On 15 September 2026 the European Commission adopted its Fair Labour Mobility package: a Communication and five legislative proposals aimed at the paperwork that slows down cross-border work in the EU. For employers that post staff, the headline item is the A1 certificate. Under the proposal, the A1 becomes the first social security document to go fully digital, issued online and held in the EU Digital Identity Wallet, where labour inspectors can verify it in seconds.
None of this is law yet. The proposals now go to the European Parliament and the Council. But the direction is clear, and it changes what inspectors will expect to see on site.
What the Commission Proposed
The package contains five proposals:
- A Regulation establishing a European Social Security Pass (ESSPASS). People could request and receive social security documents online, including the portable document A1 and the European Health Insurance Card, and store them in the EU Digital Identity Wallet.
- A Skills Portability Act. Qualifications would be issued in a standard digital format, backed by a free EU tool for comparing qualifications across member states.
- A Regulation strengthening the European Labour Authority (ELA). The ELA would get risk-assessment tools to help national inspectorates target controls, plus national inspection liaison officers. Its mandate would also cover abuse of third-country nationals and illegal employment.
- An amending Directive on professional qualifications. Recognition in regulated professions would move to a mandatory digital procedure, with a target of five weeks instead of the current three months.
- A Directive on qualifications of third-country nationals. Common EU standards for recognising qualifications gained outside the EU would cut average processing from 14 months to 4. The Commission says this could halve the administrative cost of hiring for employers.
The rollout is staged:
- Digital A1 for posted workers — 1 year after the ESSPASS Regulation enters into force.
- EHIC and other social security documents — Within 3 years.
- Simpler recognition of non-EU qualifications — Within 2 years of adoption.
- Digital qualifications in the EU wallet — Within 3 years.
- Expanded ELA powers — Improvements expected 2028–2030.
The Commission puts the benefit of the whole package at an estimated €5 billion by 2040. It also estimates that digital documents could save businesses up to €64 million, and labour inspectors €72 million, over 12 years through faster cross-border checks.
What This Means for HR and Mobility Teams
The paper A1 process still applies. The clock for the digital A1 starts one year after the ESSPASS Regulation enters into force, not from this announcement. Any posting planned for 2027 should assume today's national application routes and today's processing times, which in some member states run to several weeks.
Enforcement is moving faster than the paperwork. A stronger ELA that runs risk assessments for national inspectorates means posting-heavy sectors will be targeted more precisely. A digital A1 is quick to verify, and so is a missing one. The revised social security coordination rules agreed this year already tighten prior-affiliation requirements for posted workers. This package adds the tools to check them.
Non-EU hiring could get shorter at the credential stage. For employers recruiting engineers, nurses or other regulated professionals from outside the EU, qualification recognition is often the slowest step before a work permit can even be filed. A four-month standard would change project timelines. It depends on a directive that member states still have to transpose, so plan on current timelines for now.
Digital credentials need a digital process behind them. Once A1s and qualifications sit in a wallet, employers will need to know which assignee holds which document, when it expires, and whether it matches the posting. Spreadsheets and email chains will not hold up to an inspection built around instant verification.
Action Steps
- Audit every active posting now and confirm each worker holds a valid A1 that matches the current assignment dates and host country.
- Build current A1 lead times into 2027 assignment plans. Do not assume the digital version will be available.
- Map which non-EU hires in your pipeline need qualification recognition, and track them separately from the permit filing.
- Centralise posting records (A1s, posting notifications, contract dates) in one system so evidence can be produced on the day of an inspection.
- Watch the Parliament's first readings. Scope and deadlines can change before adoption.
How xpath.global Supports Posted Worker Compliance
xpath.global handles A1 certificate applications, posting notifications and diploma recognition for highly skilled workers, ICT transferees and secondees, with Romania as a core execution market and programme management across Europe. Every case runs through the xpath.global platform, so the document status, expiry date and posting details for each assignee sit in one place, ready to produce whether an inspector asks for paper or a QR code. Speak to our team at https://xpath.global/contact.
"Sources: European Commission, DG Employment, Social Affairs and Inclusion, "Commission proposes ambitious measures to strengthen fair labour mobility" — 15 September 2026."
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