/ /
A1 Certificates for the EU, EEA, and Switzerland
This article provides an overview of the A1 Certificate.
Overview
What is the A1 Certificate of Coverage?
The A1 Certificate of Coverage is a social security document that states the European member state under which worker is covered by social insurance.
What is the purpose of the A1 Certificate?
The A1 certificate requirement is used to support the coordination of social security systems among member states. Residents of the European Union, European Economic Area (Iceland, Norway, and Liechtenstein), and Switzerland have the right to move freely across member states and work. In light of this, the European Commission has issued regulations to support social security coordination among member states. These regulations ensure that an individual can only be covered by one member state’s social security system at a time. The A1 certificate requirement is part of those regulations.
The A1 certificates ensure that when an employee changes work location temporarily, their social security liability will not be affected and both the employer and employee will remain covered by the home state’s social security system. So the employer and employee will not need to pay social security insurance contributions in the host state. And the employee remains covered by their home state’s social security system and retains their social security rights and benefits there.
When is an A1 Certificate required?
The A1 certificate is required in all EU countries, EEA countries, and Switzerland in situations where an individual who resides in one member state is temporarily working in or on a business trip to another state.
Are A1 Certificates required for short business trips?
The EU regulations do not provide any minimum duration under which there can be a waiver of the A1 certificate requirement. This means that in principle, the current EU regulations do not differentiate between shorter business trips and longer-term postings.
The EU has released guidance stating that temporary workers who don’t provide services on their business trips (for example those attending conferences, meetings, trainings, etc) may not require an A1 certificate. However, despite this guidance, some individual member states interpret the regulations more strictly than others. So it is advisable that employers apply for the A1 for short business trips, especially if the host country specifically requires it and is known for strict enforcement.
A1 Certificate Application Process
When should the Application be made?
It is recommended that when possible, the application for the A1 certificate be submitted well in advance of the intended date of travel. This is because the amount of time it takes to receive the A1 certificate varies by country. And it is best practice for the individual to have the A1 certificate available at the start of the work activity in the host country.
Once an application is received, the relevant social security institution will verify whether the individual is currently covered by the home state’s social security system. Once ready, the A1 certificate is issued by the social security institution.
What are the Eligibility Requirements?
The employee must be registered with the social security institution of their home state in the period before they are sent to the host state.
The employer must regularly operate in the territory of the home state.
There should be an employment relationship between the employer and the employee throughout the duration of the time the employee remains in the host state.
How is the Application made?
The employer is usually responsible for applying for the A1 certificate on behalf of the employee through the home state’s social security institution. In many states the applications can be done online via the designated online portal. In other states the application can be done either in person or through the mail.
Once ready, the A1 certificate will be sent to the applicant either through email, through download in the designated portal, or by mail.
A1 Certificate Validity
The A1 certificate is valid until the expiration date listed in the document or until it is withdrawn by the issuing institution. The maximum period of validity is 24 months. If the individual stays longer, they must either switch to the host country’s social security system or apply for an extension. This extension can be obtained with the consent of the social security institutions of both the host state and home state.
Brexit Considerations
Work that Started after 1 January 2021
The UK-EU Trade and Co-operation Agreement sets out the details of the Social Security coordination rules to be applied between the EU states and the UK from 1 January 2021. The agreement is similar to the current EU social security coordination regulations. A1 certificates can be applied for to confirm the employee will remain covered by the home country social security system. However, there are some differences:
One difference is that the maximum period is 24 months with no extensions possible whereas previously extensions were possible.
The EEA states (Norway, Iceland, Lichtenstein) and Switzerland are not covered by this new agreement between the EU and the UK. The new rules for cross border work between the UK and these countries will be as follows:
Norway: Employees can remain covered by the home country for temporary postings of up to 3 years. A certificate should be obtained from the home location to confirm this. (Must apply within 4 months of the start of the posting)
Switzerland: Employees can remain covered by the home country for temporary postings of up to 2 years. A certificate should be obtained from the home location to confirm this.
Iceland: Employees remain covered by the home country for temporary postings of up to 12 months. A certificate should be obtained from the home location to confirm this. The certificate can be extended by a further 12 months provided this is obtained prior to the end of the first 12 months of the assignment.
Lichtenstein: No existing agreement is in place and the situation will need to be considered on a case-by-case basis. There is the possibility of double contributions. Postings from the UK will need to continue paying UK National Insurance contributions for the first 52 weeks.
The UK is working to create a new agreement on social security coordination with the EEA states and Switzerland. However, until then the rules outlined above will apply which are based on the old bilateral agreements that are in place.
How Strictly is the A1 Certificate Requirement Enforced?
Enforcement Varies by Member State
Member states vary in their interpretation and application of the EU regulations that an employee needs an A1 certificate to work temporarily in another state. In general, local authorities hold the employer responsible for applying for the A1 certificate before the employee’s trip. The employer is also responsible for the certificate’s continued availability for workplace inspections in the host country whenever required. Employees should also be able to provide an A1 certificate on request by foreign authorities so they should carry it at all times. Some member states go further and require that the employer present the A1 certificate on the first day of the employee’s work.
If the individual has not yet received the A1 certificate before they are meant to start work, the labour inspectorates in some countries will also accept the receipt demonstrating the application has been submitted. If the receipt is not accepted, the employer should contact the home country authorities to see whether they can prioritise the application.
Even if the authorities in the host state do not request to see the certificate, the employer’s end clients in the host state may request the posted worker to present an A1 certificate before coming to their work site.
It should be noted that several countries are very strict in their enforcement of the A1 certificate requirement. Four member states that are known to enforce the requirement quite heavily are France, Austria, Luxembourg and Switzerland.
Consequences for Violations
Fines: If the employer cannot provide an A1 certificate during an inspection the employer can be subject to costly fines (between EUR 1,000 and up to EUR 10,000). The fine can either be imposed on the employer itself or in some cases imposed on the employer’s end client in the host country.
Access to Social Security Benefits: Without the certificate, the worker risks facing difficulties trying to access social insurance benefits such as health care. For example, if an employee is injured at work in the host country, a dispute can arise as to which state’s insurance system bears the obligation. Also, if the worker needs medical assistance in the host country, without an A1 certificate, the worker may have trouble accessing medical assistance in foreign hospitals.
Unforeseen Claims: The employer may be obligated to pay social security contributions in the host state.
Denial of Entry: Local authorities in the host country may use the lack of an A1 certificate to deny a worker access to the country, to the workplace, or to business events. They could also require them to stop working entirely.
Reputation Damage: The employer risks receiving the status of an illegal employer.
Frequently Asked Questions
What if the A1 Certificate is not issued in the time for the employee's trip?
In the case of electronically submitted applications, the employer will usually receive a confirmation of the application, which the employee can use as proof of the application. It is also recommended that the employee also have proof of their social insurance registration (pay slips, an earlier A1 certificate, etc). These can then be presented to authorities in the host state if needed until the actual A1 certificate is issued.
A1 Certificate Country Specific Information
Austria
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made to the relevant Austrian health insurance organisation through ELDA website: Online Portal
Documents required:
Processing time:
Host Country Application Process & Timeline
Enforcement: Strict enforcement
Fines up to EUR 10,000.
The Austrian financial police are increasingly present at trade fairs and similar events and are checking whether employees from abroad have the A1 certificate.
Special Considerations:
In the case of posted workers, the employer is required to notify the Austrian Central Coordinating Agency Charged with Investigating Illegal Employment ((Zentrale Koordinationsstelle für die Kontrolle der illegalen Beschäftigung, ZKO). Postings must be reported via an online portal before starting work in Austria: Online Portal
Austrian law provides for an exemption from the A1 Certificate requirement for the performance of work of a minor extent and short duration, such as a business meeting or for participation in seminars and lectures or at congresses. However, these work assignments are only exempted if they are not followed by further work.
Belgium
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made ONSS via the WABRO portal: Online Portal
Documents required:
Processing time: The authorities will send the certificate by email, within an average of 4 working days.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
In addition to obtaining an A1 certificate, in the case of posted workers, it is also obligatory that the employer inform the authorities in Belgium about the work beforehand. The Employer must do this by filling in the Limosa declaration via the Limosa online service at www.limosa.be
Bulgaria
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the National Revenue Agency (NRA) in person or by mail.
Documents required:
History of the company with a turnover statement of at least 4 months to prove that the company is operational (12 months if it is a newly registered company, and for at least 4 months there should be a turnover statement).
Documents certifying that company has hired staff, of which at least 25% will remain on the territory of Bulgaria after the posting.
Copy of business trip orders.
A copy of the contract with the foreign company under which the employees are seconded.
Contract for completed transactions and invoices.
Accounting policy, a brief presentation of the company's activities or a letter from the manager about its activities and what it will do abroad with the signature and seal of the company.
Processing time: The NRA will issue the certificate within an average of 30 working days.
Home Country Application Process & Timeline
Enforcement:
Special Considerations:
Croatia
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Croatian Pension Insurance Institute. The application form with attachments is sent by mail to the Croatian Pension Insurance Institute.
Documents required:
Employment contract
Proof of the reason why the worker is sent to the country (contract or agreement of the company and the foreign company).
Processing time: The authorities will send the certificate by email, within an average of 4 working days.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Republic of Cyprus
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Social Insurance Office of the relevant district.
Documents required:
Processing time:
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Czech Republic
Home Country Application Process & Timeline
Who applies: Employer
Channel: Joint application is made by the employer and employee through the local District Social Security Administration.
Documents required:
A certified copy of the employment contract.
A certified copy of the certificate of jurisdiction issued by the foreign institution, if such a certificate was issued in relation to the period of the application.
A certified copy of the contractual documents on the basis of which the activity is ensured in the Czech Republic (if the activity is performed there) and abroad.
Affidavit of a foreign employer (attached to the application for exemption from jurisdiction under foreign legislation, if the applicant has a foreign employer).
Processing time:
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Denmark
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Udbetaling Danmark portal: Online Portal
Documents required:
Employment contract
Processing time: The process can take up to 5 weeks.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Estonia
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Social Insurance Board via the EESTI portal: Online Portal
Documents required:
Processing time: If the application for an A1 Certificate is submitted electronically on the state portal, authorities will issue the A1 Certificate within the next working day.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Finland
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Finnish Centre for Pensions via the eServices portal: Online Portal
As a rule, the employer should apply for the certificate before the departure. However, the A1 certificate can also be granted in retrospect, for a period of work abroad that has already begun.
Documents required:
Processing time:
3 weeks; if the solution does not require contacting a foreign authority.
4 months; if contact with a foreign authority is required to resolve the matter.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
France
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the applicable insurance scheme. If the employee is affiliated with France’s general scheme, the application will be done through the local health insurance fund (CPAM): Online Portal
If they are affiliated with the agricultural scheme, the application will be done through the MSA: Online Portal
The worker must have been affiliated to the French social security scheme for at least 1 month before the posting starts.
Documents required:
Processing time: The delivery times vary from one primary health insurance fund to another.
Host Country Application Process & Timeline
Enforcement: Strict enforcement
Fines are up to EUR 3,300.
Failure to produce an A1 Certificate in France can result in penalties as follows:
For employers based outside France: Can face an administrative fine for each posted employee.
For the employer’s clients within France: Can be liable for a penalty for each worker found to be in violation. This penalty cannot be applied if the A1 Certificate application is produced during the inspection. The certificate then must be shown in the two months following the inspection.
Special Considerations:
Germany
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made electronically via the employer’s certified payroll program. If the employer, does not have a certified payroll accounting program, they can submit the electronic application online: Online Portal
Documents required:
Processing time: The A1 Certificate is issued within three working days.
Host Country Application Process & Timeline
Enforcement:
Special Considerations: In the case of posted employees, it is obligatory that employers inform the authorities in Germany about the work beforehand. Employers can do this via the Zoll website: Online Portal
Employers sending employees to Germany for business trips on short notice or for business travel up to one week are not required to obtain an A1 Certificate prior to the employee’s travel. Instead, they can obtain the A1 Certificate retrospectively if needed, i.e. after the employee has started their activities in Germany.
Greece
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the relevant Section of Insurance and Contributions at the EFKA regional Division to which they belong.
Documents required:
Processing time:
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Hungary
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made in writing from the relevant health insurance institution based on the employer's registered office.
Documents required:
Processing time: The health insurance body shall assess the employer's application within 8 days of the submission of the application in a summary procedure and within 60 days in a full procedure.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Iceland
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Documents required:
Processing time:
Host Country Application Process & Timeline
Enforcement:
Special Considerations: In the case of posted workers, it is required that they submit the A1 certificate obtained from their home state to the Icelandic Social Insurance Administration (Tryggingastofnun).
A1 Certificates can be submitted by e-mail to tr@tr.is or by mail to Tryggingastofnun, Laugavegur 114, 105 Reykjavík.
Ireland
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is submitted to the Department of Employment Affairs and Social Protection (The International Postings Section). The employer is to send the completed application form to:
International Postings
Client Eligibility Services
Department of Social Protection
Cork Road, Waterford, X91 EH04
Documents required:
Processing time:
Italy
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Application is made through the Italian Social Security Institution (‘INPS’) through an online portal: Online Portal
Once available, a copy of the A1 Certificate will be sent to the applicant via PEC or e-mail. If the original copy is required, the certificate will be available for collection at the local INPS office.
Documents required:
Processing time: 30 working days.
Host Country Application Process & Timeline
Enforcement:
Special Considerations:
Latvia
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made in person through the local branch of the State Social Insurance Agency (SSA).
Applications should preferably be submitted at least 4 weeks before starting operations in another country. If it is necessary to receive an A1 Certificate expeditiously, it has to be indicated in the application.
Documents required:
Application form
Copies of the company's contracts (contracts for the sale of services and goods) certifying the performance of a significant economic activity in Latvia. To be submitted at the choice of the employer.
Processing time: The SSA will issue the certificate within 22 working days of receipt of the request.
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Liechtenstein
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations: The posting must be reported before the start of the deployment in Liechtenstein via the Electronic Registration System (EMS).
For the entire duration of the posting, the following documents must be carried with the worker at all times or be available in another way and must be shown to the control bodies on request:
ID or passport
Employment contract (or other equivalent document) in German
Agreements on posting allowances and expense allowances in German
Form A1 (or other equivalent document), issued by the responsible person Social security agencies
Lithuania
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Foreign Benefits Service of the State Social Insurance Fund Board (Sodra) via the electronic policyholder service system: Online Portal
Documents required:
A certified copy of the employee's identity document (if the person being posted or hired is not a citizen of the Republic of Lithuania)
An employer's questionnaire
Sender's questionnaire
Documents proving the employer's activity in Lithuania and abroad, ie:
A certified copy of the service contract with the host company;
A certified copy of the employment contract with the posted or hired employee;
Certified copies of agreements concluded with natural or legal persons regarding the performance of activities in Lithuania and abroad.
Processing time: 20 working days from the date of receipt of all documents.
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Luxembourg
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Centre Commun de la Sécurité Sociale (CCSS) [Joint Social Security Centre] via SECUline: Online Portal
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement: Strict enforcement
Fines are up to EUR 10,000
Special Considerations:
Malta
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made by completing and submitting form online: Online Portal
Documents required:
Employer questionnaire (Only applicable for posted employees)
Processing time: 31 working days
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Netherlands
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Dutch Social Insurance Bank (Sociale Verzekeringsbank or SVB) online via TWinternet: ****Online Portal
Documents required:
Processing time: One week
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Norway
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Norwegian National Insurance Authorities (NAV): Online Portal
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Poland
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Application is made online through the Social Insurance Institution ZUS (Zakład Ubezpieczeń Społecznych) via the Electronic Services Platform (PUE): Online Portal
Once available, the A1 certificate can be obtained at any local ZUS branch in paper format or in its digital format through the ZUS PUE portal.
Documents required:
Processing time: If all required information is submitted, A1 Certificate is issued immediately. If it is necessary to conduct an explanatory procedure, they will issue the A1 Certificate no later than within one month. In particularly complicated cases, it will be issued no later than two months after submitting the application.
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Portugal
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Application is made through the Social Security Direct portal: ****Online Portal
Once available, the A1 certificate will be sent to the message box on the Social Security Direct portal.
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Romania
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the National House of Public Pensions either in person or by mail.
Documents required:
Company registration certificate;
Fiscal attestation certificate;
Certificates from the Territorial Labor Inspectorate, respectively statement on the own responsibility of the employer's legal representative, showing the total number of employees;
Certificate stating the employer's situation, issued for the current month;
Current financial statements of the applicant in Romania;
Declaration on the employer's own responsibility to certify the turnover achieved by him in Romania and that achieved by him on the territory of the other Member State, in the last year, respectively from the date of establishment;
Commercial contracts implemented on the Romanian territory prior to the period for which the attestation of the applicable legislation is requested;
Commercial contracts to be implemented on the Romanian territory during the period for which the attestation of the applicable legislation is requested;
The contract / pre-contract concluded between the Romanian employer and the employer in the state of employment, as well as the authorized translation;
Monthly declaration D112 (Annex 1.1 and Annex 1.2);
The Romanian identity card / identity card of the employee (s);
The individual employment contract of the employee (s);
Certificate regarding the contribution period completed in the last 12 months;
Declaration on the employer's own responsibility attesting to the possible periods for which the persons for whom A1 portable documents are requested have benefited from forms E 101 and E 102, portable documents A1.
Processing time: The A1 Certificate will be issued within 25 working days from the date when the completed application was submitted.
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Slovakia
Home Country Application Process & Timeline
Who applies: Employer
Channel:
Application is made through the relevant branch of the Social Insurance Agency.
The completed application should be printed, signed and mailed or delivered in person to the relevant branch office of the Social insurance Agency.
Once available, the A1 Certificate will be sent to the employer or employee.
The Branch Office of the Social Insurance Agency should be notified in writing of any changes that occur during a posting within 10 days.
Documents required:
Photocopy of the employer's contract with a foreign entity to perform work in another Member State of the European Union, (another relevant document proving the place of temporary work of the employee, if the contract does not specify the place of temporary work of the employee).
Photocopy of the employment contract or agreement.
Processing time: Maximum of 45 days
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Slovenia
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the Slovenian Insurance Office (ZZZS) via the SPOT portal: Online Portal
Application can also be made by mail.
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Spain
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through the local “Tesorería General de la Seguridad Social”
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Sweden
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made to the Försäkringskassan by mail.
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations: A1 certificate should be sent to the Swedish Tax Office for approval. Once approved, the employer and employee are exempt from paying social contribution in Sweden.
For posted workers, it is also obligatory that the employer inform the authorities in Sweden about the work beforehand. This should be done via the website of the Swedish Work Environment Authority. It is not required to do this if the employee works less than 5 days in total in Sweden.
Switzerland
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made through a web application: Online Portal
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement: Strict enforcement
Special Considerations:
United Kingdom
Home Country Application Process & Timeline
Who applies: Employer
Channel: Application is made to HMRC through a web application: Online Portal
Documents required:
Processing time:
Host Country Enforcement & Other Considerations
Enforcement:
Special Considerations:
Was this article helpful?