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Since 20 June 2011 the UK Border Agency introduced new guidance which makes it mandatory for Bulgarians and Romanians to take out a ‘Comprehensive Sickness Insurance’ policy when applying for yellow card registration as a working student. But finding out what is actually meant by ‘comprehensive sickness insurance’ is proving more difficult than you would expect?

The new requirement was introduced as part of changes to the BR1 Yellow Card form and BR1 Guidance Note (version 06/2011) in June.

Comprehensive sickness insurance is actually a form of private medical cover offering policyholders treatment for serious illnesses in private hospitals normally outside of the NHS.

What is ‘comprehensive’ cover?

There is no standard wording for comprehensive sickness cover in the insurance world and you cannot simply ask for a comprehensive sickness policy.

Insurance companies are reluctant to claim that a particular policy is comprehensive as there are dozens of variations of cover, options, exclusions and plans on offer.

Many students have already been refused yellow card on the grounds that they have not provided ‘evidence’ that they have comprehensive sickness insurance in place.

In some cases the student had not provided original documents or the documentation from the insurance company did not specify the schedule of benefits in the 12 page letters sent to applicants. For example, AXA, does not issue a letter containing a schedule of benefits and told a Romanian student that the UK Border Agency caseworker should ‘refer to the attached booklet’.

Another Romanian student was refused because her top of the range Aviva policy contained a number of ‘exclusions’ or exemptions including ‘pre-existing conditions’ and ‘alcohol abuse’.

Insurance companies not sure what qualifies as comprehensive

Immigration Matters has talked to the UK Border Agency Bulgarian and Romanian helpline as well as several leading insurance companies, including Aviva, AXA and specialist brokers Active Quote, to try and clarify the situation so that Bulgarian and Romanian student know exactly what type of policy will give them the ‘comprehensive’ cover that is required for a yellow card.

The insurance companies are not much help as they claim they are not sure of what qualifies as comprehensive. Some policies offer hospital treatment only and would be considered as budget or low cost alternatives. The more expensive policies will cover the policyholder against a wider range of illnesses including those requiring out-patient treatments.

The UKBA helpdesk, Bulgarian and Romanian section, was not specific but said that comprehensive cover means you are covered against most eventualities including out patient treatment.  

In other words a budget policy is probably not going to be sufficient, although many applicants have no doubt managed to obtain a yellow card using such a policy. 

The Home Office Guidance for Bulgarian and Romanian section caseworkers (ANNEX A) states:

‘Assessing whether an EEA national who claims to be a student or self sufficient person holds Comprehensive Sickness Insurance  

A. Acceptable evidence of CSI  

  • From 20th June 2011 applications from EEA nationals applying for documentation confirming their right to reside in the UK as a student or self-sufficient person must show that they have one of the following forms of evidence in order to demonstrate comprehensive sickness insurance:  
  • A comprehensive insurance policy document confirming that the applicant has private medical insurance. A proportionate approach should be taken when considering what is ‘comprehensive’. For example, a policy may contain certain exemptions but if the applicant is covered by the policy for medical treatment in the majority of circumstances then this will be sufficient.’

In other words, exclusions are acceptable and caseworkers should be ‘proportionate’ or balanced in their decision making approach.

Tom Parker from Active Quote added that all health insurance policies have certain standard exclusions – self inflicted injury and pre-existing conditions – no matter how expensive the premiums.

The company, however, announced today that it will no longer be offering sickness policies to Bulgarians and Romanians due to high cancellation rates.

Applicants can go direct to insurers such as Aviva and AXA.

Whilst Bulgarian and Romanian EU member citizens have access to GP’s and NHS hospitals, the guidance notes stress that this does not qualify as comprehensive sickness cover.

‘The following forms of evidence remain unacceptable as evidence of comprehensive sickness insurance:

‘Cash back health schemes such as dental/optical/prescription charges.

‘Reliance on access to the UK’s National Health Service (NHS).

‘This does not constitute comprehensive sickness insurance for the purposes of the Regulations, including for students.’

Immigration Matters is often asked whether or not a European Health Insurance Card (EHIC) is sufficient proof o sickness cover. The guidance notes state that an EHIC is only acceptable for temporary stay in the UK:

‘For persons temporarily in the UK (e.g. less than one year), a valid European Health Insurance Card (EHIC). The EHIC is the replacement for the E111 form.

The revised BR1 form has caused some confusion as it does not make it clear that a student will need Comprehensive Sickness Insurance, as the actual question relates to those applying as ‘self sufficient’ EU applicants. However, the guidance does specify that insurance cover is required

No other students, for instance non-EU Tier 4 students, or Tier 2 migrantss have so far been asked to take out Comprehensive Sickness Insurance to work or study in the UK.

See also:

Health care workers needed in UK now

Immigration Rules for Bulgarian and Romanian nationals

If you need any immigration advice or help with Sponsorship or Work Permits, Visa, ILR/Settlement, Citizenship, dependant visa or an appeal against a refusal please email: or visit

Majestic College offer special packages for EU students. They also have a number of employers looking for staff right now and are willing to employ Bulgarians and Romanians.

For more information call Joanna on 0208 207 1020 or email

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