Social Security & the A1 Certificate

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. For employees, the employer files the application, not you. Since January 1, 2025, it 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. Agree on the workation with your employer early so the A1 is applied for before you leave.

Applies to the EU, EEA, Switzerland, and the United Kingdom
Proves: German social security law still applies despite working abroad
For employees, the employer files the application
Electronic filing only since Jan 1, 2025 (software or SV-Meldeportal)
Always have it applied for before departure
No de minimis threshold: an A1 is intended even for a one-week workation

Workations: posting or exception agreement

For a time-limited workation in the EU, EEA, Switzerland, or the UK, there are two ways to stay in the German system. The standard route is posting (Entsendung) under Art. 12 of Regulation (EC) 883/2004: you temporarily work abroad for your German employer, for at most 24 months, and your health insurance fund issues the A1 (for privately insured people, the pension insurance does). If posting does not fit, for example because the workation is not in the employer's interest or conditions are missing, employer and employee can apply for an exception agreement under Art. 16 of Regulation 883/2004, which the DVKA negotiates with the other state. The DVKA explicitly assigns workations to these rules, not to the framework agreement on telework.

Standard route: posting under Art. 12 Reg. 883/2004, up to 24 months
The A1 is issued by your health insurance fund, for privately insured people by the pension insurance
Otherwise: exception agreement under Art. 16 Reg. 883/2004 via the DVKA
Apply before departure and allow for processing time

The framework agreement on telework does not cover workations

Since July 1, 2023, a multilateral framework agreement on cross-border telework has been in place. It is meant for cross-border workers who regularly work from home in their country of residence for an employer in another state: under certain conditions they may perform up to 49.99% of their working time in their country of residence without losing the social security coverage of the employer's country. A workation is something else, namely temporary work from a country where you do not live. According to the DVKA, the framework agreement does not apply to that. For workations, the A1 certificate via posting or an exception agreement remains the route (see above). The agreement applies only between the more than 20 signatory states, runs for five years, and can be extended once.

Governs regular cross-border telework from the country of residence below 50%
Does not apply to workations, i.e. temporary work from another country
For workations: A1 via posting (Art. 12) or an exception agreement (Art. 16)
In force since July 1, 2023, 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. They do not cover every branch, though: the German-US agreement covers pension insurance only — for health insurance, the US is effectively a country with no agreement. 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 (US: pension insurance only)
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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