A Comparative View of the Comprehensive Sickness Insurance Condition for Residence in Article 7 of Directive 2004/38

The Citizenship Directive 2004/38 provides for a right of residence for more than three months and up to five years for EEA nationals and their family members in other EEA states, subject (amongst other things) to a requirement of “comprehensive” sickness insurance during one’s stay. Yet what does “comprehensive” mean under EU and EEA law? How has this been interpreted by the CJEU and/or EFTA Court? And how is the requirement understood and applied at national level? These are the main issues discussed in the following article, which reveals a surprisingly high level of disparity in terms of interpretation and application of the requirement at national level in Norway, Iceland, Liechtenstein and Sweden.