" Free movement of persons is one of the fundamental freedoms of European integration. It is protected by EU primary law, especially by the TFEU and its provisions on citizen's rights and free movement of workers within the Union. The described freedom is not absolute, however. One of the crucial limitations consists of the economically non-active EU citizens and their family members having to obtain comprehensive sickness insurance cover in the host Member States in order to enjoy the right of residence for more than three months in those states. The aim of the paper is to analyse the legal framework of the UK, Ireland, Slovenia and Croatia and their implementation of the EU Residence Directive's comprehensive sickness insurance condition for the right of residence in EU Member States and determine whether certain changes to the Residence Directive are needed in order to obtain a clearer regulation of EU citizens' rights in cross-border situations. The analysis has shown that the national autonomy may result in various interpretations, depending on the type of the social security health system the country in question employs. Different interpretations have highlighted the need for a clearer EU-level regulation, to increase clarity and legal certainty for migrants. "

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