Disclaimer: This question is probably based on a misconception or flaw in the understanding.
Can we use the term $U(1)$ gauge invariance for the free electromagnetic field? Let me explain why I ask this question.
Response to ACuriousMind's query As far as I know, gauge invariance is another name for local invariance, and free electromagnetic field is not a local gauge theory but QED is (I may be wrong!). In QED, where there is a fermion field $\psi(x)$, we demand local gauge invariance as $\psi(x)\to e^{i\theta(x)}\psi(x)$ where $e^{i\theta(x)}\in U(1)$. In case of a free electromagnetic field, I do not see any trace of the group $U(1)$. All I know is that the free Lagrangian is invariant under $A_\mu\to A_\mu+\partial_\mu\Lambda(x)$ but I fail to see any $U(1)$ group transformation property or any U(1) group element associated with this.