UK State Pension and US Social Security: Totalization and the End of the Windfall Elimination Provision

You can receive a UK State Pension and US Social Security together. Each country pays its own benefit on its own contribution record, the totalization agreement lets a short record in one country borrow years from the other to qualify, and since January 2024 the US no longer cuts Social Security because you also have a UK pension. The tax on both follows where you live.

Two things changed recently: the US repealed the Windfall Elimination Provision, and from 6 April 2026 the UK restricted voluntary National Insurance for people abroad. This guide covers entitlement first and tax second. For the tax return side in depth, see our retiree guide to who taxes each US and UK pension.

How do the UK State Pension and US Social Security each decide who qualifies?

The UK counts qualifying years of National Insurance. The US counts credits (also called quarters of coverage), up to four a year.

The UK State Pension

For anyone reaching State Pension age on or after 6 April 2016, the new State Pension applies. GOV.UK says you usually need 10 qualifying years on your National Insurance record to get any of it, and 35 qualifying years for the full rate if your record started after April 2016. The full rate is £241.30 a week for 2026/27. People with a record before 2016 have a "starting amount" and may need more than 35 years if they were contracted out. The Department for Work and Pensions' explainer puts each qualifying year added after 5 April 2016 at about £6.89 a week, one thirty-fifth of the full rate.

State Pension age is currently 66 and is rising to 67 between 2026 and 2028. Under the State Pension age timetable, people born between 6 April 1960 and 5 March 1961 reach it at 66 plus a set number of months.

US Social Security

The Social Security Administration (SSA) normally requires 40 credits, about ten years of work, for a retirement benefit. For 2026, one credit takes $1,890 of covered earnings and nobody can earn more than four in a year. A reduced benefit can start at 62; full retirement age is 67 for people born in 1960 or later.

How does the totalization agreement US UK workers rely on actually work?

The totalization agreement fills gaps in eligibility. It does not merge the two pensions, transfer contributions, or let one country pay for years worked in the other. The US/UK social security agreement, which the US calls a totalization agreement and the UK a reciprocal agreement, has been in force since 1 January 1985. Its first job is deciding which country you pay contributions to while working, covered in our guide to contractor tax and the certificate of coverage. Its second is benefits.

If you are short of US credits

The SSA's guide to the agreement says that if you do not have enough US credits for a regular benefit, you may qualify for a partial US benefit based on both countries' credits, but only if you have earned at least six US credits, generally a year and a half of work. If you already have enough US credits, the US cannot count your UK credits at all.

The SSA's operating manual, POMS GN 01719.120, gives the conversion: one US quarter of coverage for every 13 weeks of UK coverage in a calendar year. The resulting "totalization benefit" is pro-rata. The SSA builds a theoretical full-career benefit from your actual US earnings and then pays the fraction that matches your real US coverage. UK years get you through the door; they do not increase the dollars.

If you are short of UK qualifying years

The mirror rule is in POMS GN 01719.125: the UK counts US coverage if you are not insured for a UK benefit on UK coverage alone and you have at least 52 weeks (one year) of UK coverage. The UK credits 13 weeks for each US quarter. GOV.UK confirms the effect for the new State Pension: time spent contributing in a country with a social security agreement can be added to reach the 10-year minimum, but "the amount you actually get paid will only be based on the qualifying years in your UK National Insurance record".

One caution: the UK column of the SSA's public guide still describes older UK rules. For UK entitlement, rely on GOV.UK and your own State Pension forecast.

Three split-career patterns

Your record	UK State Pension	US Social Security
10 or more UK qualifying years and 40 or more US credits	Regular State Pension on UK years	Regular benefit on US earnings. The agreement is not needed on either side
1 to 9 UK qualifying years and 40 or more US credits	US coverage counted to reach 10 years; paid on UK years only	Regular benefit on US earnings
10 or more UK qualifying years and 6 to 39 US credits	Regular State Pension on UK years	UK coverage counted to reach 40 credits; pro-rata totalization benefit

Below six US credits, or below one year of UK coverage, the agreement gives no help on that side. It also does not extend to Medicare.

What did the end of the Windfall Elimination Provision change for a UK State Pension?

The repeal means a UK State Pension no longer reduces US Social Security, for any month after December 2023. Before that, it often did.

The Windfall Elimination Provision (WEP) reduced the US retirement benefit of anyone who also received a pension from work not covered by US Social Security. POMS RS 00605.360 records that the 90% factor applied to the first band of average earnings could fall to 40% for workers with 20 or fewer years of substantial US earnings. A foreign pension counted.

The treatment of UK pensions was more specific than most summaries say. Under POMS GN 00307.290, for January 1995 to December 2023 a pension from a totalization country triggered WEP where the person received a non-totalized benefit from both countries. In plain terms:

• Someone with 40 US credits and enough UK years for a State Pension in their own right was caught: two regular benefits, so WEP applied, unless they had 30 years of substantial US earnings, which exempted them.
• Someone whose UK State Pension was awarded under the agreement, using US coverage to qualify, was not caught. Nor was a US totalization benefit itself.
• The part of a pension based on voluntary contributions did not trigger WEP. The SSA manual names the United Kingdom as an example.

The Social Security Fairness Act ended all of this. POMS RS 00605.360 states that the President signed the Act on 5 January 2025 and that it "eliminates the WEP reduction for benefits payable for months after December 2023", beginning with the benefit due for January 2024, paid in February 2024. The Act also repealed the Government Pension Offset (GPO), which had reduced spouse's and survivor's benefits for some people with government pensions.

If your US benefit was reduced because of a UK pension, check your current award against the SSA's Social Security Fairness Act page and contact the SSA if a reduction still appears.

How to claim each pension from the other country

The SSA's guide says you can apply in one country and ask for the application to be treated as a claim in the other. Each country then decides under its own law.

1. Get both records first. Check your UK National Insurance record and State Pension forecast on GOV.UK, and your US earnings record with the SSA.
2. Living in the US, claiming the UK State Pension. GOV.UK says you must be within four months of State Pension age, and you claim through the International Pension Centre by phone or with the international claim form. The SSA can also take the claim: its guide says you can apply for UK benefits at any US Social Security office using form SSA-2490-BK.
3. Living in the UK, claiming US Social Security. The SSA's guide directs UK residents to the Federal Benefits Unit at the US Embassy in London for US benefits, and to the UK authorities for UK benefits.
4. Choose how the State Pension is paid. GOV.UK says it can go to a bank where you live or to a UK account, every 4 or 13 weeks, with a 0.39% conversion charge on payments converted to local currency.

The State Pension only increases each year in certain countries, and the GOV.UK list of countries where an annual increase is paid includes the USA.

Filling National Insurance gaps from abroad after 6 April 2026

The rules for voluntary contributions changed on 6 April 2026, and the GOV.UK guidance for people who live or work abroad now splits by tax year.

• Gaps for 2025/26 or earlier. The old test applies: you must have lived in the UK for three years in a row or paid three years of contributions. Voluntary Class 2 also requires that you worked in the UK immediately before leaving and are working, or worked, abroad.
• Time abroad from 2026/27 onwards. GOV.UK states: "You cannot pay voluntary Class 2 National Insurance contributions for time abroad." Class 3 is available only if you previously lived in the UK for 10 years in a row or paid 10 years of qualifying contributions. Earlier voluntary contributions for periods abroad and National Insurance credits do not count towards the 10.
• Transitional cases. People who applied on or before 5 April 2026 to pay for 2024/25 or 2025/26 may keep the three-year test for Class 3, provided they pay those contributions and apply for 2026/27 by 5 April 2027.

The cost difference is large. The 2026/27 voluntary rates are £3.65 a week for Class 2 and £18.40 a week for Class 3, so a full year costs £189.80 at Class 2 and £956.80 at Class 3. Against that, one extra qualifying year is worth about £6.89 a week of new State Pension at 2026/27 rates, roughly £358 a year, if the year increases your pension at all. GOV.UK warns that voluntary contributions do not always do so, for example where you were contracted out.

The usual deadline is six years: GOV.UK gives 5 April 2032 as the last date to fill a gap for 2025/26. Applications for time abroad are made on form CF83. Check your forecast, or ask the Future Pension Centre, before paying anything.

Who taxes the UK State Pension and US Social Security?

The country where you live taxes both benefits. Article 17(3) of the US/UK income tax treaty provides that payments made by one country under its social security legislation "to a resident of the other Contracting State shall be taxable only in that other State". Article 17(3) is one of the provisions preserved from the saving clause, so US citizens benefit from it too.

Where you live	Benefit	Who taxes it
UK resident, not a US citizen	US Social Security	UK only under Article 17(3); reported on the Self Assessment foreign pages
UK resident US citizen	UK State Pension	UK taxes it; the US return also includes it, with a foreign tax credit for the UK tax
UK resident US citizen	US Social Security	UK only. IRS Publication 915 lists the United Kingdom among the countries whose resident US citizens are exempt from US tax on their benefits
US resident, any citizenship	UK State Pension	US only under Article 17(3); paid by the UK without tax deducted
US resident, any citizenship	US Social Security	US only; taxed under the normal US rules for benefits

Two details catch people out. First, the UK State Pension is not US Social Security on a US return. IRS Publication 915 says foreign social security benefits "are taxable as annuities" unless a treaty exempts them or treats them as US Social Security, and the UK treaty does neither for a US resident. Second, the Publication 915 base amounts that decide how much US Social Security is taxable ($25,000 for a single filer and $32,000 for married filing jointly in the 2025 edition) are tested against your other income, which includes the UK State Pension.

We cover the wider picture in US and UK tax on retirement income and UK pensions under the US tax treaty, and our treaty relief service prepares the claims.

A worked example: 8 UK years and 25 US years

Illustrative example: a British-born engineer, born on 15 July 1960, worked in the UK for eight qualifying years, moved to Texas and then worked in covered US employment for 25 years. He is a US resident. His State Pension age under the timetable is 66 years and 4 months, which falls in November 2026. On UK years alone he fails the 10-year minimum, but the UK counts his US coverage and he qualifies. Assuming no contracting out and a simple one thirty-fifth per year, his State Pension is 8/35 of £241.30, about £55.15 a week or roughly £2,868 a year at 2026/27 rates, uprated annually because he lives in the US. His US benefit is a regular one on 25 years of earnings, with no reduction for the UK pension. Both are taxed only in the US. Because he has fewer than 10 UK years, he cannot buy Class 3 years for time abroad from 2026/27, although gaps up to 2025/26 inside the six-year window may still be open to him under the old three-year test. This is illustrative only; actual amounts depend on the full records.

Had he worked 12 UK years, he would have had a State Pension in his own right, and before 2024 that pairing of two regular benefits is the one that triggered WEP. Today there is no reduction either way.

What people get wrong

• "Totalization tops up my pension." It opens eligibility. Each country still pays only for its own years.
• "My UK State Pension will cut my Social Security." Not for any month after December 2023.
• "I can buy cheap Class 2 years from America." Not for 2026/27 onwards, and Class 3 for time abroad now needs a 10-year UK history.
• "My State Pension is frozen in the US." It is uprated. Canada and New Zealand are the frozen cases among agreement countries.

Planning the two pensions together

Entitlement comes first: how many qualifying years and credits you have, whether voluntary National Insurance is still open to you, and when to start each benefit. Tax then decides what you keep. Our retirees page explains how we combine the US/UK totalization agreement position with retirement tax planning, and our US/UK pensions service covers workplace and private pensions alongside the state ones.

US/UK Cross Border Tax is US CPAs and UK tax advisers working as one team, with offices in London, Manchester, New York and San Francisco. If you have worked in both countries and want both pensions, and both tax returns, looked at together, contact us.