Introduction
After almost 10 years of negotiations, the European Union has reached a provisional agreement (22 April 2026) to revise the long-standing rules governing the coordination of social security systems across Member States (Regulation (EC) No. 883/2004).
This reform reflects the significant evolution in cross-border working patterns, including increased mobility, business travel and remote working arrangements. The proposed changes aim to enhance legal certainty, strengthen enforcement, and modernise administrative processes.
While the agreement remains subject to formal adoption, employers should begin assessing the potential impact on their global mobility and payroll compliance frameworks. The final vote in the European Parliament is expected this July and if adopted without material change, we would see the revised Regulations in force as early as October 2026. A transitional period of 24 months can be expected for some elements.
Key points to note
A1 certificates and administrative requirements
- The introduction of targeted exemptions from A1 certificate requirements
- Outside the construction sector, an A1 certificate would not be required for short-term work of up to three working days within a 30-day period.
- An A1 certificate would not be required for business trips (newly defined) if the activity performed is not held to be commercial, e.g. no service is provided or no goods are supplied.
Aside from the above exemptions, an A1 posting certificate application (prior notification) would need to be submitted in advance, and the home authority must provide evidence of such submission immediately.
- Increased scrutiny from host authorities with emphasis on documentation.
Changes to posting rules (Article 12)
- Minimum of 3 months prior social security coverage in the home country
- Retention of the 24-month posting limit with refinements
- Stronger anti-abuse measures
Multi-state worker rules (Article 13)
- Continued reliance on A1 certificates
- Clarification for non-EU residents undertaking EU multi-state work
Broader changes to benefits coordination
- Updates to unemployment, family and long-term care benefits
- Aim to reduce double contributions and coverage gaps
UK considerations
At this stage, the EU’s proposed reforms to Regulation (EC) 883/2004 will have limited direct impact on the UK, because the UK–EU relationship is now governed by the Protocol on Social Security Coordination in the Trade and Cooperation Agreement (TCA). This is a separate, self contained regime. While being based on EU Principles of single state coverage, aggregation and exportability of benefits, the TCA does not replicate EU Regulations fully. The TCA is a bilateral agreement which has legislative authority in the UK and is governed by a joint UK/EU specialist committee.
For this reason, the proposed changes to EU Regulations will not have any automatic application to UK inbound and outbound workers. Coverage in these situations will continue under TCA rules. The result is that we will likely see increased divergence for Social Security cover and compliance for UK/EU mobility.
That said, the TCA can be updated or realigned to the EU position by renegotiation and amendments being made to the agreement. We will need to see what the political appetite is to enter into any such negotiation.
In the meantime, any changes which the EU introduces will increase the divergence for UK and EU mobility with employers needing to be aware of parallel frameworks in operation for EU internal and EU/UK Social Security rules.
Our view
This reform represents a significant update to EU social security coordination rules and signals a shift towards greater compliance and transparency.
While simplification measures such as A1 exemptions are welcome, employers should expect increased administrative obligations and compliance risk.
Key areas of focus include advance A1 requirements, tighter posting rules, and ongoing complexity for multi-state and remote working arrangements.
How Grant Thornton can help
Grant Thornton’s Employer Solutions team supports organisations in managing cross-border workforce risks and evolving compliance requirements.
We can assist with:
- Reviewing cross-border working arrangements
- Assessing A1 processes and governance frameworks
- Reviewing short-term business travel policies
- Implementing compliance frameworks and tracking processes
By taking early action, employers can reduce compliance risk and ensure readiness for the new EU requirements.
