A1 certificate: when you need one and who issues it in DACH

An A1 certificate (portable document A1, PD A1) is the EU form that states which country’s social-security legislation applies to a worker who is active in another EU, EEA or Swiss state. It is issued by the social-security institution of the country whose law continues to apply and is used for postings under Article 12 of Regulation (EC) No 883/2004, work in several states under Article 13 and individual exceptions under Article 16. In Germany the issuer is typically the Krankenkasse, the Rentenversicherung or the DVKA, in Austria the health insurer via ELDA, and in Switzerland the AHV compensation office via ALPS.

Quick answer

What does an A1 certificate actually certify?

The A1 is a “statement of applicable legislation”, according to Your Europe. It tells the authorities of the other state that the holder stays in the home social-security system and that contributions are due only there. The FSIO makes the same point: the A1 certifies which national law applies and that contributions are owed only in the issuing country.

The Commission’s FAQ adds that the document names the employer, the posting period and the continued application of the sending state’s law. It binds the institution of the host state as long as it has not been withdrawn or declared invalid (Article 5(1) of Regulation 987/2009). Since 1 November 2026, Article 19(3) of Regulation 987/2009, as inserted by Regulation (EU) 2026/2359, requires an institution asked for such an attestation to assess the relevant facts and confirm that the information in it is correct.

In short, it is a social-security document. The DVKA and the FSIO both note that the procedure concerns social security only, not tax. The sources reviewed do not describe the A1 as a permit, so work permits, residence rules, income tax and permanent establishment need separate checks. On the last point see permanent establishment and remote employees.

When do you need an A1 for a posting or a business trip?

For a posting, Article 12(1) of Regulation 883/2004 keeps an employee in the sending state’s system “provided that the anticipated duration of such work does not exceed 24 months and that he/she is not sent to replace another posted person” (wording as amended by Regulation (EU) No 465/2012). Your Europe says the employer requests the A1 and that the maximum period on it is 24 months. Austria’s USP adds conditions, including one month of coverage under Austrian law immediately before the posting. From 2 November 2028, Regulation (EU) 2026/2359 replaces Article 12 and Article 14(1) of Regulation 987/2009: a person recruited with a view to being sent must then have been subject to the sending state’s law for at least three months immediately before the employment starts.

Business trips are the grey area. The Commission’s practical guide (2019 version) says trips to conferences, meetings, fairs or training are not postings under the Posting of Workers Directives. It then states that for social-security coordination the employer must notify the home state, whenever possible in advance, and obtain a PD A1 for every cross-border work activity, “even if only of short duration”, and that the regulations contain no exception for business trips. A footnote adds that the business-trip formalities were under discussion in 2019.

That discussion has since produced Regulation (EU) 2026/2359, published in the Official Journal on 27 October 2026 and in force since 1 November 2026. Its new Article 15(1b) of Regulation 987/2009 provides that the duty to inform the competent institution and request the attestation does not apply to business trips, nor, outside the construction sector, to activities of no more than three consecutive working days within 30 consecutive days. A business trip is defined as a temporary activity related to the employer’s business interests that excludes providing services or delivering goods but includes meetings, conferences, seminars and training. Under the amended application dates these provisions apply only from 2 November 2028, so the rules described above remain the current ones until then. How and when the changes take effect for Switzerland and the EEA states has not been checked.

Practice differs by country:

• Germany: for short service or business trips of up to seven days the A1 can be requested afterwards if needed, according to the Deutsche Rentenversicherung. For France, Austria and Switzerland it recommends applying in advance. This is a timing option, not an exemption.
• Switzerland: the FSIO’s 2019 answer notes that no rule sets a minimum period below which an A1 is unnecessary, even for a few hours. It considered advance applications for very short one-off trips disproportionate in most cases, except where sanctions apply (it names France and Austria), and says regular short trips should be assessed as work in several states.

Because that FSIO paper is from 2019, confirm the current position with the issuing body.

What if the employee works in several countries?

Under Article 13(1) of Regulation 883/2004, as amended by Regulation (EU) No 465/2012, a person who normally works in two or more Member States is subject to the law of the residence state if a substantial part of the activity is pursued there. If not, a person with one employer is subject to the law of the state of that employer’s registered office or place of business; separate rules cover several employers. Article 14(8) of Regulation 987/2009 describes a substantial part as a quantitatively substantial part, not necessarily the major part, judged by working time and/or remuneration, and treats a share below 25 percent as an indicator that no substantial part is pursued. The DVKA applies 25 percent of working time and/or pay as its threshold and describes habitual work as recurring at least one day a month or five days a quarter.

The person or employer first informs the institution of the residence state, which makes a provisional determination that becomes definitive after two months unless another institution objects (Article 16 of Regulation 987/2009). For people living in Germany, the application goes through the electronic A1 procedure to the DVKA at the GKV-Spitzenverband. For people living elsewhere, the residence-state institution decides. The Deutsche Rentenversicherung says one A1 for habitual work in several states can be issued for up to five years for all Member States, so one per trip is not needed.

Which countries does the A1 cover?

The Commission states that the coordination rules apply across the EU and in Iceland, Liechtenstein, Norway and Switzerland. The United Kingdom is handled differently: “specific coordination rules” apply under the EU-UK Trade and Cooperation Agreement. The DVKA says postings from 1 January 2021 follow that agreement, with an expected maximum of 24 months, and that an A1 continues to be issued for a transitional period. Austria’s USP notes that since Brexit no exception agreements are possible with the UK. For UK procedure see the UK hiring guide.

Nationality can also matter. The Deutsche Rentenversicherung says a German A1 for a posting to Switzerland is available only to EU and Swiss nationals and rejects applications for, for example, Norwegian or Turkish nationals; within the EU alone, nationality does not matter for people lawfully resident in a Member State. The FSIO’s 2019 paper likewise places third-country nationals outside the A1 between Switzerland and the EU, Iceland, Liechtenstein and Norway. Check nationality and residence before relying on an A1.

Who issues the A1 in Germany, Austria and Switzerland?

Germany

The competent body depends on how the person is insured. The Deutsche Rentenversicherung assigns statutory health insurance to the Krankenkasse, privately insured members of a professional pension scheme to the ABV, and other privately insured persons to the pension insurance carrier. The DVKA states that all A1 applications must be made electronically since 1 January 2025, and § 106(1) SGB IV requires the employer to transmit the application from a system-tested program or with a system-tested electronic form aid. The DVKA also says home office or mobile work abroad for the German employer may qualify as a posting if the other conditions are met. The three-working-day period in § 106 runs from the finding that German law applies, so do not treat it as a turnaround guarantee.

Austria

The USP says applications for the posting certificate are made exclusively via ELDA. The ÖGK says individual Article 16 exception applications for EU, EEA and Swiss cases go to the ministry (BMASGPK). Self-employed people use the SVS, which states that a posting is limited to 24 months without extension.

Switzerland

The FSIO says employers apply to their AHV compensation office through ALPS, which issues the A1 for up to 24 months if the conditions are met. If 24 months are not enough, the employer applies through ALPS and the FSIO seeks an exception agreement with the host authority; the FSIO states that under Swiss practice this happens only if the total posting does not exceed 5 to 6 years. This route is the Swiss counterpart to an Austrian posting into Switzerland or a Swiss posting into Germany.

How does the cross-border telework framework work?

The framework agreement on cross-border telework entered into force on 1 July 2023. According to the Belgian depositary page, Germany, Austria and Switzerland are all signatories as of 1 July 2023, with the DVKA, the Dachverband and the FSIO named as their competent bodies. The list changes, so check that both the residence state and the employer’s state are signatories.

The main conditions:

• The employee lives in a different state from the employer’s seat and teleworks from the residence state for 25 percent to under 50 percent of total working time (the FSIO gives 25 to 49.9 percent), with the consent of employer and employee.
• The employer applies to the competent body of the state whose law should apply: the DVKA electronically in Germany, the Dachverband in Austria (the Austrian health insurer then issues the PD A1) and the compensation office via ALPS in Switzerland.
• An agreement runs for up to three years and can be renewed on a new application. Retroactive application of up to three months is possible; the DVKA and the Dachverband tie this to contributions already paid in their country.
• The framework concerns social security only. Cases outside it, such as telework of 50 percent or more, need an individual Article 16 application, in Austria to the ministry.

Article 16 agreements are discretionary. The DVKA says they are generally concluded for periods of up to five years, with an extension of up to three more years possible in justified cases.

What happens if an employee works abroad without an A1?

The sources describe several consequences, but none quantifies a general penalty. The Commission’s FAQ says the absence of an A1 does not itself prevent a posting, although the employer must still prove that the posting conditions are met. The FSIO’s 2019 paper adds that Swiss law applies from departure when posting conditions are met even without the form, and that the A1 can be issued retroactively.

The practical risk is inspection. The same 2019 paper states that France and Austria provide administrative sanctions and fines if the A1 cannot be shown, with none if a prior application can be proven. The USP says a foreign employer posting into Austria must keep registration documents such as the A1 at the Austrian workplace and that violations lead to penalties. The USP’s wage and social dumping page lists fines of up to 20,000 euro for missing posting documents, but it does not say which line applies to a missing A1, so do not assume a specific amount. Your Europe adds that after 24 months the employer can ask the issuer for an extension, which is not granted automatically, or move the employee into the host state’s system, after which the person is no longer a posted worker under the coordination rules.

What does this mean for your hiring model?

The A1 keeps an employee in the home social-security system for a defined period. If the person is meant to live abroad permanently, work mostly in the host state or stay beyond 24 months, the question shifts from paperwork to the hiring model. Compare direct employment, a local entity, a genuine contractor and an Employer of Record in the decision guide, and for contractors read the note on false self-employment.

For the wider planning questions see the guides for hiring in the EU from Germany, Austria and Switzerland.

Key terms

Employee

A worker engaged under a local employment contract, with the employer responsible for payroll, social security contributions and compliance with local labour law.

Employer of Record (EOR)

A third-party provider that legally employs a worker on behalf of a client company in a country where the client has no local entity, handling local payroll, contracts and compliance.

Permanent establishment

A tax concept describing a fixed place of business or sufficient business activity in a country that can trigger local corporate tax obligations for a foreign company.

Final checklist

• Write down the facts: employer state, residence, work states, share of working time and expected duration.
• Choose the right basis: Article 12 posting, Article 13 multi-state work, telework framework or Article 16 exception.
• Identify the issuing body for the employer state and apply electronically, before the work starts whenever possible.
• Treat business trips as covered unless the issuing body confirms otherwise; the 2026 exemptions apply only from 2 November 2028.
• Check that both states are signatories before relying on the telework framework.
• Give the employee a copy and keep the A1 available for inspections; when posting into Austria, keep it at the Austrian workplace.
• Diarise the end date and decide before it whether to extend, end or change the hiring model.
• Check tax, permits and permanent establishment separately.