Can I work with a client who is in another country
United Kingdom, Published 17 August 2026
Four minute read. Published on 17 August 2026. Last reviewed on 17 August 2026. Focus, the United Kingdom, with a European reader in mind.
A note on what this is
This guide is our reading of the law and the published guidance, from a legal and compliance point of view. It is not advice about your practice, and it cannot weigh the particulars that make your situation yours. It also leaves untouched the ethical question that usually sits underneath, which is almost always the harder one. Compliance is the duller half of the problem. It is not the less important half.
In short
There is no single answer, because it is not really a single question. Working with a client abroad raises four, with different answers. Whether you may use your title where the client is sitting, whether the practice of psychotherapy is itself restricted there, whether your insurance follows you, and whose data protection law governs the notes. The title and activity questions come apart, and in Germany and Italy it is the activity question that carries the greater risk. As a rule of thumb, start from the law of the place where your client is sitting. Your United Kingdom professional body will not answer for another country.
The title
This part is reasonably clear. In the United Kingdom the words psychotherapist and counsellor are not protected, while the psychologist titles are reserved to registrants of the Health and Care Professions Council. Much of Europe works the other way round. Germany reserves its title to holders of an Approbation, which requires a psychology degree, and Italy admits only registered psychologists and physicians with a four year specialisation. Do not generalise from those two. Austria asks for no psychology degree at all, and Ireland has not yet opened its registers.
The activity, and where the session happens
Title and activity are separate questions. In the Netherlands the title is reserved but the work is not, so someone adequately trained may practise lawfully and simply may not use the protected name. Germany takes the stricter view, and practising the healing arts there without an Approbation or a Heilpraktiker permit is an offence under a 1939 statute; Italy treats unauthorised practice of a regulated profession as a criminal matter.
Those statutes are clear on their own terms. What is much less clear is how they apply to a practitioner sitting in Britain while the client is elsewhere. No regulator we could find has published a position on that, so please treat it as a question for local advice.
One ruling looks as though it ought to help. In September 2025 the Court of Justice held that care delivered exclusively by electronic means is governed by the law of the provider's Member State. Our reading is that it does not reach a practice established outside the Union. That is an interpretation, not a decided point.
The insurance
Of six United Kingdom schemes whose wording we read in August 2026, every one makes cover abroad conditional on you remaining resident here, and treats time away as a temporary visit. None covers a practitioner who has moved. That much was consistent.
The detail was not, so please do not rely on a number you have read somewhere. One scheme publishes a limit of 60 consecutive calendar days abroad, on a page carrying no date. Another states there is no limit. The rest publish no figure. As a rule of thumb, read your own wording for the territorial limit and the jurisdiction clause separately, then ask your insurer in writing about your client's location as well as your own. BACP members may want to note that the 2025 Ethical Framework treats cross border cover as a condition of membership.
The data, and how sure we are
One part of this is settled. You are subject to the United Kingdom GDPR because you are established here, wherever your client happens to be, and the [Data Use and Access Act 2025](/resources/guides/data-use-and-access-act-2025) did not change that.
The rest is less certain, so we will mark it as we go. The EU regulation reaches a practice outside the Union only where services are offered to people in the Union in a way that shows the provider envisaged doing so, and a reachable website in English does not on its own meet that test. Our reading, and it is a reading rather than a rule, is that a practitioner who did not go looking for European clients is probably outside the regulation. The Court of Justice has never ruled on this test, so nobody can put it higher than that. The guidance says a service is not caught merely because someone enters the Union, but its examples are all holidays rather than moves, which leaves the client who emigrates unanswered. If it does apply, a representative in your client's country is likely to be needed.
Adequacy is a separate point, often confused with this one. It was renewed in December 2025 and runs to December 2031. It lets personal data reach you from the Union, and says nothing about whose law governs what you then do with it.
Three weeks away is not a move
Much of what is written about this collapses two pairs of cases. A client travelling for three weeks is not a client who has relocated, and a practitioner working from Sicily for a fortnight is not one who has moved there. Insurance turns on your continued residence here. Local professional law, as a rule of thumb, turns on where your client is during the session.
What to do this week
- List every client who is outside the United Kingdom during sessions, and the country they are in. Everything else follows from that list.
- Read your policy wording rather than your schedule, and ask your insurer in writing whether cover follows your client's location as well as yours.
- For each country on the list, check the title and licensing position with that country's own regulator. Our [other guides](/resources/guides) cover the United Kingdom side.
- Consider whether anything you publish invites clients in the Union. Pricing in euro, a European directory listing or advertising into a Member State all point that way.
A footnote on advice
This guide is information, not legal advice, and it is not advice about your insurance or your registration. Where a point is settled we say so, and where we are interpreting we say that too. Before acting on it, please check your wording with your insurer, check your position with your professional body, and take advice from a lawyer qualified in the country your client is in. Vestibola accepts no liability for decisions taken on the basis of this page.
References
- Case C-115/24, UJ v Österreichische Zahnärztekammer, judgment of 11 September 2025
- Directive 2000/31/EC on electronic commerce
- Regulation (EU) 2016/679, the General Data Protection Regulation
- EDPB Guidelines 3/2018 on the territorial scope of the GDPR
- Commission Implementing Decision (EU) 2025/2574, renewing UK adequacy
- Psychotherapeutengesetz, section 1.pdf)
- Heilpraktikergesetz 1939, sections 1 and 5
- Legge 18 febbraio 1989, n. 56, ordinamento della professione di psicologo
- Wet op de beroepen in de individuele gezondheidszorg, articles 3 and 4
- CORU, Counsellors and Psychotherapists Registration Board
- HCPC, professions and protected titles
- UKCP, working overseas
- BACP, Ethical Framework for the Counselling Professions 2025
- Balens, combined liability policy wording
- Everywhen, counsellors insurance
About this guide
Jurisdiction, the United Kingdom, with reference to the law of Germany, Italy, Austria, the Netherlands and Ireland. Last reviewed on 17 August 2026. Insurance wordings and commencement dates change, so treat anything dated here as accurate only to that date. This guide is not legal advice.
Frequently asked questions
Can a UK therapist work with a client who lives in another country?
There is no single answer, because it is not really a single question. Working with a client abroad raises four, with different answers. Whether you may use your title where the client is sitting, whether the practice of psychotherapy is itself restricted there, whether your insurance follows you, and whose data protection law governs the notes. As a rule of thumb, start from the law of the place where your client is sitting.
Does UK indemnity insurance cover a client who is abroad?
Of six United Kingdom schemes whose wording we read in August 2026, every one makes cover abroad conditional on you remaining resident here, and treats time away as a temporary visit. None covers a practitioner who has moved. The detail varies, so read your own wording for the territorial limit and the jurisdiction clause separately, then ask your insurer in writing about your client's location as well as your own.
Does the EU GDPR apply to a UK therapist with a client in the European Union?
You are subject to the United Kingdom GDPR because you are established here, wherever your client happens to be. The EU regulation reaches a practice outside the Union only where services are offered to people in the Union in a way that shows the provider envisaged doing so. Our reading, and it is a reading rather than a rule, is that a practitioner who did not go looking for European clients is probably outside the regulation. The Court of Justice has never ruled on this test.
Last reviewed 17 August 2026. General information for practitioners, not legal advice.