EU Reform of A1 Requirements: What Changes for Business Trips and Short Cross-Border Assignments

After nearly ten years of negotiation, the Council of the EU and the European Parliament reached a compromise text in April 2026 to reform Regulations (EC) No 883/2004 and 987/2009. The reform brings a range of changes to the coordination of social security systems, and one is particularly relevant for employers: new, clearly defined exemptions from the A1 requirement.

The status quo: Today, every cross-border activity requires an A1

Currently, Article 15 of Regulation (EC) 987/2009 requires prior notification to the competent social security institution, and therefore an A1 certificate, as soon as an employee carries out work in another EU/EEA country or in Switzerland. There is no explicit statutory exemption for short stays or business travel.

In practice, this has caused considerable legal uncertainty. While some Member States took a lenient approach to one-day business meetings, others strictly required an A1 for every short activity. Employers caught without an A1, for example during an inspection in France or Austria, faced fines, double contributions, and reputational damage.

What is changing

The compromise text introduces, for the first time, two explicit statutory exemptions from the A1 requirement.

Exemption 1: Business trips

The term "business trip" is now legally defined in Article 1(2)(eb) of Regulation 987/2009. Covered are temporary activities in the business interest of the employer, such as business meetings, conferences, seminars, cultural and scientific events, and receiving training.

These trips will be fully exempt from the A1 requirement, with no time limit. A two-week internal conference in Lisbon, for example, would no longer require notification.

Exemption 2: The 3-day rule

For activities that do not qualify as a business trip, a second exemption applies: cross-border assignments of no more than three consecutive working days within a period of 30 consecutive days are also exempt from the prior notification requirement.

There is one exception. Activities in the construction sector remain subject to the prior notification requirement from day one. The new Annex 6 of Regulation 987/2009 defines the construction sector very broadly.

Before vs. after: What changes in practice

Today, even a five-day conference in Berlin requires an A1. Under the new rules, the same conference would be fully exempt as a business trip. A two-day client visit in Paris currently triggers the notification requirement, but would in future fall under the 3-day rule. By contrast, a one-week client project in Vienna remains A1-required, since it neither qualifies as a business trip nor stays within the three-day window. Training attended by an employee in Madrid will no longer require notification, while construction work in Munich continues to need an A1 from day one, regardless of duration.

Practical pitfall: Business trip or posting?

The decisive issue lies in the distinction. The legal definition explicitly excludes two activities from the business-trip concept: the provision of services and the delivery of goods.

This means that as soon as an employee provides a service to a third party abroad, the activity does not qualify as a business trip, even if it is just a one-day appointment. The 3-day rule may then still apply; otherwise, the full A1 obligation remains.

The distinction can be subtle and must be assessed case by case.

When will the new rules apply?

The new rules will not apply immediately. The current compromise text still needs to be confirmed by the Committee of Permanent Representatives (COREPER), formally adopted by the European Parliament and the Council, and published in the Official Journal of the EU.

According to Article 3 of the Regulation, the A1-relevant provisions (Art. 15 of Regulation 987/2009) will then apply only 24 months after entry into force. Realistically, application can be expected in 2028 at the earliest.

Vamoz supports the transition

We are following the reform and will update our compliance logic to match the new categories. Our platform already classifies travel by type (Business Trips, Cross-border, Workations), which means employers will not have to rebuild their workflows when the new rules take effect. Our A1 Automation solution will be adjusted accordingly.

As soon as the regulation is published in the Official Journal, we will report in detail on the exact application date and the final implementing rules.