Social security comes down to one question: which system applies during your workation — the German one or the destination country's? Within the EU/EEA, Switzerland, and the UK, there are clear coordination rules and a clean proof document, the A1 certificate (A1-Bescheinigung). In a country with no such agreement, this mechanism is missing, and in the worst case you risk paying contributions twice. This guide explains what you and your employer need to clarify before the trip.
The A1 certificate: your proof within the EU
The A1 certificate documents to the authorities of the country you're working in that German social security law continues to apply despite working abroad. It is relevant for assignments in the EU, the EEA, Switzerland, and the United Kingdom. Since January 1, 2025, applications must be filed electronically without exception — via certified payroll software or the SV-Meldeportal (the German social security reporting portal). Paper or fax are no longer accepted. Always apply for the A1 before you leave.
- Applies to the EU, EEA, Switzerland, and the United Kingdom
- Proves: German social security law still applies despite working abroad
- Electronic filing only since Jan 1, 2025 (software or SV-Meldeportal)
- Always apply before departure
The Framework Agreement on telework (since July 2023)
Since July 1, 2023, a multilateral framework agreement on cross-border telework has been in place. Under certain conditions, it allows up to 49.99% of total working time to be performed as telework in your home country without losing the social security coverage of your employer's country. There is an often-overlooked lower threshold: the agreement only applies from 25% telework in the home country upward — below that, the normal coordination rules apply. It applies only between the more than 20 states that have signed on, runs for five years, and can be extended once.
- Up to 49.99% telework in the home country without changing social security coverage
- A 25% floor — below that, the normal coordination rules apply
- In force since July 1, 2023, valid for 5 years, extendable once
- Applies only between the signatory states (more than 20)
Countries without an agreement: proceed with caution
For states with no EU coordination and no bilateral social security agreement — a country with no agreement — no certificate confirming continued application of German law is issued. German "radiating effect" (Ausstrahlung) under § 4 SGB IV (Book IV of the Social Code) can still apply in principle, but it does not protect you from the destination country also demanding contributions. Countries with no agreement include Mexico, Thailand, Indonesia, Costa Rica, and the UAE, among others. The US and Canada, by contrast, have bilateral agreements with their own posting rules. The UK is a special case: not a classic agreement, but coordination through the EU-UK Trade and Cooperation Agreement, under which A1 certificates continue to be issued.
- No agreement → no certificate: includes Mexico, Thailand, Indonesia, Costa Rica, UAE
- US and Canada: bilateral agreements with their own posting rules
- UK: a special case — coordinated via the EU-UK agreement, A1 still available
- "Radiating effect" (§ 4 SGB IV) does not protect against local contribution obligations — clarify the case with the DVKA (the German liaison body for health insurance abroad)
Sources
Verified, mostly official sources. Reflects the state of research as of the writing date — please double-check with the source directly before making important decisions.
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