunate, and rather sneaky. :-) If that's the case, then we would need a Plan B like the EU Blue Card (harder, I think) or Family Reunification as the partner of EU citizen (much easier, if you have such a partner). - @gwynj