Why living somewhere is not the same as visiting

Insurance for a holiday is a product. Insurance for a life is a set of overlapping systems that were each designed for someone who has always been there.

When you visit Portugal or Spain, one travel policy does almost everything: a doctor if you fall ill, a replacement flight, a lost suitcase. It works because it assumes you are going home. The moment you stop going home, that assumption collapses. A travel policy will not pay for the chronic condition you now manage locally. A home policy will not respond the same way to a house nobody sleeps in from October to April. And the health system that has looked after you for forty years may stop being responsible for you the week you register your address abroad.

Two things drive most of the confusion we see. The first is which passport you hold, because that decides whether any public entitlement travels with you. The second is how you entered the system — as an EU citizen exercising free movement, as a pensioner whose home country still pays for their healthcare, as a visa applicant who had to buy a policy before arriving, or as someone who bought a house first and thought about the rest later. Two neighbours on the same street can have completely different correct answers.

What follows is what actually happens, including the awkward parts. It is general information rather than advice on your situation, and where something genuinely varies by insurer, by consulate or by case, we say so instead of inventing a number.

The foundations that apply to everyone

Public system versus private cover — and why most people end up with both

Portugal's Serviço Nacional de Saúde (SNS) and Spain's public health system are both broad, tax-funded systems that legal residents can use once they are properly registered. They are not the poor relation of a private policy. For emergencies, serious illness, surgery and long-term treatment, the public hospital is frequently where you want to be.

What the public system does not sell is speed and choice. A non-urgent specialist appointment or a scan is scheduled when the system can schedule it. A private policy buys a different queue, a choice of clinic, and — in practice, for many international residents — the ability to be seen by someone who consults in English.

So the common outcome is not one or the other. It is both: registered with the public system for the things it does best, holding a private policy for access. If you want that comparison in more detail, we have written it up separately in SNS versus private insurance, and the private health insurance page sets out how the local policies differ.

The part that catches people out

Registration with the public system is not automatic on arrival, and private cover bought abroad is not a substitute for it. Both need doing. The order in which you do them is usually dictated by paperwork — an address, a social security number, sometimes a residence permit — not by preference. If you are still assembling documents, it is worth reading what you can arrange before you have a NIF or residency.

The home policy written for someone who lives there

Portuguese and Spanish household policies are drafted with a normal residence in mind: someone sleeps there, notices the leak, turns off the water. A great many properties owned by international residents are not that. They are empty from November to March, or occupied a fortnight at a time, or let out in summer.

Almost every policy handles this through an unoccupancy condition. After a continuous period with nobody living in the property, cover for certain perils is restricted or withdrawn — most often escape of water, sometimes theft, occasionally more. The number of days and the exact consequence vary by insurer and are written into the conditions, which is precisely why a generic answer is useless here. What matters is that the clause exists, that it is measured in consecutive days, and that a claim is the moment it gets applied.

The awkward version of this conversation happens after a burst pipe in a house that has been shut up since Christmas. We have written the detail in how an unoccupancy clause voids cover on a second home. Two related traps: letting the property out, even occasionally, can take it outside a residential policy altogether — the Alojamento Local requirements are a separate obligation, not an add-on — and a policy attached to your mortgage by the lending bank is usually written to protect the bank's interest first. Our home insurance page covers what a policy needs to say for a property used this way.

What "insurance intermediary" means in Portugal, and how to verify one

In Portugal, the people who arrange insurance are regulated as insurance distributors and must be registered with the Autoridade de Supervisão de Seguros e Fundos de Pensões — the ASF. Registration is by category, and the category defines what the firm may do and on whose behalf it acts. Adler & Rochefort is registered as an agente de seguros: an insurance agency that holds distribution agreements with insurers and advises clients on cover placed with them.

Two practical consequences. First, a registered intermediary must identify itself properly — registered name, category and registration number — and is subject to conduct rules and a complaints route. Second, the register is public, so you never have to take anyone's word for it.

Before you send anyone a passport scan, a property deed or a medical history, do this:

  1. Ask for the registered company name, not just the trading name. These are often different, and only the registered name appears on the register.
  2. Ask for the ASF registration number and the category of registration.
  3. Search that number on the ASF's public register of insurance distributors at asf.com.pt and confirm the name and status match what you were told.
  4. Check that any quote or policy document names the insurer carrying the risk, separately from the intermediary arranging it. They are two different companies with two different jobs.

If anyone is reluctant about the first three, that is your answer. Ours are on our about page, in writing: Ownizo, Unipessoal Lda., ASF registration 425591790/3.

By nationality

This is the section that changes the practical answer. Everything above applies to everyone; what follows does not.

British residents

Since the end of free movement, a British national moving to Portugal or Spain arrives on a visa or residence route rather than as an EU citizen. That is well understood. What is less well understood is that the healthcare question and the insurance question came apart at the same time.

The limits of the S1 route

An S1 is the mechanism by which one country continues to pay for the state healthcare of someone living in another. For British nationals it is chiefly relevant to those whose healthcare costs remain a UK responsibility — most commonly recipients of a UK State Pension, and certain other exportable benefits and posted workers. Where it applies, it is genuinely valuable: it registers you into the local public system on broadly the same footing as a local resident.

Its limits are the part people discover late:

  • It is not available to everyone. Early retirees below UK State Pension age, and people living on savings, investments or remote work, generally do not qualify.
  • It gives access to the public system. It is not private cover, and it does not buy private appointments, private hospitals or English-speaking private clinics.
  • It has to be registered locally before it does anything. Holding the form is not the same as being in the system.
  • Eligibility and the exact process are set by the UK authorities and the local health service, and they change. Confirm your own position with them rather than with a forum.

Why UK private medical policies generally do not travel

UK private medical insurance is written for UK residents and built around UK hospital networks and consultants. Once you are resident abroad, the policy typically no longer fits the eligibility conditions it was sold under, and even where a policy technically continues, the network it pays into is 2,000 kilometres away. Continuing to pay a UK premium after moving is one of the most common wasted expenses we see.

Nor is a GHIC a substitute. It is designed for necessary treatment during temporary visits, not for people who live here.

The practical gap

The gap that catches British residents out is the middle: below State Pension age, so no S1; resident abroad, so the UK policy no longer works properly; not yet registered with the local public system, because that is waiting on paperwork. For weeks or months there is nothing behind you but a travel policy that was never designed for this.

The fix is unglamorous — put local private cover or an international policy in place from the date of the move, rather than from the date the paperwork completes. More detail in insurance for British residents in Portugal after Brexit.

Dutch residents

The Dutch position is the cleanest on paper and the easiest to get wrong in practice, because the Dutch system is compulsory and people assume compulsory means permanent.

What happens to the basisverzekering on deregistration

The Dutch basisverzekering is obligatory for those insured under the Dutch national scheme — broadly, people who live or work in the Netherlands. It follows from that obligation that when you deregister from the Netherlands and are no longer covered by the Dutch scheme, the obligation ends and so does the policy. It is not optional cover you may choose to keep for comfort. You are required to end it, and continuing to pay premiums does not buy you cover for treatment in Portugal.

Separately, Dutch nationals drawing a Dutch state pension or certain benefits may remain entitled to healthcare at the Netherlands' expense while living in another treaty country, administered through the CAK, with a contribution deducted accordingly. That route is not the basisverzekering continuing; it is a different mechanism with its own registration. We have set out both in Dutch: uitschrijven uit Nederland en uw zorgverzekering and het S1-formulier en het CAK in Portugal.

The timing trap when you move mid-year

Dutch health insurance is organised around the calendar year: annual policy terms, an annual switching window, an annual own-risk amount. A move in June does not fit that rhythm, and three things collide:

  • The Dutch policy ends on the date the obligation ends — not at the end of the year, and not on the date you happen to sign a new one somewhere else.
  • Local Portuguese or Spanish private cover starts when it starts, subject to the insurer's own acceptance process, which takes time.
  • Registration with the local public system depends on your address and status paperwork, which follows its own clock.

Any misalignment between those three dates is a period with no cover. The way to avoid it is to fix the deregistration date first and work backwards from it, arranging the replacement so it starts on that date rather than after it.

What replaces it locally

Practically, a Portuguese private policy alongside SNS registration, or international private medical cover where you will spend meaningful time outside Portugal. Dutch readers who prefer this in their own language can start at zorgverzekering in Portugal.

One expectation worth resetting: a Portuguese private policy is not a translated basisverzekering. The Dutch system defines a statutory basket of care. A Portuguese private policy defines a network, annual limits per benefit and its own treatment of pre-existing conditions. Comparing them line by line is the only way to know what you have actually swapped.

American residents

Americans arrive with the widest gap between what they are used to paying and what they are used to being covered for — and with a domestic plan that almost never follows them.

Why US health plans rarely help abroad

US employer plans, marketplace plans and Medicare are built around US provider networks and, in Medicare's case, are generally limited to care within the United States. Some plans include a narrow emergency-abroad provision; almost none provide the routine, ongoing care that living somewhere requires — a GP, repeat prescriptions, a scan, a consultant you see twice a year. Keeping a US plan running to cover Portugal is not a strategy, though people with US ties sometimes keep one deliberately for treatment they intend to have in the US. That is a decision to take with open eyes, not an accident.

The role of international private medical insurance

This is where IPMI earns its place. Instead of covering you within one country's network, an international policy covers you across a defined region — for example Europe, or worldwide excluding the US — with a single set of terms that does not reset every time you move. For Americans who split the year, keep family in the US, or expect to move again within Europe, it usually fits better than a purely domestic Portuguese policy. It also tends to be more expensive, and the treatment of pre-existing conditions still has to be examined honestly at application rather than hoped over.

The interaction with D7 and residence permit evidence

Health cover is not only a practical question for American applicants; it is part of the file. Portuguese consulates and, later, AIMA generally expect documentary proof that you hold health cover valid in Portugal for the period concerned. The friction is in the detail:

  • A US domestic plan's summary of benefits is rarely accepted, because it does not evidence cover in Portugal.
  • What is usually wanted is a certificate or declaration naming the insured people, the territory and the validity dates — not a marketing brochure or a screenshot.
  • Requirements vary between consulates and can change, and the consulate handling your file has the final word. Confirm the current list with them; do not rely on a document that satisfied someone else's application last year.

We have written the evidence question up separately in what counts as valid proof of health insurance for a D7, alongside a broader guide for Americans moving to Portugal and a note on health insurance in Portugal for Americans.

Outside our remit

US citizens abroad carry tax and reporting obligations that have nothing to do with insurance and which we are not qualified to advise on. Where a question is fiscal — filing, reporting, treaty positions, the tax treatment of a policy or a payout — take it to a qualified tax adviser. We will tell you plainly when a question has crossed that line.

Other EU residents

For citizens of another EU or EEA member state the mechanics are the friendliest, which is exactly why the edges get missed.

The EHIC covers necessary state healthcare during a temporary stay, on the same terms as a local. It is not a residence entitlement. Once you live here, the card is not the instrument you are relying on, and continuing to travel back to your old GP on an EHIC is not a plan.

An S1 works much as described above: if another member state remains responsible for your healthcare costs — typically as a pensioner of that state, or as a posted worker — it registers you into the local public system at that state's expense. If you take local employment or become self-employed here, you generally contribute here instead, and the S1 route stops applying.

Where portability stops being sufficient:

  • Planned treatment. Deliberately travelling to another member state for a procedure is a separate authorisation process, not something an EHIC covers.
  • Private care. Neither an EHIC nor an S1 buys private appointments, private hospitals or an English- or Dutch- or German-speaking private clinic.
  • Repatriation and evacuation. Public entitlement does not pay to bring you home, or to move you to a specialist centre. That is a separate cover.
  • Everything that is not health. Free movement portability says nothing at all about your house, your car, your boat or your professional liability. Those are placed locally, under local law, whatever your nationality.

The cover people forget

Health and home get arranged because someone asks about them. These are the ones that surface a year later, usually because something happened.

Living across two countries

A growing number of the people we advise do not live in one country. They have a house in the Algarve and an apartment in Andalusia; they spend winters in one and summers in the other; or they are moving from one to the other over eighteen months rather than in a weekend.

Three things are worth knowing.

Insurance intermediation is portable within the EU; policies are not automatically. An intermediary authorised in one member state can serve clients in another under Freedom of Services — in Portuguese, Livre Prestação de Serviços, or LPS. That is how we advise clients in Spain on the basis of our Portuguese authorisation. It means the same adviser and the same file can follow you across the border. What it does not mean is that a policy automatically responds on both sides: the territorial limits written into the policy decide that, and they differ by line of business. A household policy is tied to an address. A motor policy has a defined territory. Health and IPMI have a defined area of cover. Marine has a defined cruising range. Ask about the territory explicitly, in writing, for each policy.

Residence is singular even when your life is not. Which country you are resident in drives your public healthcare entitlement and the basis on which local policies are written. Splitting your year does not split your residence, and guessing at it creates problems well beyond insurance. Where that question is fiscal, it belongs with a tax adviser rather than with us.

Two properties are not one file duplicated. Rebuild costs, construction, seismic exposure, flood exposure, occupancy patterns and even the meaning of "contents" differ between the two markets. If you hold property in more than one jurisdiction, insuring a property portfolio across two jurisdictions goes into what changes.

A short practical checklist

Have these ready and any quote — from us or from anyone else — gets faster and more accurate. Missing items are the main reason a quote comes back as a range instead of a price.

For any quote

  1. Identity document — passport or national identity card, for each person to be covered.
  2. NIF (Portuguese tax number), or NIE in Spain, if you already have one. Not always needed to start, but needed to issue.
  3. Address of the risk and your correspondence address, if they differ.
  4. Dates — the date you want cover to start, and the date any current policy renews.
  5. Details of existing cover — insurer, policy number, sums insured, and the current schedule if you have it. A copy of the schedule is worth more than a description of it.
  6. Claims history for the last few years, honestly stated. Non-disclosure is how claims get declined.

For health cover, additionally

  1. Date of birth for everyone to be insured.
  2. An honest account of pre-existing conditions and current medication. Insurers treat these very differently, and the difference only helps you if it is disclosed at application.
  3. Whether you need the certificate for a visa or residence file, and which authority is asking — the wording of the document depends on it.

For property, additionally

  1. The caderneta predial or equivalent, and the built area.
  2. Construction type and approximate year, plus any recent renovation.
  3. An estimate of the rebuild cost and of contents value, with valuables listed separately.
  4. How the property is used through the year, including the months it is empty and whether it is ever let.

Frequently asked questions

Do I need private health insurance if I can use the SNS?

They do different jobs. The public system handles emergencies, serious illness and long-term treatment; a private policy buys faster access to private specialists and diagnostics, a choice of clinic, and documentation some visa and residence processes ask for. Most international residents hold both rather than choosing.

Will my existing health insurance from home cover me here?

Usually not in the way you expect. Domestic plans are written for residents of the country that issued them and are built around that country's network. UK private medical policies and US plans rarely respond to routine treatment in Portugal, and the Dutch basisverzekering ends when the obligation to hold it ends. What replaces it is local private cover or an international policy.

How do I check that whoever is advising me is registered?

Ask for the registered company name, the ASF category and the registration number, then search that number on the ASF's public register. Any registered intermediary will give you all three without hesitation.

Can a policy arranged in Portugal follow me to Spain?

The adviser can, under Freedom of Services. Whether a given policy responds in Spain depends on the territorial limits in its wording, which vary by line of business. Ask for the territory in writing for each policy.

Does any of this depend on my tax position?

Residence affects public healthcare entitlement, and tax residence is a related but separate question decided under tax law. We do not advise on tax, and we will say so when a question crosses into it.

Who wrote this

Adler & Rochefort is an English-speaking insurance agency licensed in Portugal and passported into Spain under Freedom of Services. We are members of afpop, NCA Portugal and the British-Portuguese Chamber of Commerce, and we are registered with the ASF under no. 425591790/3 — a public registration you can verify before you contact us. More about the firm, its memberships and its insurer agreements is on our about page.

If something in this guide applies to you and you would like a written view on it, write to us at insurance@adlerrochefort.com — a paragraph about where you live, what you own and what you are unsure about is enough to start. We reply in writing, in English.

General information only. This guide describes how these systems generally work and is not advice on your circumstances or a recommendation of any policy. Entitlements, consular requirements and policy wordings change; confirm your own position with the relevant authority or insurer. Nothing here is tax advice.