EU reform to simplify A1 certificate requirements for cross-border work

The EU's recent overhaul of regulations 883/2004 and 987/2009 aims to reduce administrative burdens for cross-border business activity while tightening oversight on long-term postings. According to analysis by professional services firm dhpg, the reform introduces specific exemptions from the mandatory A1 certificate—a document currently required for almost any work-related travel within the EU.

Under the new rules, A1 certificates and prior notifications will no longer be required for business trips that involve neither service provision nor goods delivery, such as conferences, seminars, or internal meetings. Furthermore, the reform introduces a 'three-day rule,' allowing for short-term operational tasks—such as technical visits or urgent project meetings—to be conducted without A1 documentation, provided they last no longer than three consecutive work days within a 30-day window. However, this exception explicitly excludes the construction sector, where stricter reporting remains in place due to historical risks of social security fraud.

While the reforms offer flexibility, they also impose stricter conditions on traditional long-term postings. Employers will face mandatory pre-departure filing requirements and a new 'pre-insurance' period, requiring employees to have been part of the home country’s social security system for at least three months prior to posting to prevent opportunistic hiring. Additionally, the reform limits chain postings, mandating a two-month break after the maximum 24-month posting period before a worker can be sent back to the same member state.

Businesses should note that these changes are not yet in effect. Implementation is expected approximately 24 months after the official publication of the regulation in the EU's Official Journal, with experts anticipating a practical start date around 2028. Until then, current reporting obligations for international assignments remain unchanged.