Introduction
After almost 10 years of negotiations, the European Union has adopted revisions to the long-standing rules governing the coordination of social security systems across Member States (Regulation (EC) No. 883/2004).
Following the provisional agreement of 22 April 2026 and European Parliament approval in July 2026, the Council of the EU gave its final approval on 28 September 2026.
The revised Regulation will enter into force on the first day of the month following its publication in the Official Journal of the European Union. A transitional period of approximately 24 months is expected for many of the substantive provisions.
This reform reflects the significant evolution in cross-border working patterns, including increased mobility, business travel and remote working arrangements. The changes aim to enhance legal certainty, strengthen enforcement, and modernise administrative processes.
Employers should now assess the impact on their global mobility and payroll compliance frameworks.
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 will not be required for short-term work of up to three working days within a 30-day period.
- An A1 certificate will 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) will 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 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).
For this reason, the 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.
For ordinary UK-EU movements after the transition period, the TCA Protocol on Social Security Coordination remains the primary framework. Amendment of Regulations 883/2004 and 987/2009 at EU level does not, by itself, amend the TCA.
For individuals within the personal scope of the Withdrawal Agreement, EU coordination rules continue to apply in and to the UK. These cases must be identified separately and should not be processed as standard TCA cases.
Looking ahead – digitalisation
Separately, on 15 September 2026, the European Commission proposed a European Social Security Pass (ESSPASS). Under the proposals Social Security documents, including the A1, would be requested online and issued digitally for real-time verification across Member States. The proposals still need to be agreed by the European Parliament and the Council.
The Commission’s ESSPASS proposal would digitalise the request, issue, and cross-border verification aspects of social security applications, starting with the A1 process.
The proposal is relevant to the UK only subject to the applicable legal arrangements and does not itself alter applicable-law criteria.
The practical UK priority is therefore framework triage, robust evidence, linked certificate and payroll controls, and monitoring of both TCA governance and UK access to future ESSPASS arrangements.
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.
