Social Security

Europe | Provisional agreement on revised rules on EU social security coordination

Summary

The Council of the European Union and the European Parliament have recently reached a provisional agreement on the long-awaited revision of the EU rules on social security coordination.

The reform is based on the original Commission proposal from 2016 and aims to modernise the existing framework under Regulation (EC) No 883/2004 in light of increasingly complex cross-border working patterns.

While the agreement is not yet final, it provides a clear indication of the direction of travel: greater clarity, stronger alignment between Member States, increased digitalisation, and enhanced enforcement across the EU.

The detail

The revision process has been ongoing since 2016, reflecting the need to adapt social security coordination rules to a significantly evolving labour market. In particular, developments such as:

• Increasing cross-border mobility
• Growth of remote work and telework arrangements
• More flexible and multi-state working patterns (“highly mobile workers”)
• Increased administrative complexity for authorities and employers has exposed limitations in the current framework.

The provisional agreement reached in April 2026 addresses several key areas of coordination, including:

• Applicable legislation (for posted workers and multi-state workers)
• Unemployment benefits
• Family benefits
• Access to benefits for economically inactive persons
• Long-term care benefits

The reform also places a strong focus on digitalisation and administrative cooperation. Discussions continue around enhanced electronic data exchange and broader use of digital processes and documentation to simplify and accelerate procedures for both employers and authorities.

For postings, discussions have focused on strengthening the link between the sending state and the worker, including reinforcement of minimum prior affiliation periods before a posting can begin. Current discussions also reference:

• 3 months prior affiliation before certain postings
• 2 months interruption periods between successive Article 12 postings now written into legislation
• Prior notification requirements for A1 applications, with exception of business trips outside of the construction industry, and trips of no more than 3 consecutive days over a period of 30 consecutive days
• ‘Replacing another person’ is not limited to one individual within a 24-month period (for example, if the first employee did not finish a project before departing from the host country, and is subsequently replaced for the remainder of the project).

For multi-state workers, additional clarification is expected regarding Article 13 situations, including confirmation of 24-month validity periods for A1 certificates and further guidance around the interpretation of the “registered office or place of business” of the employer.

In the area of unemployment benefits, the agreement reflects a trend towards stronger alignment between benefit entitlement and prior affiliation to the employment country, including minimum activity thresholds in certain cases.

Family benefits and healthcare coordination are also expected to be simplified, with a view to improving legal certainty in cross-border family situations and reducing administrative complexity.

Different implementation timelines and transition periods may also be expected between Member States, particularly for countries with large frontier worker populations and significant administrative volumes.

What this means

Although the final legal text is still pending, the agreement already highlights several important trends for employers and globally mobile employees:

• Increased clarity, but also stricter application of rules on applicable legislation (e.g. postings and multi-state working) and the need for prior notification.
• Increased digitalisation of social security coordination processes
• Closer link between benefits and actual work history, particularly in unemployment scenarios
• Simplification efforts, especially in family benefits and healthcare coordination

For organisations managing cross-border mobility, this reinforces the need to:

• Review existing mobility frameworks and policies
• Ensure robust tracking of cross-border activities, with specific distinctions between posted workers and multi-state workers
• Monitor developments around new administrative requirements (e.g. A1 requirement)
• Prepare for potential changes to posting eligibility requirements and administrative timelines, and where practical, adopting new practices now to prepare for these changes.

It is important to note that the provisional agreement still requires formal approval by both the European Parliament and the Council, following legal and linguistic finalization.

Outlook

The reform marks a significant step in the modernization of EU social security coordination, but key elements may still evolve during the final stages of the legislative process.

Given the long negotiation history and the complexity of the topics involved, further clarification at EU and national level is expected once the final text is adopted.

We will continue to monitor developments closely and provide updates as more detailed guidance becomes available. Given the volume of content amidst the changes, stay tuned for a series of more focused insights on each element, and how this will impact employers and their employees alike.

Council of the European Union – Press Release (29 April 2026)

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Alan McAllin
Director

Craig Smith
Senior Manager

Daniela Haller
Senior Manager

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