• Insights

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

June 24, 2026

Countries / Territories

  • European UnionEuropean Union
  • BelgiumBelgium

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Jo Antoons, Marina Ocariz

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.  

 

 

 

 

 

 

Countries / Territories

  • European UnionEuropean Union
  • BelgiumBelgium

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.