Social Security

European Union | EU reforms social security coordination including business travel

Summary

On 28 September 2026, the Council of the European Union formally adopted the long-awaited revision of Regulations (EC) No 883/2004 and No 987/2009 on the coordination of social security systems. The reform focuses on the rules for postings and activities pursued in two or more Member States, as well as unemployment, long-term care, welfare, and family benefits by making the legislation easier and fairer to enforce.

The detail

The EU Social Security reform is now agreed and final. Whilst an immediate change to systems and processes is not currently required, companies should start assessing the potential impact of the reform on existing processes for A1 certificates, business travel, posted workers and multi-state activities. The UK has a separate Social Security framework since Brexit so the changes below should not be automatically applied to EU/UK cases. For the EEA and Switzerland, the reform will only apply once it has been formally incorporated into the EEA Agreement and the EU-Swiss agreement, respectively; the timing may therefore differ from the EU timetable.

Some of the key changes with direct impact on employers can be found below:

Prior notification requirements

• For postings under Article 12, the employer must generally notify the competent institution of the sending Member State in advance. No prior notification is required for qualifying business trips or for short-term postings of no more than three consecutive working days within a period of 30 consecutive days, except in the construction sector.
• Automatic acknowledgement must be provided by the authorities as proof of notification. Member States may impose sanctions on employers who fail to notify them ahead of posting. Late notification, however, does not change the applicable legislation, and an A1 can be issued retrospectively.

Changes to postings

• The minimum period of prior affiliation to the sending Member State’s social security system will increase from one month to three months for a posting under Article 12.
• Requirement of 2 months ‘reset’ before a new posting can commence with an A1 being applicable.
• The replacement rule has been clarified so that successive workers may not be used to keep the same position under the posting rules for more than an aggregate period of 24 months.

Changes to Multi-State working

• The reform also contains clearer statutory criteria for activities pursued in two or more EU member states, providing more clarity on what should be considered to establish the determination of the employer’s place of business, and consequently the country of applicable Social Security legislation
• For persons working in two or more Member States, an initial A1 certificate may be issued for a period of up to 24 months and may be renewed where the underlying circumstances continue to apply. Open-ended, and initial certificates of longer duration will no longer be applicable.
• Non-EU residents working in two or more EU member states are deemed to be resident in the member state where the majority of their EU working time is carried out.

Changes to Business Travel

• The new coordination rules, for the first time, defines a business trip as a temporary time-limited activity related to the employer’s business, excluding provision of services or delivery of goods, but including meetings, conferences, seminars, cultural and scientific events, and receiving training.
• Business trips, as defined above, would not require an A1 certificate.
• Short activities lasting no more than 3 consecutive days within a period of 30 consecutive days also do not require an A1 certificate.

What this means 

The reformed regulations will now be published in the Official Journal of the European Union and therefore will enter into force. For the key changes concerning postings, cross-border activities in multiple member states, as well as the associated A1 procedures, a transition period of 24 months will apply from such date.

Employers and authorities will have a two-year preparation period to review existing A1’s, business travel and processes to adapt to the new requirements.

The reform may lead to significant administrative simplifications, particularly short-term cross border activities, but it is important that employers are prepared for when the new changes come into effect. In respect of business trips, whilst the paperwork administrative step may disappear for some employees, the need to analyze and review the working arrangements of their business travelers remains paramount to ensure the conditions are met.

 

Contact us

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

Alan McAllin
Director – UK

Craig Smith
Senior Manager – UK

Natalia Graf
Director – Switzerland

Ulrich Buschermöhle
Director – Germany

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