Provisional EU agreement changes the rules on the posting of workers

In April 2026, the European Union reached a provisional agreement on the modernisation of European social security rules, as set out in Regulation (EC) No 883/2004. Although the proposals have yet to be formally adopted, the new rules could potentially come into force as early as October 2026. For employers with internationally mobile workers, the changes could have significant implications for postings, business trips and the administrative obligations relating to social security.

New approach to A1 certificates

One of the most notable changes concerns the A1 certificate. For certain short-term assignments lasting up to three working days within a 30-day period. And for business trips, an A1 certificate would no longer be mandatory. Business trips must not involve any commercial activities.

For all other cross-border work, an A1 certificate is still recommended from the first day. The application must be submitted in advance and immediate proof of submission must be available. This requires tighter planning and administrative preparation by employers.

In addition, the conditions for the posting of workers are being tightened. Whereas workers are currently required to have been affiliated with the social security system of the sending country. For at least one month, it is proposed that this period be extended to three months.

Special attention for the construction sector

The exemption of up to three working days per month does not apply to all sectors. For the construction sector, it appears that the exemptions for very short-term assignments will not apply. This means that an A1 certificate will still be required even for short-term assignments abroad within the EU.

In practice, this will lead to a greater emphasis on timely applications and less scope for the ad hoc deployment of staff. Organisations in the construction sector would therefore be well advised to critically assess their current processes relating to secondments.

Greater responsibility for employers

Although some of the proposals are aimed at simplification, other changes actually introduce additional complexity. Employers will have to assess whether an exemption applies for each trip or posting, whilst at the same time ensuring that their records are complete and accurate.

In addition, it is expected that monitoring of compliance with social security rules within the EU will increase further. Other obligations, such as immigration rules, posting rules and tax regulations, also remain fully relevant.

What can you do now?

The final vote in the European Parliament is expected in July 2026. If the proposal is adopted without significant changes, the amended regulations could come into force as early as October 2026. A transition period of approximately two years is envisaged for various aspects.

For organisations that regularly deploy staff across borders, this is an opportune moment to look ahead. This includes reviewing travel, posting and mobility policies, identifying staff who may be affected by the changes, and analysing the impact on ongoing projects and client agreements.

Although the rules are not yet finalised, the direction seems clear. Timely preparation can help to mitigate future risks and administrative challenges.

Want to find out more?

Does your organisation deal with international secondments, business trips or cross-border employment? Please feel free to contact our specialists. We would be happy to advise you on the potential implications of the proposed changes and the design of future-proof processes.