The EU's revised social security coordination rules entered into force on 1 November 2026. But that does not mean every new A1 and posting requirement applies today: most operational changes are scheduled for November 2028.
For HR teams, the immediate opportunity is to review the handoffs between mobility, payroll, tax, travel and local teams, before future requirements create last-minute friction.
The timing that matters
| When | What it means |
|---|---|
| 1 November 2026: in force | The revised regulation (Regulation (EU) 2026/2359) is in force. Review the existing A1 process and the assignment data behind it. |
| 1 November 2028: main rollout | Most of the updated rules start to apply, including those on applicable legislation and prior notification of postings. |
The Parliament adopted the text on 7 July 2026 and the Council on 28 September 2026. The Commission's own summary says most of the revised rules apply two years after entry into force. Until then, plan around today's A1 practice and confirm the position with the national institution in each country.
What the revised rules say for postings
These points come from the Commission's description of the reform. They apply from November 2028, not today.
- Prior affiliation: a worker must have been affiliated to the home-country social security system for at least three months before being posted.
- Cooling-off period: after 24 months of posting, there must be a break of at least two months.
- Notification first: postings must be notified before they happen, apart from business trips.
- Short postings: no notification is needed for postings of a maximum of three days, in all sectors except construction.
The construction exception matters for project teams. A three-day posting to a construction site needs notification. A three-day posting in most other sectors does not.
One future portal for posting declarations
On 20 October 2026, the European Parliament adopted its first-reading position on a public interface, connected to the Internal Market Information System, for declaring the posting of workers. The vote was 558 to 93, with 18 abstentions.
It is not live yet. A Member State that chooses to use it must tell the Commission at least six months before it starts. The interface would be free of charge, data would be kept for a maximum of 36 months after the posting ends, and Member States would not add further requirements for companies that use it. Which countries join, and when, is still open.
What this means for HR and mobility teams
Three checks are worth making now, while nothing is urgent.
1. Classify the move early
A business trip, a cross-border service posting and a local hire do not trigger the same work-permission or social security checks. If the label is wrong at the start, every later filing is wrong too.
2. Know who owns each filing
Align immigration, A1, posting declarations, payroll and the actual worksite before a start date is confirmed. A three-month prior-affiliation test and a notify-first rule both need the right person to act before the employee travels.
3. Build a reusable evidence trail
Keep the employment structure, dates, social security status and filing responsibilities attached to the same assignment. Because notification comes before the posting, these facts are needed before the employee starts.
Action steps
- Pull a list of current postings and assignments across the EU and check each one's start date, end date and home-country affiliation history.
- Flag any posting that is approaching 24 months, or that has been extended in the past.
- Map who files the A1 and the posting declaration today, and who signs off the start date.
- Review your short-trip rules for construction and site-based work.
- Revisit the process in 2027, once Member States say whether they will use the posting portal.
For a practical walk-through of the earlier reform steps, see our related guides:
xpath.global coordinates work authorisation, tax and social security, relocation, employment support and local delivery around each move. You keep policy and budget control, and we give the process one accountable owner and your team a clear view of the next action.
Work authorisation, tax and social security, relocation and employment support — coordinated around each move, with one accountable owner.
Discuss a move or programmeSources: European Commission, "Updated EU rules on social security coordination enter into force" — 1 November 2026; European Parliament Legislative Observatory, procedure 2024/0301(COD) — 20 October 2026. Dates and transition periods can change; confirm the position with the national institution in each country before acting.
