In recent weeks, the French Parliament has been debating the 2026 social security and general budget bills.
Until now, the uncertainty surrounding the outcome of the proceedings on the budget has made it premature to report on developments. However, with cross-party support coalescing around a new health levy on non-Europeans, the time appears right for some commentary.
The proposal originated as an amendment to the draft Social Security Financing Bill, tabled by centrist député François Gernigon. It swiftly attracted backing from other centrist and right-leaning groups, including members of Les Républicains.
The amendment stated:
“Les personnes étrangères ressortissantes d’un État non membre de l’Union européenne, de l’Espace économique européen ou de la Confédération suisse, titulaires d’un visa de long séjour valant titre de séjour mention « visiteur », sont tenues d’acquitter une cotisation annuelle spécifique dans conditions des fixées par décret, conditionnant l’ouverture et le maintien de leurs droits à la prise en charge de leurs frais de santé.”
In her response, Amélie de Montchalin, the Minister of Public Accounts, expressed sympathy for the proposal and indicated that the government would “examine the matter in due course,” signaling that the idea is being taken seriously at ministerial level.
CMU/PUMA
The context of the debate lies in the evolution of France’s universal healthcare system. In 2016, the Couverture Maladie Universelle (CMU) — which provided healthcare access to all residents for a modest contribution — was replaced by the Protection Universelle Maladie (PUMA). PUMA guarantees an automatic right to health cover to everyone legally residing in France, regardless of employment status.
However, while the CMU charge applied to economically inactive households, the PUMA charge was more narrowly focused on those with professional and investment income. As a result, most expatriates who are not economically active — particularly those living off pensions or the capital from savings — pay no health-related social security contributions.
Currently, only around 70,000 “rentier” households (French and foreign nationals) with a professional activity but substantial investment (including dividend) income are liable for the PUMA health contribution. These individuals escape the normal social contribution system. The rate is 6.5% (but decreasing) on unearned income (revenus de patrimoine) above €23,550. The generous (and complicated) method of calculation used generally means that most of those liable pay under €1,000 per year.
European citizens do not pay the charge and anyone who has a pension is completely exempt, even though they might otherwise be liable on professional and investment income.
Moreover, due to bilateral tax treaties, certain groups — most notably inactive U.S. citizens — are exempt not only from French social charges on pension income but, in some cases, also from French income tax. Under the USA/France tax treaty they pay tax in the US on their pensions. (Reciprocally, French pensioners in the US pay tax on French pensions to France.) For French source income, Americans pay tax in France.
The cumulative effect is that some non-European residents enjoy substantial fiscal relief while benefiting from publicly funded healthcare, a situation that critics have described as turning France into a “tax haven” for well-off expatriates.
This arrangement has long rankled segments of the French political class. Many foreign residents, particularly from outside the European Union, benefit from access to France’s healthcare system without making social security contributions.
What is the Charge?
At this stage, the details of any new health charge remain undefined. Although some newspaper reports have indicated that it will be a fixed charge, the amendment itself does not specify this. A decree will set out the calculation of the charge, which will almost certainly have regard to income and possibly also personal circumstances.
If lawmakers seek guidance from precedent, the former CMU contribution rate of 8% on income exceeding €9,500 could serve as a reference point. Similarly, existing income thresholds for free or subsidised healthcare may provide a template for exemption limits — currently €10,339 for a single person and €15,508 for a couple for complete exemption, with incremental increases for dependent children. The risk that some people could be liable for both the PUMA charge and the new health charge can almost certainly be dismissed; the new charge will apply to those who are economically inactive.
There also remain technical difficulties with the amendment as passed, as it refers only to those on a long-term visitor visa, ignoring the fact that there are many other types of visas. Moreover, it is silent on those who have been granted permanent residency. Its application to only certain types of residency status would almost certainly be considered discriminatory.
The explanation given in the text by the sponsors for the clause may also be a problem for the Constitutional Council, for in introducing the amendment they state that “Le présent amendement vise à instaurer une cotisation obligatoire pour les ressortissants extracommunautaires titulaires d´un visa long séjour « visiteur », notamment les retraités américains installés en France sans y exercer d´activité." That’s very naughty. We are also aware that many Americans in France choose to continue with a private health policy, so they are not in the state system.
There may well yet be further amendments made to the clause which deal with this and other anomalies.
Tax and Social Security Treaties
During the parliamentary debates, an additional amendment to the main clause was also passed, exempting from the charge those citizens from countries where there was a social security protocol in place with France. However, the scope of these agreements varies widely. While one exists for the United States, it explicitly excludes healthcare coverage, unlike the UK–France arrangements under the Brexit Withdrawal Agreement.
More generally, the government also raised the possibility of revisiting tax treaties that exempt foreign residents from certain French taxes and charges.
Renegotiating such treaties — particularly with countries like the United States — would be a long and uncertain process, as it would require mutual consent and ratification by both parties. In the short term, therefore, any new health charge is likely to apply only within the limits of existing international agreements.
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