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Can I claim both US and UK state pensions? Understanding dual pension eligibility

3 min read

According to the Social Security Administration, the U.S. and U.K. have a Totalization Agreement in place that helps people who have worked in both countries claim their social security benefits. This means that for those who have paid into both systems, the answer to the question, "Can I claim both US and UK state pensions?" is generally yes, but the process involves understanding specific rules regarding eligibility and credit accumulation.

Quick Summary

Individuals who have worked in both the U.S. and the U.K. can be eligible for state pensions from both countries due to a Totalization Agreement. Claimants may use credits from both nations to qualify for a benefit if they lack enough in one system. The 2025 Social Security Fairness Act eliminated a past penalty affecting US benefits for those also receiving a UK pension. Tax implications vary based on residency.

Key Points

  • Claiming Both Pensions: You can claim both the US and UK state pensions due to a Totalization Agreement between the two countries.

  • Totalization Agreement: This international pact allows you to use work credits from one country to qualify for a pension in the other if you lack enough credits in a single country. {Link: Social Security website https://www.ssa.gov/international/Agreement_Pamphlets/uk.html} provides detailed information

  • End of WEP: The recent Social Security Fairness Act eliminated the Windfall Elimination Provision (WEP), which previously reduced US benefits for individuals receiving a UK pension.

  • Pro-Rata Payouts: The pension amount you receive from each country is calculated based on the contributions paid within that specific country, not a combined total.

  • Where to Apply: You can apply for benefits from one or both countries at the social security office in the country where you currently live.

  • Tax Implications: Your residency determines how your pensions are taxed, with a tax treaty helping to prevent double taxation, though professional tax advice is recommended.

  • Eligibility Requirements: Meeting the minimum work requirements (10 years for US and UK) is crucial, though the Totalization Agreement can bridge small gaps.

In This Article

Can you claim both a US and UK state pension?

Yes, it is possible to claim both a US Social Security pension and a UK State Pension if you have worked in both countries. This is facilitated by a Social Security agreement between the two nations.

The US-UK Totalization Agreement

The Totalization Agreement between the U.S. and the U.K., in effect since 1985, helps prevent double taxation and allows individuals to combine work credits from both countries to meet minimum benefit eligibility requirements.

Eligibility for US Social Security and UK State Pension

Eligibility requires meeting each system's criteria, though the Totalization Agreement can help if you are short on credits. The US generally requires 40 credits for a full benefit (up to four per year), while the UK requires 10 qualifying years of National Insurance contributions for any pension and 35 years for the full amount. The agreement allows using credits from one country to help qualify in the other if minimums are not met.

The end of the Windfall Elimination Provision (WEP)

A significant change is the repeal of the Windfall Elimination Provision (WEP) by the Social Security Fairness Act, signed into law on January 5, 2025. This eliminates a previous reduction in US benefits for those receiving a UK State Pension, allowing affected individuals to potentially receive full benefits from both systems. Processing these adjustments may take time.

How to claim your benefits

The Totalization Agreement allows for coordinated filing. If you live in the United States, applications can be made at any U.S. Social Security office, and you can apply for your UK pension using form SSA-2490-BK there. If you live in the United Kingdom, contact the Federal Benefits Unit at the U.S. Embassy in London for US applications and any UK social security office for your UK pension. More details can be found on {Link: Social Security website https://www.ssa.gov/international/Agreement_Pamphlets/uk.html}.

Comparison of US Social Security and UK State Pension

Feature US Social Security UK State Pension (New State Pension)
Minimum Eligibility 10 years (40 credits) 10 qualifying years of NI contributions
Full Benefit Eligibility Based on 35 years of highest indexed earnings 35 qualifying years of NI contributions
Retirement Age Full Retirement Age (FRA) is 67 for those born in 1960 or later, with early retirement at 62 at a reduced rate. State Pension age is gradually rising to 67, with options for deferral for higher payouts.
Payment while Abroad Generally payable to US citizens and some non-citizens living in the UK. Payable to individuals living overseas.
Taxation Can be taxable in the US depending on income. Not usually subject to UK tax if a non-resident, but may be taxable in the country of residence.
Benefit Calculation Based on 35 years of average indexed monthly earnings. Based on NI contribution history.

Taxation of international pensions

Taxation depends on your residency and the US-UK tax treaty. Generally, the country of residence taxes the pension, with the treaty preventing double taxation. Consulting a cross-border tax specialist is recommended due to complex international tax rules.

Conclusion

Claiming both US Social Security and UK State Pensions is possible due to the Totalization Agreement, which allows combining work credits for eligibility. The repeal of WEP means US benefits will not be reduced by receiving a UK pension. Applications can typically be made in your country of residence. Taxation is complex and governed by treaty, making professional tax advice advisable. {Link: Social Security website https://www.ssa.gov/international/Agreement_Pamphlets/uk.html} provides further details.

Frequently Asked Questions

No, it does not. While you can claim both, you must meet the individual eligibility criteria for each pension system. The Totalization Agreement helps if you do not have enough work credits in one country by allowing you to count credits from the other.

To be eligible for the new UK State Pension, you generally need 10 years of National Insurance (NI) contributions. For the maximum amount, you need 35 qualifying years.

No, it will not. The Windfall Elimination Provision (WEP), which used to reduce US benefits for those receiving a UK pension, was repealed by the Social Security Fairness Act of 2025. This means you can now receive your full entitlement from both.

Yes, you can claim and receive a UK State Pension while living overseas. The UK government can pay your pension directly into an overseas bank account.

You can apply for both pensions through the social security office of the country where you live. For example, if you live in the US, you can apply for your UK pension at any US Social Security office.

Each country calculates its own benefit separately, based on your contributions to its respective system. The Totalization Agreement allows the combining of work periods for eligibility, but not for the calculation of the benefit amount.

Taxation depends on your country of residence and is governed by the US-UK tax treaty. Your pensions may be taxable in the country you reside in, and the treaty helps prevent double taxation. Consulting a tax specialist is recommended.

References

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Medical Disclaimer

This content is for informational purposes only and should not replace professional medical advice. Always consult a qualified healthcare provider regarding personal health decisions.