New EU Social Security Coordination Rules: What Employers Need to Know

On 22 April 2026, the European Union reached a provisional agreement on the revision of the rules coordinating national social security systems for people moving across borders in the EU. This revision follows more than 10 years of negotiations since the European Commission first presented its proposal and represents a significant development for employers with a mobile workforce across the EU.

The revised framework aims to support fair labour mobility, reduce legal uncertainty for businesses operating cross-border, strengthen the protection of employees’ social security rights and facilitate digitalisation and enforcement, including cooperation and exchange of information between EU Member States.  

Key Areas Covered by the Revision

• • • Unemployment benefits
    • Long-term care benefits
    • Access to welfare benefits for economically inactive persons
    • Family benefits; and
    • The determination of applicable national social security legislation for posted workers and individuals working in two or more Member States.

Key Changes Employers Should Note

For organisations managing international assignments or frequent cross-border activities, the provisional agreement introduces several important changes:  

Extended prior affiliation requirement for postings

Employees must now be affiliated to the social security system of the sending state for at least three months before they can become eligible for an A1 certificate and remain subject to their home social security scheme during the posting.  This replaces the current one-month requirement.

Mandatory “cooling-off” period after postings

Following a 24-month posting, a mandatory two-month cooling-off period must be observed before the same employee can be posted again to the same EU Member State or the employee can be replaced. This cooling-off period does not prevent employer from applying for an exceptional agreement that enables an A1 certificate valid for up to five years.

Changes to A1 certificates for multi-state workers

A1 certificates for multi-state workers can be requested for a period of 24 months (subject to renewal), based on the projected travel patterns across the EU for the following 12 calendar months. Non-EU residents are deemed to have their residency for the determination of the applicable national security scheme in the EU Member State where they perform most of their activities.

Application for A1 certificates prior to the posting

Applications for an A1 certificate must be submitted before the start of the posting. Where certificates are not issued automatically, authorities must provide an automatic acknowledgement of receipt, which will serve as proof that the application has been made.

Limited exemption for short-term activities

An exemption from filing an A1 application applies for business trips and short-term activities lasting no more than three consecutive working days within a 30-day period. This last exemption does not apply to the construction .

These changes significantly reduce flexibility and increase the need for advance planning and stricter internal compliance processes.

What Does This Mean for Employers?

The revised rules will require employers to reassess how they manage postings, business travel, and multi-state working arrangements.

First, the extended three-month prior affiliation requirement will mean that
companies will need to assess prior affiliation to the sending state’s social security system for at least three months before they post employees to another EU Member State immediately after hiring them.  

In addition, the notification requirement – effectively the submission of the A1 application for temporary postings – should be completed in advance. This represents a stricter approach than what is currently applied and enforced in many Member States.

Although the provisional agreement introduces an exemption for business trips and short-term activities lasting no more than three consecutive working days within a 30-day period, this simplification remains limited. Most business travellers and short-term assignments will still require an A1 certificate, therefore this proposed exemption may be seen insufficient. Furthermore, it is unclear at this time how employers would be able to monitor compliance with the 30-day period.

The proposal introduces a definition of “business trip” as a temporary activity carried out in the employer’s interest, excluding the provision of services or delivery of goods. Covered activities include attending business meetings, conferences, cultural or scientific events and training. However, how this definition will be interpreted in practice may vary significantly between Member States, generating legal ambiguity and compliance risks for employers.

Additionally, if the A1 has not yet been issued, employers must provide to the competent institution of the Member State in which the activity is taking place, either the acknowledgement of receipt, or proof that exemption applies. At this stage, however, there is no clarity on the format or documentation that will be accepted as proof of exemption, creating additional compliance

Overall, the proposed revision introduces stricter compliance requirements and reduces flexibility for managing cross-border work with the EU. Employers will need to plan assignments and business travel more carefully, ensure A1 applications are submitted on time, and maintain clear documentation to demonstrate compliance.

Next Steps

The provisional agreement must now be formally adopted by both the European Parliament and the Council before the revised rules can enter into force. The rules are expected to be adopted in July and to enter into force in September 2026. The revised above-mentioned rules for posted and multistate workers are expected to take effect after a transitional period of 24 months.

How can Fragomen Help?

Fragomen Consulting Europe (FCE) can assist clients in managing their A1 certificate compliance program in line with the revised EU social security rules. Through a comprehensive compliance approach, FCE helps employers anticipate social security, immigration and posted worker obligations early in the planning process, reducing risk and operational disruption.  

Need to Know More?

For more information about EU social security coordination changes and their impact on short-term and business travel compliance, please contact Fragomen Consulting Europe at [email protected].  

This blog was published on 24 June 2026 and and reflects information available at that time. Updates may occur as policies evolve. To stay informed on the latest immigration news and analysis, please subscribe to our alerts and follow Fragomen on  LinkedIn, Facebook and Instagram.