Ina Ree­se Tax & Legal Prac­ti­ce – Flens­burg | Harrislee

A1 certificate: What will change for postings abroad from 2028 onwards

From 2028, the A1 cer­ti­fi­ca­te requi­re­ment will no lon­ger app­ly to short busi­ness trips of up to three days. Howe­ver, stric­ter rules will app­ly to genui­ne postings. 
A1 certificate: What will change for postings abroad from 2028 onwards

A1 certificate: What will change for postings abroad from 2028 onwards

Anyo­ne who sends employees abroad on a tem­po­ra­ry basis or who works across bor­ders them­sel­ves is fami­li­ar with the pro­ce­du­re: befo­re any peri­od of work abroad, an ‘A1 cer­ti­fi­ca­te’ must be appli­ed for. This con­firms that the employee remains sub­ject to Ger­man social secu­ri­ty legis­la­ti­on and is not sub­ject to com­pul­so­ry social secu­ri­ty con­tri­bu­ti­ons in the coun­try whe­re they are working. Until now, this requi­re­ment has had to be met wit­hout excep­ti­on, even for short busi­ness trips. That is set to change.

The EU is reforming the coordination of social security systems

In April 2026, the Euro­pean Par­lia­ment and the Coun­cil rea­ched a pro­vi­sio­nal agree­ment on a revi­si­on of the EU regu­la­ti­ons on the coor­di­na­ti­on of social secu­ri­ty. Spe­ci­fi­cal­ly, this con­cerns Regu­la­ti­ons (EC) No 883/2004 and No 987/2009, which have not been sub­stan­ti­al­ly amen­ded sin­ce they came into force in 2010. The for­mal decis­i­on is still pen­ding. Fol­lo­wing a 24-month tran­si­ti­on peri­od, the majo­ri­ty of the new pro­vi­si­ons are expec­ted to come into force in 2028.

Convenience for short business trips

One of the most prac­ti­cal chan­ges con­cerns short busi­ness trips. In future, an A1 cer­ti­fi­ca­te will no lon­ger be requi­red if the work car­ri­ed out abroad lasts for a maxi­mum of three working days within a 30-day peri­od. For com­pa­nies that regu­lar­ly send staff abroad for mee­tings, trade fairs or cli­ent visits, this repres­ents a signi­fi­cant sim­pli­fi­ca­ti­on. The con­s­truc­tion indus­try is exempt from this rela­xa­ti­on, as it is sub­ject to its own rules.

Stricter requirements for genuine postings

Anyo­ne who posts workers abroad for exten­ded peri­ods will have to com­ply with stric­ter requi­re­ments in future.

  • Three months’ pri­or insu­rance cover: The employee to be pos­ted must have been cover­ed by social secu­ri­ty in the coun­try of pos­ting – in this case, Ger­ma­ny – for at least three months pri­or to the start of the pos­ting. This results in addi­tio­nal plan­ning work for new recruits who are due to be pos­ted abroad.
  • Repea­ted second­ment to the same coun­try: A worker may only be pos­ted to the same coun­try again if the­re is a break of more than two months bet­ween postings.
  • Refund in the event of ear­ly ter­mi­na­ti­on: If an employee is unable to com­ple­te their second­ment, ano­ther employee may take over the role. The total dura­ti­on of the second­ment must not exceed 24 calen­dar months.

Multiple employment in different countries

Workers who usual­ly work in seve­ral EU Mem­ber Sta­tes have, until now, had the appli­ca­ble natio­nal law deter­mi­ned for an inde­fi­ni­te peri­od. In future, this deter­mi­na­ti­on will only app­ly for 24 months and must then be review­ed and con­firm­ed again. This appli­es, for exam­p­le, to cross-bor­der workers or tho­se employ­ed in long-distance transport.

What does this mean for businesses in practice?

For small and medi­um-sized enter­pri­ses that occa­sio­nal­ly post staff to other Euro­pean count­ries, the chan­ges bring both sim­pli­fi­ca­ti­ons and new obli­ga­ti­ons. The rem­oval of the A1 requi­re­ment for short busi­ness trips signi­fi­cant­ly redu­ces the admi­nis­tra­ti­ve bur­den. At the same time, the three-month pri­or insu­rance rule will in future requi­re ear­lier staff plan­ning for inter­na­tio­nal projects.

The new regu­la­ti­ons will initi­al­ly app­ly only within the EU. Sepa­ra­te agree­ments are requi­red for the Euro­pean Eco­no­mic Area, Switz­er­land and the United King­dom. The­re is still time to prepa­re befo­re the reform comes ful­ly into force. Anyo­ne who is alre­a­dy plan­ning to work abroad or has ques­ti­ons about the cor­rect hand­ling of the A1 cer­ti­fi­ca­te should keep an eye on deve­lo­p­ments and, if in doubt, seek legal or tax advice.

Source: Hau­fe: Tax

This artic­le was crea­ted with the help of AI and has been edi­to­ri­al­ly reviewed.

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