On 7 July 2026, the European Parliament approved the long-awaited revision of the European Union’s social security coordination rules contained in Regulations (EC) No. 883/2004 and 987/2009. The revised legislation modernises the existing framework to reflect today’s increasingly international labour market, where remote working, cross-border employment and international assignments have become commonplace.
Although the fundamental principle remains unchanged—that an individual should generally be subject to the social security legislation of only one Member State at a time—the revised rules introduce a number of important changes for employers and internationally mobile employees.
The most significant amendments include:
Extended prior insurance requirement for posted workers
Under the current rules, an employee must generally have been subject to the social security legislation of the sending Member State for at least one month before being posted abroad. This period will be extended to three months. The objective is to strengthen the genuine connection between the employee and the sending country and to reduce abusive posting arrangements.
Mandatory A1 application before the assignment starts
Employers will be required to apply for an A1 certificate before an employee commences work in another Member State. While many employers already obtain the certificate in advance, this requirement will become considerably stricter. Proper planning of international assignments will therefore become even more important.
Greater legal certainty for multi-state workers
The revised Regulation provides clearer rules for employees who work simultaneously in two or more Member States. This is particularly relevant for hybrid workers, international commuters, consultants and executives who regularly perform work across borders.
The amendments also clarify the position of third-country nationals legally residing and working within the European Union, creating greater consistency in the application of the coordination rules throughout the EU.
What does this mean for employers?
Although most organisations will not need to make immediate changes, employers with internationally mobile workforces should start reviewing their assignment policies and compliance procedures well before the new rules become applicable.
Particular attention should be given to:
• the timing of A1 applications;
• planning international secondments;
• reviewing posting procedures;
• assessing employees who work in multiple Member States; and
• ensuring adequate documentation demonstrating compliance with the revised requirements.
The majority of the amendments are expected to become applicable approximately 24 months after the revised Regulation enters into force, meaning that most changes are anticipated to apply from around July 2028.
At Migrantic, we closely monitor developments in European social security legislation and advise employers, payroll departments and internationally mobile employees on the practical consequences of these changes. Early preparation will help organisations avoid compliance risks, unexpected social security liabilities and delays in obtaining the required certificates.