Retirement benefits when you’ve worked both countries

More than a few of you have been asking lately about the US – France Social Security Totalization Agreement. This treaty may well apply to you if you have a work history in France and also in the US. But as both the French basic pension and the US Social Security program are complicated in and of themselves, understanding how and when to apply the Treaty can be pretty confusing.

You can find the US Social Security Administration’s explanation of the whole Treaty here: https://www.ssa.gov/international/Agreement_Pamphlets/documents/France.pdf. But we will focus in this article on what happens when you go to apply for benefits at retirement.

The Basics of state retirement eligibility

The first point to understand is that both countries have two major criteria for determining your retirement benefit: 1. The duration of your earnings record (i.e. how many quarters or years did you work in the country at a minimum income level); and 2. the amount of your earnings.

The second of these items is the most complicated part – and we will give you a basic idea of how that works in a moment. But the Treaty only applies to that first item: the duration of your record.

Both countries have criteria to determine how long you must work in order to qualify for retirement benefits. The Treaty assures that you do not lose out on eligibility for US and/or French benefits solely because you split your career between the two nations.

This is how it works. When you want to apply for benefits in either country, you notify the correct administration that you have an additional earnings record in the other country. The administration will then calculate your benefits under their own country’s rules. The first thing they look at is whether you have enough quarters or years to qualify for full benefits within that country’s own system. If you do, the Treaty will not come into play.

Any country where your local earnings record is sufficient to qualify you for state benefits will now calculate your benefit amount and pay you as it would any other retiree in the country.

But let’s say your US record is two years short of the amount needed to qualify for benefits but that you have an additional two years that you worked in France. The US administration will add the necessary two years from France to their calculations. In the reverse scenario, France will do the same. But France has a much lower bar for basic qualification.

Calculating amounts

This first step has ensured that you are going to get some sort of state retirement benefit. But you still need to determine the actual amount.

The actual amount you receive from each country will be based solely on your earnings record there. In other words, while your work in the second country can guarantee that you get some benefit, those earnings will not be used in the calculation of an amount. For that, each nation will use the average earnings points system that normally applies, essentially giving you a zero-earnings for those years.

How will this affect your pension and social security benefits?

You may well receive a full retirement benefit from one country where you worked most of your years and a partial benefit from another. Or you might receive a partial benefit from both.

US social security

To use the Treaty, you must have six credits (about 1 ½ years of work) in the US system. Where this is the case, the Social Security Administration (SSA) will use your date of birth to apply a point system to your earnings over the years. This is known as “indexing” and the system means that the SSA can adjust your earnings for inflation (A salary of 50,000 USD now has a very different value than the same amount in 1985). The SSA then uses the 35 years of your highest earnings. If you worked less than 35 years in the US, they use zeros for the missing years.  

The average of these indexed earnings gives the Administration an AIME figure for you  - “average indexed monthly earnings”. Next, they apply a benefit replacement formula. This tells you what percentage of your average earnings are going to be paid in benefits (i.e. how much of your salary will be “replaced” by benefits). For people who were 62 years old in 2024, that formula meant that you would get 90% of you the first 1,174 USD of your AIME, 32% of the next 5,904 USD and 15% of AIME over 7,078 USD.

Finally, the SSA will reduce or increase your benefits if you take them before your full retirement age or after the maximum benefit age of 70 years old. For a more complete explanation from the SSA with examples, go to https://www.ssa.gov/oact/ProgData/retirebenefit1.html.

If the SSA calculation includes French working years, you will see a final reduction in the amount of your benefits. But the amount of that varies significantly depending on what proportion of your years were outside the US. If you worked 8 years in the US and 2 in France, expect very little adjustment. If the proportion was a third or half, you will see a more significant impact. But remember that the US will only be looking at enough French years to meet the basic eligibility requirement (about 10 years). And you have already got those years in the US, totalization will not apply.

You may also see remarks about the Windfall Elimination Provision (WEP), which reduced some social security benefits because of pensions received from elsewhere. This provision is no longer in effect and should be ignored.

French pension

If you worked in France, you should have two pensions – the state basic pension and the supplemental pension that applies to whatever your particular field of work was. The Totalization Agreement pertains to your basic state pension.

French system has a much lower minimum time frame for eligibility (usually about one year). Under the Totalization Agreement pension authority will do  two calculations. First,  calculate the amount of your French pension based solely on your French credits. They then calculate what your prorated benefit would be using French and US credits. They will pay you the higher of the two.

Other points to note

To get credits from one country counted by another, you only need to alert them that you have an international work record. The relevant authorities will get your records directly from the other state.

The Totalization Agreement also provides a process to ensure that you do not pay into both systems at once and provisions for accessing disability or survivor benefits from either system. It does not apply to help you qualify for US Medicare benefits if your US work record is insufficient to do so.