June 25, 2026 – Grant Thornton has warned that Irish employers with staff with cross-border working arrangements such as business trips, remote working or work placements could face increased compliance obligations from as early as October 2026 due to proposed EU Social Security changes. The reforms are expected to affect a wide range of organisations whose employees regularly travel across EU member states.
The European Union has reached a provisional agreement to revise the long-standing rules governing the coordination of social security systems across Member States (Regulation (EC) No. 883/2004). The proposed reforms to the EU's social security coordination framework are designed to modernise rules that govern employees who work across multiple European States.
Among the proposed changes are enhanced requirements relating to A1 certificates., with a clear shift towards advance applications and stricter compliance. They also tighten the rules around employee postings and strengthen oversight of cross-border working arrangements, signalling a more robust enforcement environment.
Under the existing regime, many employers retrospectively seek A1 certificates after an employee has commenced duties in another EU State. The proposed reforms place greater emphasis on obtaining A1 certificates before cross-border work begins. While there will be some flexibility introduced such as a limited exemption for short business trips, employers will need to proactively ensure compliance and ensure appropriate controls are in place to track employee.
Considering the widespread and frequent movement of employees in industries such as construction, technology and professional services, many organisations will need to review their existing policies and compliance processes ahead of the potential October implementation date.
Commenting on the proposed changes, Clare Fitzgerald, Tax Director, Grant Thornton, said:
“How and where we work has drastically changed over the past number of years with more companies doing business internationally than ever before and people taking workations abroad, for example, in another EU State. While the proposed EU reforms introduce some welcome simplifications for short-term travel, they significantly raise the bar on compliance — employers will need much stronger processes around A1 management, and cross-border governance.
Employers should be looking at these proposed changes now, with a final vote expected in July and implementation possibly coming as early as October 2026. With increased use of technology and data-sharing by authorities, and growing divergence with the UK, the compliance environment is only getting more complex.
While reviewing policies may sound straightforward on paper, the reality is that timelines are tight — and many organisations risk being caught off guard during the summer period. The message is clear: don’t sleepwalk into an administrative headache this autumn.”
ENDS
