Important Updates
Important Updates
May 14, 2026 | United KingdomUnited Kingdom: Children Can Now Use Passport E-Gates
May 15, 2026 | AustraliaAustralia: Federal Budget for 2026-27 Released
May 15, 2026 | ChileChile: Expedited Business Visa Implemented for Indian Nationals
May 15, 2026Fragomen Wins 2026 FEM Americas EMMAs for Outstanding Agility & Crisis Management and Thought Leadership
May 15, 2026 | RomaniaRomania: New Unified Work Permit System and Online System Implemented
May 14, 2026 | United KingdomUnited Kingdom: Children Can Now Use Passport E-Gates
May 15, 2026 | AustraliaAustralia: Federal Budget for 2026-27 Released
May 15, 2026 | ChileChile: Expedited Business Visa Implemented for Indian Nationals
May 15, 2026Fragomen Wins 2026 FEM Americas EMMAs for Outstanding Agility & Crisis Management and Thought Leadership
May 15, 2026 | RomaniaRomania: New Unified Work Permit System and Online System Implemented
May 14, 2026 | United KingdomUnited Kingdom: Children Can Now Use Passport E-Gates
Subscribe
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 InsightsVietnamese ImmigrationView 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
  • Vietnamese Immigration
  • 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
  • Insights

Understanding Posted Worker Notifications and A1s: The Importance of Compliance

November 22, 2023

EU flags

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Harry Goldstraw

What is the Posted Worker Directive?

The Posted Worker Directive (PWD) is an EU law that applies to workers temporarily sent to work in an EU country. It is designed to ensure that these workers enjoy basic work-related rights and protections when working in an EU host country, such as minimum wages, hours worked and entitlement to holidays. It ensures that posted workers are treated fairly during their assignments while also protecting the host country’s labour market.

A key element of the PWD framework is the administrative obligation on employers to submit a notification to the host country authorities—known as Posted Worker Notifications (PWN)—before commencing work and to ensure relevant employment-related documents are on file for each posted worker.

The rules differ across the various member states, which can cause issues for companies that may struggle to stay compliant.

Why is this important?

Employers need to consider a wide range of factors when posting employees on short-term assignments. It is no longer sufficient to solely look at work permit/visa requirements when reviewing a secondment or even a business visit; PWN requirements must be assessed on a country-specific basis.

In some countries, the PWN and immigration processes have been combined. In many countries, PWNs are linked to social security compliance through Certificates of Coverage (or A1s as they are known in Europe).

While the PWD is designed to create a level playing field, the information required, language and filing processes varying significantly across countries add a degree of complexity. Therefore, a ‘one size fits all’ approach is not sufficient due to the fragmented system across countries.

Even when issued, some PWNs can be restricted to a specific travel pattern or assignment dates. As such, if these change, due to delays in visa processing or business requirements, an updated or even new PWN may be required with updated supporting documents.

Increased risks of non-compliance

With increased digitisation across government bodies, the ability of government departments both nationality and internationally to share data on travellers is increasing. By sharing data between immigration, tax and social security departments, it is easier for governments to look for non-compliance in breaching salary and employment protections, late or unfiled PWNs and inconsistent document retention at company or client locations.

Additionally, the European Labour Authority launched the Posting 360 Programme in March 2023, aiming at strengthening cooperation between the labour and social security authorities of EU Member states to ensure compliance with posted worker rules.

The increase in posted worker inspections has led to an increase in authorities issuing penalties to employers.

Financial penalties vary depending on country and severity of non-compliance but can range from €70 EUR to €225,000 EUR. In some instances, unlimited fines can be issued so consequences can be significant. 

There are also significant reputational risks associated with non-compliance. There have been instances of country authorities alerting the national press of non-compliance, creating not only a regulatory risk, but a much broader risk impacting a company’s reputation both nationally and internationally.

In some countries, an immigration ban and/or suspension can be imposed on the sending company, limiting its ability to send workers to the country to deliver on client projects or work between offices.

The risks for non-compliance also include late filings. Some authorities monitor PWN applications and if they notice a trend in late or retrospective filing, an audit of a company can be triggered.

Key takeaways

Whilst PWN can seem like a straightforward concept, in practice, the filing and document retention requirements can differ greatly from country to country, so companies need to think strategically when designing a business travel programme.

Whilst visa and work permit requirements are frequently considered ahead of travel, PWNs and A1 assessments need to be aligned with the immigration review, knowing what documents are needed and when to ensure travellers are compliant.

Compliance is key, and Fragomen can help companies coordinate their relocation, tax and labour departments under the umbrella of the firm’s immigration/global mobility services to provide a single solution covering all areas of immigration, PWN and social security compliance.

In addition to the practical compliance services, Fragomen offers advisory support, working with companies to design policies and helping with multijurisdictional assessments to advise on which country offers the best solution--not just from a visa perspective, but also considering the wider PWN and administrative compliance.

Need to know more?

For further information on the varied requirements for PWNs or questions related to ensuring employees can work in EU countries, reach out to the Fragomen Consulting Europe team at [email protected].

This blog was published on 22 November 2023, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, X, Facebook and Instagram.

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Photo of Harry Goldstraw

Harry Goldstraw

Senior Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0)207 090 9299

Related offices

  • Fragomen in London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Awards

Fragomen Wins 2026 FEM Americas EMMAs for Outstanding Agility & Crisis Management and Thought Leadership

Fragomen is recognized with multiple honors at the 2026 FEM Americas EMMAs, including Outstanding Agility & Crisis Management as a Service Provider and Thought Leadership – Best Survey or Research Study of the Year for the Worldwide Immigration Trends Report 2026.

Learn more

Blog post

Housing Market Dynamics in Saudi Arabia: Policy Changes, Rent Stabilization and Cost of Living Implications for Employers

Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.

Learn more

Visas

German Visa Risks: What Past Unauthorised Employment Means for Your Visa Application

Manager Dr. Adela Schmidt explains how German authorities assess past travel and business activities and why suspected unauthorized work during prior visits can lead to visa refusals and temporary entry bans.

Learn more

Podcast

Why Strategy Matters Now: Inside the Center for Strategy and Applied Insights

Partner Cosmina Morariu and Senior Director Leah Rogal discuss the mission of Fragomen’s Center for Strategy and Applied Insights and how it helps organizations and governments navigate evolving immigration policy and global talent mobility challenges.

Learn more

Fragomen news

Fragomen and Papaya Global Launch Strategic Partnership to Streamline Global Mobility and Compliance

Fragomen and Papaya Global announce a strategic partnership combining workforce technology and immigration capabilities to help organizations simplify global mobility, enhance compliance and manage cross-border workforces through a more integrated, technology-enabled approach.

Learn more

Video

Understanding Immigration in Latin America: Residency Options and Citizenship Pathways

Latin America & the Caribbean Managing Partner Leonor Echeverria explores how Latin America’s evolving immigration landscape offers accessible and flexible residence pathways for foreign nationals, highlighting key visa options, regional trends and the growing role of digital modernization across the region.

Learn more

Podcast

Reality Check Pt. 2: Immigration Law in Pop Culture

Senior Associate Stephanie Weaver and Associate Julia Manacher continue their discussion on immigration law in popular culture, examining how television and media portray immigration processes and the realities behind common immigration storylines.

Learn more

Media mentions

Bloomberg: Trump Wants to Make H-1B Workers More Expensive for US Employers

Partner Kevin Miner discusses how proposed H-1B salary threshold increases may raise employer costs and influence hiring strategies for specialized talent across industries.

Learn more

Video

Portugal Extends Citizenship Timeline | #MobilityMinute

In this Mobility Minute, Manager Pierangelo D’Errico discusses Portugal’s newly approved nationality law changes and the potential impact on Golden Visa applicants and other foreign residents.

Learn more

Media mentions

Global Mobility Lawyer: AI Use in UK Immigration Tribunals Prompts Scrutiny Over Decision-Making Process

Partner Rajiv Naik highlights the importance of transparency, clear guidance and human oversight as AI use expands in UK immigration tribunals.

Learn more

Video

Europe’s Entry and Exit System (EES): What Travelers Need to Know

Senior Associate Tuğba Özyakup outlines how Europe’s Entry and Exit System (EES) introduces digital tracking of non-EU short-stay travel across the Schengen Area, requiring more proactive planning, accurate record-keeping and awareness of increased border processing times to avoid delays and overstay risks.

Learn more

Fragomen news

2026年4月 アメリカ移民法ダイジェストLearn more

Awards

Fragomen Wins 2026 FEM Americas EMMAs for Outstanding Agility & Crisis Management and Thought Leadership

Fragomen is recognized with multiple honors at the 2026 FEM Americas EMMAs, including Outstanding Agility & Crisis Management as a Service Provider and Thought Leadership – Best Survey or Research Study of the Year for the Worldwide Immigration Trends Report 2026.

Learn more

Blog post

Housing Market Dynamics in Saudi Arabia: Policy Changes, Rent Stabilization and Cost of Living Implications for Employers

Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.

Learn more

Visas

German Visa Risks: What Past Unauthorised Employment Means for Your Visa Application

Manager Dr. Adela Schmidt explains how German authorities assess past travel and business activities and why suspected unauthorized work during prior visits can lead to visa refusals and temporary entry bans.

Learn more

Podcast

Why Strategy Matters Now: Inside the Center for Strategy and Applied Insights

Partner Cosmina Morariu and Senior Director Leah Rogal discuss the mission of Fragomen’s Center for Strategy and Applied Insights and how it helps organizations and governments navigate evolving immigration policy and global talent mobility challenges.

Learn more

Fragomen news

Fragomen and Papaya Global Launch Strategic Partnership to Streamline Global Mobility and Compliance

Fragomen and Papaya Global announce a strategic partnership combining workforce technology and immigration capabilities to help organizations simplify global mobility, enhance compliance and manage cross-border workforces through a more integrated, technology-enabled approach.

Learn more

Video

Understanding Immigration in Latin America: Residency Options and Citizenship Pathways

Latin America & the Caribbean Managing Partner Leonor Echeverria explores how Latin America’s evolving immigration landscape offers accessible and flexible residence pathways for foreign nationals, highlighting key visa options, regional trends and the growing role of digital modernization across the region.

Learn more

Podcast

Reality Check Pt. 2: Immigration Law in Pop Culture

Senior Associate Stephanie Weaver and Associate Julia Manacher continue their discussion on immigration law in popular culture, examining how television and media portray immigration processes and the realities behind common immigration storylines.

Learn more

Media mentions

Bloomberg: Trump Wants to Make H-1B Workers More Expensive for US Employers

Partner Kevin Miner discusses how proposed H-1B salary threshold increases may raise employer costs and influence hiring strategies for specialized talent across industries.

Learn more

Video

Portugal Extends Citizenship Timeline | #MobilityMinute

In this Mobility Minute, Manager Pierangelo D’Errico discusses Portugal’s newly approved nationality law changes and the potential impact on Golden Visa applicants and other foreign residents.

Learn more

Media mentions

Global Mobility Lawyer: AI Use in UK Immigration Tribunals Prompts Scrutiny Over Decision-Making Process

Partner Rajiv Naik highlights the importance of transparency, clear guidance and human oversight as AI use expands in UK immigration tribunals.

Learn more

Video

Europe’s Entry and Exit System (EES): What Travelers Need to Know

Senior Associate Tuğba Özyakup outlines how Europe’s Entry and Exit System (EES) introduces digital tracking of non-EU short-stay travel across the Schengen Area, requiring more proactive planning, accurate record-keeping and awareness of increased border processing times to avoid delays and overstay risks.

Learn more

Fragomen news

2026年4月 アメリカ移民法ダイジェストLearn more

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.