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UK and Portuguese Health Systems Compared: NHS vs SNS, the S1 Form and Private Cover for British Expats

An older couple with silver grey hair pulling two suitcases through the bright arrivals hall of an airport in southern Portugal, the man smiling and pointing towards the exit

20 min read

If you move from the UK to Portugal, you swap one public health service for another: the National Health Service (NHS) for the Serviço Nacional de Saúde (SNS). Both are funded by the state and open to residents, but the way in, the costs and the waiting times differ. And since Brexit, some rules depend on whether you are a British national or receive a UK pension.

This guide compares the UK and Portuguese health systems from the point of view of someone moving to Portugal. It explains what happens to your NHS entitlement, how the S1 form works for UK pensioners, what the GHIC and EHIC still cover, what you can expect when you visit the UK and when private health insurance in Portugal makes sense. It is based on the guidance of the NHS and the UK government, information from the Portuguese administration on gov.pt and publications of the Portuguese health regulator ERS.

Key points at a glance

  • The NHS is residence-based: If you move to Portugal permanently, you are no longer automatically entitled to free NHS treatment. In Portugal you use the SNS once you are registered as a resident.
  • S1 for UK pensioners: If you live in Portugal and receive a UK State Pension or certain other UK benefits, the UK may pay for your state healthcare in Portugal. You apply to NHS Overseas Healthcare Services and register the S1 with the Portuguese social security system.
  • Not if you also draw a Portuguese pension: Then Portugal is responsible for your healthcare, not the UK. If you instead receive pensions from several countries other than Portugal, the NHS says the country where you paid contributions longest is responsible.
  • GHIC only in certain cases: As a resident of Portugal you cannot use a UK-issued GHIC or EHIC unless you are, for example, a UK State Pensioner or frontier worker with a registered S1, a family member covered by their S1, or a UK student.
  • Visits to England: According to the NHS, people with a registered UK-issued S1 who live in the EU have been able to use the NHS like a UK resident when visiting England since 1 January 2024.
  • Private cover is optional: The S1 covers state healthcare only. Private health insurance in Portugal comes on top if you want to avoid waiting for specialists and planned operations.

The UK and Portuguese health systems compared

The NHS and the SNS follow the same idea: healthcare paid for by the state, open to everyone who lives in the country. In everyday life, however, you will notice differences, above all in costs, waiting times and language.

TopicNHS (UK)SNS (mainland Portugal)
Who is entitledPeople ordinarily resident in the UKLegal residents registered with the SNS, or people with a registered S1
OrganisationSeparate health services in England, Scotland, Wales and Northern IrelandOne national service; on Madeira and the Azores, regional services with their own rules
First point of contactGP practiceHealth centre (centro de saúde) with a family doctor (médico de família), if one is available
ChargesTreatment free at the point of use; in England, patients pay prescription charges, for exampleA user charge (taxa moderadora) only in hospital emergency departments, with exceptions; a share of the price for medicines
Waiting timesIn England, a legal right to start non-urgent consultant-led treatment within 18 weeks of referralLegal maximum of 120 days for a first specialist appointment and 180 days for surgery at normal priority; often exceeded for specialist appointments
LanguageEnglishMainly Portuguese

How the Portuguese system is organised, from the health centre to the local health units (ULS), is explained in detail in our guide Portugal’s healthcare system explained. This article focuses on what changes for you as someone coming from the UK.

90 daysbefore your move you can apply for an S1 if you already receive a UK State Pension
1 Jan 2024since then, S1 holders use the NHS like residents when visiting England
150 %of the national NHS rate if you have to pay for treatment as a visitor

What happens to your NHS entitlement when you move

The NHS is a residence-based system. According to the NHS guidance on planning your healthcare abroad, if you move abroad permanently you are no longer automatically entitled to medical treatment in the UK under normal NHS rules. The NHS asks you to tell your GP practice that you are moving so that you and your family can be removed from its register.

Being a British citizen does not change this. What counts is where you live. If you later return to live in the UK, you can use the NHS like any other resident again. According to the UK government, you then register with a GP using the GMS1 form and, the first time you are treated, bring at least two documents proving that you live in the UK again, such as a tenancy agreement, a council tax bill or a payslip.

Three ways into Portuguese state healthcare

According to the UK government’s guidance on healthcare in Portugal, UK nationals usually access the Portuguese system in one of three ways:

1
As a resident

Everyone registered as a resident can use the SNS on the same basis as a Portuguese citizen, whether employed, self-employed or not working. You register at your local health centre and receive a user number (número de utente).

2
With an S1 form

If you receive a UK State Pension or certain other UK benefits, the UK may pay for your state healthcare in Portugal. Frontier workers who live in Portugal and work in the UK, and workers posted to Portugal by a UK employer, can also be entitled to an S1.

3
With a UK GHIC or EHIC

Only for temporary stays, for example for students on a study period in Portugal or for posted workers. The card does not replace registration if you live in Portugal.

Whichever way applies to you, registration in Portugal comes first. Your ID document, your Portuguese tax number (NIF), your address and a valid residence document must be on record with your user number, otherwise the SNS will, as a rule, not cover the costs (gov.pt, guide for migrants). If you are employed or self-employed, the UK government also mentions your social security number (NISS). According to its 2021 guidance, you must show proof of healthcare cover for a residence visa and for registering as a resident; what counts is what the Portuguese consulate or the local authorities require. Its current guide Living in Portugal says you do not need private health insurance, but you do need to register for state healthcare. For urgent health problems, the SNS 24 health line on the mainland is available around the clock on 808 24 24 24; in an emergency, call 112.

A man in his sixties handing his ID document and a form across the reception desk of a health centre in Portugal
At the health centre you register with your S1 or residence document and receive your user number.

The S1 form for UK pensioners, step by step

The S1 is the most important document for many British retirees in Portugal. According to the NHS, it entitles you and your dependants to state healthcare in the country where you live, paid for by the UK, on the same basis as an insured resident of that country.

Who can get an S1. You must be lawfully resident in Portugal (or another EU country, Iceland, Liechtenstein, Norway or Switzerland) and meet one of these conditions:

  • You receive a UK State Pension.
  • You receive an exportable UK benefit that entitles you to an S1, according to the NHS: contribution-based Employment and Support Allowance, Maternity Allowance, or Widow’s Benefit or Widowed Parent’s Allowance.
  • You are a posted or frontier worker recognised by HMRC, or a UK civil servant working in the EU; you then apply to HMRC for the S1.
  • You receive the unemployability supplement of a UK war pension.

Disability Living Allowance, Personal Independence Payment, Carer’s Allowance and Attendance Allowance only still give you an S1 if you received it on that basis before 1 January 2021, and only for as long as you keep receiving the benefit.

When the UK is not responsible. If you receive both a Portuguese state pension and a UK State Pension, you cannot get a UK S1, because Portugal is then responsible for your healthcare. If you receive pensions from several countries other than Portugal, the NHS says the country where you paid contributions for the longest period is responsible.

How to apply and register:

  1. Apply in good time. If you already receive a UK State Pension, you can apply to NHS Overseas Healthcare Services up to 90 days before your planned move, by phone on +44 191 218 1999 (Monday to Friday, 8am to 6pm) or by email to [email protected]. The S1 starts on the date you move. If you do not receive your pension yet, wait until it is paid.
  2. Give an address in Portugal. A temporary address is accepted, but you must report any change. The S1 is sent by email with a download link, otherwise by post.
  3. Register the S1 with social security. Take the S1, your passport and your residence certificate to a social security office (Segurança Social); you may also need your NIF.
  4. Register at the health centre. You then register the S1 at your local health centre and receive your user number. It shows that you are entitled to state healthcare on the same basis as a Portuguese citizen.

Cover while you wait. The NHS points out that it is your responsibility to have appropriate cover until the S1 is registered; without it, you may be charged for treatment. If registration is delayed and you need urgent treatment, the UK government advises you to contact Overseas Healthcare Services.

Partners and dependants. You can add dependants to your application. Whether Portugal accepts them depends on how Portugal defines a dependant; someone who works in Portugal or receives a pension from another country may not qualify. If your partner is covered as your dependant and later starts drawing their own UK State Pension, their dependant cover ends and they receive their own S1, which they must register again.

What else pensioners should consider for health cover in Portugal, from age limits to premiums, is explained in our guide Health insurance in Portugal over 60 and 70.

GHIC and EHIC: what you can still use

The UK Global Health Insurance Card (GHIC) has replaced the UK-issued European Health Insurance Card (EHIC) for most people. It gives you access to medically necessary state healthcare during a temporary visit, on the same basis as a local resident. According to the NHS, it does not cover treatment in private facilities, medical repatriation or mountain rescue.

Once you live in Portugal, a different rule applies. According to the UK government’s guide Living in Portugal, you cannot use or renew a UK-issued GHIC or EHIC as a resident unless you are, for example:

  • a UK student in Portugal,
  • a UK State Pensioner with a registered S1,
  • a frontier worker with a registered S1, or
  • a family member covered by such an S1.

With a registered S1, you receive a UK-issued GHIC or EHIC for temporary visits to other countries where it is valid. If you are registered with the SNS and social security as a resident without an S1, you may be entitled to a Portuguese EHIC for travel, according to the UK government also for visits to the UK. Using a card you are not entitled to can mean paying the full cost of treatment. How the European card works when travelling is explained in our guide to the European Health Insurance Card.

Moved before or after 1 January 2021

The end of the Brexit transition period still matters for British nationals in Portugal, because some rights depend on when you moved.

  • Residence: If you moved to Portugal before 1 January 2021 and have lived there legally since then, you and your family have rights under the Withdrawal Agreement. According to the UK government, you should have a Withdrawal Agreement residence permit; if you do not, it says you must get one now by emailing the Portuguese migration agency AIMA at [email protected] with proof of your time in Portugal.
  • EHIC instead of GHIC: If you have lived in the EU since before 1 January 2021 with a registered UK-issued S1, the NHS says you can choose a new UK EHIC instead of a GHIC.
  • Moving now: If you move after that date, the UK government says you enter Portugal on a residence visa and then apply for a residence card. According to its 2021 guidance on healthcare in Portugal, you must show proof of healthcare cover for the visa and for registering as a resident.

Healthcare when you visit the UK

Many British expats travel back regularly to see family. What you pay for treatment there depends on your situation:

A
With a registered UK S1

According to the NHS, since 1 January 2024 you can use the NHS in England on the same basis as a UK resident during a temporary visit and do not pay for treatment. For Scotland, Wales and Northern Ireland, check the charging rules of the NHS body there.

B
Insured through the SNS

Without an S1, the UK government says you should not expect free NHS treatment unless you have an EHIC, a provisional replacement certificate (PRC) or an S2 showing that Portugal pays, or another exemption applies.

C
Without proof of cover

Treatment you have to pay for is charged at 150 % of the national NHS rate, according to the UK government’s guidance for visitors from the EU.

For everyone, A&E and GP visits in England are free, and urgent treatment is always provided, with payment dealt with later. The UK government also names exemptions for former UK residents visiting England, including UK war pensioners and UK government employees. Its guidance additionally states that UK nationals who lived and worked in the EU on or before 31 December 2020 may be able to use NHS services without charge and may be asked for proof of residence. Check before you travel which rule applies to you, and take out travel insurance for visits to the UK, as you would for any other trip.

Costs and waiting times in both systems

Costs. According to the Alerta de Supervisão 6/2025 of the Portuguese health regulator ERS, user charges in the SNS are now only payable in hospital emergency departments, with exceptions; the examples of charges on the UK government’s Portugal page (2021) no longer apply. For most medicines, the SNS reimburses 90, 69, 37 or 15 % of the price depending on the drug group (Portaria 195-D/2015, with special rules for some medicines); you pay the rest. In England, patients pay prescription charges, for example. Charges, medicines and dental care in the SNS are explained in detail in our guide Portugal’s healthcare system explained.

Waiting times. In England, the NHS gives you a legal right to start non-urgent consultant-led treatment within 18 weeks of referral, with exceptions. In Portugal, legal maximum waiting times at normal priority are 120 days until the first specialist appointment in hospital and 180 days until surgery (Portaria 153/2017). According to the ERS report on the second half of 2024, 53.1 % of patients in public hospitals waited longer than the limit for their priority level for a first specialist appointment; for surgery the share was 15.1 %.

Appointments, results and forms in the SNS are in Portuguese. The UK government links to a list of English-speaking medical facilities and doctors in Portugal in its guide Living in Portugal.

When private health insurance in Portugal makes sense

The S1 and registration with the SNS give you state healthcare in Portugal. Private hospitals and clinics are not included. Private health insurance in Portugal does not replace the SNS; it comes on top. It is worth considering if you:

  • want specialist appointments and tests without waiting months,
  • do not want to put off a planned operation,
  • want to choose an English-speaking doctor at a private clinic,
  • spend a lot of time in the UK or elsewhere and want cover outside Portugal through an international plan.

If you had private medical insurance in the UK, ask your insurer in writing whether the policy still covers you once you live in Portugal. Before accepting you, Portuguese insurers ask about your health; according to a November 2024 analysis by the consumer organisation DECO PROteste, insurers set a maximum age for joining and exclude pre-existing conditions. Anyone over 60 or with a diagnosed condition will therefore find it hard to get cover; MGEN is an exception there. Our guides explain pre-existing conditions and waiting periods, what private health insurance in Portugal costs and how the best private health insurance plans in Portugal compare.

Five mistakes British expats make

1

!Relying on the NHS after moving. The NHS is residence-based; a British passport alone does not give you free treatment once you live abroad.
✓Tell your GP practice that you are moving and register with the SNS in Portugal.
2

!Applying for the S1 too late. Without a registered S1 or other cover, you may have to pay for treatment.
✓If you already receive your State Pension, apply up to 90 days before the move and register the S1 promptly at the Segurança Social and the health centre.
3

!Living on an old UK GHIC. As a resident of Portugal, you can only use a UK-issued card in certain cases.
✓Check whether you are entitled to a UK card through your S1, or to a Portuguese EHIC through the SNS.
4

!Forgetting to report changes. If you start drawing a Portuguese pension or change your address, your S1 entitlement can change.
✓Tell NHS Overseas Healthcare Services about every change of address or circumstances.
5

!Taking out private cover only after a diagnosis or at an older age. Many Portuguese insurers have a maximum joining age and exclude known conditions.
✓Decide on private cover alongside the SNS while you are healthy and below the maximum joining age, ideally when you move.

Frequently asked questions

What is the difference between the NHS and the SNS?

Both are public health services funded by the state and open to residents. In the SNS you pay a user charge only in hospital emergency departments, with exceptions, and a share of the price for medicines. Appointments and forms are mainly in Portuguese, and the legal waiting limits are 120 days for a first specialist appointment and 180 days for surgery at normal priority.

Can I still use the NHS after moving to Portugal?

Not automatically. The NHS is residence-based, so after a permanent move you lose your normal entitlement. With a registered UK-issued S1, you can use the NHS like a resident when visiting England since 1 January 2024. If you return to live in the UK, you can register with a GP again.

Who is entitled to an S1 form in Portugal?

People lawfully resident in Portugal who receive a UK State Pension or certain exportable UK benefits, posted and frontier workers recognised by HMRC, and recipients of the unemployability supplement of a UK war pension. If you also receive a Portuguese state pension, Portugal is responsible for your healthcare instead.

How do I register my S1 in Portugal?

Take the S1, your passport and your residence certificate to a social security office (Segurança Social), and possibly your NIF. Then register at your local health centre, where you receive your user number. Until the S1 is registered, make sure you have other cover.

Can I use my UK GHIC if I live in Portugal?

Only in certain cases, for example as a UK State Pensioner or frontier worker with a registered S1, or as a UK student. The UK-issued card is then meant for temporary visits to other countries. If you are covered by the SNS as a resident without an S1, ask about a Portuguese EHIC for travel.

Do I pay for NHS treatment when I visit the UK?

With a registered UK S1, not in England. A&E and GP visits in England are free for everyone. For other treatment without an S1, you need an EHIC, a provisional replacement certificate or an S2 from Portugal, or another exemption; otherwise it is charged at 150 % of the national NHS rate. Travel insurance for visits to the UK is advisable.

Do British expats need private health insurance in Portugal?

No. According to the UK government’s current guidance, you do not need private health insurance, but you must register for state healthcare. Private cover makes sense if you want specialists, tests and planned operations without long waits. For a residence visa, the UK government’s 2021 guidance says Portugal requires proof of healthcare cover.

What happens to my S1 if I start drawing a Portuguese pension?

According to the NHS, you are then no longer entitled to a UK-issued S1, and Portugal becomes responsible for your healthcare. Tell NHS Overseas Healthcare Services about the change.

Our advice as an independent broker

Before you move, clarify which country will be responsible for your healthcare: as a UK pensioner usually the UK through the S1, with pensions from several countries the country where you paid contributions longest, and with a Portuguese pension or work in Portugal usually Portugal through the SNS. Apply for the S1 in good time, register it straight after the move and register with the SNS in any case. Then decide whether you want private cover on top, and for what: hospital only, specialists as well, or treatment outside Portugal.

As an independent broker, we compare plans from several insurers, check which private hospitals near you are in the network and explain the terms in English. You will find an overview on our page Health insurance in Portugal.

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As of 2 November 2026. This article reflects the information available on the date stated and does not replace legal or insurance advice in individual cases. Sources: NHS guidance “Planning your healthcare abroad”, “Get healthcare cover abroad with a UK GHIC or UK EHIC” and “Guide to NHS waiting times in England”; UK government guidance “Healthcare for UK nationals living in Portugal”, “Living in Portugal”, “Healthcare for EU and EFTA citizens visiting the UK” and “Using the NHS when you return to live in the UK”; information from the Portuguese administration on gov.pt (“Migrantes: cuidados de saúde em Portugal”); the DECO PROteste analysis of 21 November 2024; Alerta de Supervisão 6/2025 and the report on waiting times in the SNS in the second half of 2024 by the Entidade Reguladora da Saúde; Portaria 195-D/2015 and Portaria 153/2017.

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