What is an A1 Certificate? Complete guide for employers

‍

What is an A1 Certificate?

An A1 certificate is a document that confirms the legal situation regarding social security when an employee or a self-employed person temporarily works in another country of the EU, EEA or Switzerland. The certificate proves that the employee remains subject to social security in their home country and pays contributions there, rather than needing to pay into the host country's system.

The A1 certificate is issued under Regulation (EC) No. 883/2004, specifically Article 12 for standard business trips and temporary assignments. Historically, this certificate was known as the E-101 before regulatory changes renamed it to A1 to emphasize its special status within the European social security coordination framework.

The A1 certificate covers all branches of social insurance, including pensions, unemployment insurance, work accident insurance, and healthcare. While work accident and healthcare coverage are often the most immediately relevant during business trips (since accidents or medical needs can occur at any time), pension insurance contributions are also recorded and may be relevant, particularly during longer assignments. The A1 is really about proving that comprehensive social security coverage exists without gaps across all these insurance branches.

‍

Why does A1 Certificate exist?

The A1 certificate exists to solve a practical problem with social security rules. The basic rule in social security is called the "territoriality principle" - this means you must pay social security contributions in the country where you actually work. However, within the EU, binding regulations (specifically Regulation (EC) No. 883/2004 and 987/2009) override this principle to prevent complications for workers moving between countries.

Without these regulations, the territoriality principle would still apply everywhere in the EU. For example, if someone went to work in Italy for five weeks, they would have to pay Italian social security contributions for those five weeks, even if they usually work in another country. This would create a terribly fragmented process for anyone working temporarily in different EU countries.

To prevent this problem, the EU created exceptions to the territoriality principle. The A1 certificate is the official document that proves when these exceptions apply, allowing workers to remain in their home country's social security system even when working temporarily abroad.

‍

Why is an A1 Certificate necessary?

In simple terms, the A1 certificate prevents the abovementioned territoriality principle from applying. It “stops” every country from wanting contributions for just a few weeks of work. With an A1, you can prove that you continued to pay contributions into your home country system during the trip.

This matters for benefits too. If you were in Italy but continued paying contributions into Germany's system, you want to receive your benefits from Germany, the system you actually paid into.

A1 certificates exist for both employees and self-employed individuals. Even self-employed managing directors who are exempt from social security contributions in Germany need A1 certificates, because this social security exemption is a German characteristic that might not apply at all in the destination country. The A1 ensures that Germany's classification applies during the trip.

‍

Who should apply for an A1 Certificate?

The employer is legally required to apply for the A1 certificate, not the employee. This is a critical distinction that many organizations overlook. ⚠️

The employer must be the applicant because they are the party sending the employee abroad. The application requires confirmation that:

• There is actual work to be done in the host country
• A job exists for the employee to return to in the home country
• The assignment has a clear, determined end date

Employees cannot apply for the certificate independently and cannot obtain it on their own - for example, to cover personal holidays or "just in case" scenarios. The A1 specifically certifies work-related travel under the employer's direction and authority.

‍

Who needs an A1 certificate?

Anyone working temporarily in another EFTA country needs an A1 certificate. This includes employees, civil servants, and self-employed individuals who work temporarily across borders within the EU, Iceland, Liechtenstein, Norway, or Switzerland.

The key requirement: Both business trips and workations require A1 certificates from the first day of work abroad as soon as the border is crossed and work activity begins. There is no minimum duration - even a trip lasting just one hour requires an A1 certificate.

The key distinction really is the work activity. When someone goes on vacation, they don't need an A1 certificate. But the moment work enters the picture, the A1 requirement applies.

‍

How to apply for an A1 Certificate?

The application process for the A1 Certificate varies significantly by country. Here are some examples:

• Switzerland: ALPS portal (online application system)
• Germany: SV-Meldeportal
• UK: Direct contact with HMRC
• Other EU countries: Contact your national social security authority for specific procedures

‍

Processing times and proof of application

Processing times of A1 certificates vary considerably by country. For example, HMRC in the UK currently takes between 2-5 months to issue A1 certificates. Other countries may process applications much faster through automated portals.

What's important to note is that a proof of A1 certificate submission is acceptable for employee travel. If your certificate is still being processed but you've already applied, documentation showing proof of submission is sufficient for travel purposes. This is particularly relevant given the extended processing times in some countries. However, you should still apply well in advance of any planned travel to avoid complications.

‍

How long is an A1 Certificate valid?

According to Article 12 of Regulation (EC) No 883/2004, the A1 certificate should cover the exact time you're working in the host country for your employer.

Each trip should have its own A1 certificate. If you need to go to Italy three times next year for three weeks each, you should apply for three separate A1 certificates for three weeks each. It makes no sense to apply for a certificate with validity of 1 year in this case when you're actually going three times for three weeks.

The A1 for a business trip or workation should always match the actual trip. Compliance is never about making vague statements and hoping for the best. Compliance means stating the facts and getting the correct document.

The definition of "temporary" working requires having a clear intention to return to the home country and a determined end date for the assignment. The work abroad must be a clear deviation from the normal work pattern, not a permanent relocation.

Key timeframes of A1 certificate validity from the regulations:

• Maximum period: Two years according to the Article 12 of Regulation (EC) No 883/2004
• Extensions: Plus one year is nearly always possible
• Longer periods: Depending on the host country, you may need approval after three, four, or five years
• Five+ years: From five years it becomes really difficult to get an extension of your A1, usually requiring a change to host country social security

There are no A1 certificates "in reserve". For business trips, you should apply for A1 certificates for each trip individually, not long continuous periods with one certificate.

‍

Do Swiss employees need A1 Certificates?

Yes, Switzerland has decided that EU social security coordination regulations apply to them. Even though Switzerland is not in the EU, they've adopted these coordination rules for social security purposes. Swiss employees can apply for A1 certificates through the ALPS portal, and these certificates work the same way as EU A1 certificates.

‍

Is an A1 Certificate required for workations?

Yes, an A1 certificate must be issued for workations from the first day, as soon as the border is crossed. Workations count as assignments under social security law, so A1 or Certificate of Coverage requirements apply. This has been decided by the highest court in Germany.

Here's the practical part: If vacation days are taken during the workation, you don't need an A1 for the vacation portion, just like it would be with regular vacations. But if you don't have clarity about which specific days will be employee’s vacation versus work days within the workation, it makes sense to apply for the entire timeframe.

The moment the employee opens their laptop to work during the workation, the A1 must be present. If they say "tomorrow the weather is bad, I'd rather work instead of the day after tomorrow," and you only have the A1 for the day after tomorrow, the A1 is wrong.

The usual recommendation is to apply for and A1 for the entire period of workation and don't exclude vacation days, because they don't cause any harm. The A1 only says home social security law applies should the person work, so vacation days covered by an A1 are harmless.

‍

What happens without an A1 Certificate?

Several serious consequences can occur when employees travel without proper A1 certificates:

1) Immediate enforcement actions:

• Removal from premises: Workers can be physically removed from job sites and denied the ability to provide services
• Entry denial: In some cases, workers may be prevented from entering the country to perform work
• Real-world examples: Groups traveling from the UK to France to provide services have been directly sent back when unable to present A1 certificates upon arrival. France and Sweden are particularly strict, conducting spot checks at trade shows, in hotel lobbies, and at co-working spaces.

‍

2) During audits: If you've made an EU posted worker notification (PWD - Posted Worker Directive), authorities will ask if an A1 is present. If local authorities check and there's no A1, you could face rejection with penalty or just a penalty.

3) Insurance coverage risks: If a work accident or car accident happens and you don't have an A1, the German BG (social insurance) can refuse protection. Can you fix this retroactively? Yes, there are decisions showing you can do it. But what if this happens the third or fourth time? Then it might be that it's not just declaratory anymore, you as an employer just don't provide the required benefits.

4) Late payment surcharges and penalties: These can result from working without proper A1 certificates.

5) Reputational damage: Beyond financial penalties, companies risk significant reputational harm when found non-compliant, particularly if employees are turned away from client sites or trade shows.

The bottom line: since A1 certificates are now simple to obtain through portals and providers and automation, it's simply no longer acceptable not to have them. A1 certificates should be treated as essential travel documents, just like passports, for any cross-border business activity.

‍

{{download-box}}

‍

Does A1 Certificate replace travel health insurance?

A common misconception: Many employers assume that obtaining an A1 certificate means their employees are fully covered for healthcare during business trips abroad. ⚠️This is not the case. While the A1 certificate does confirm which social security system applies - including which health insurance system provides coverage - it doesn't guarantee comprehensive protection against medical costs.

Within Europe, employees can use their European Health Insurance Card (EHIC) for medical care while traveling. However, there's a critical limitation: the EHIC provides coverage based on your home country's rules and reimbursement rates, not the host country's actual costs. So if an employee needs medical treatment in a country where healthcare is significantly more expensive than at home, the home country's health insurance will only reimburse according to domestic rates. This leaves a potentially substantial gap that someone must cover - and that someone is the employer.

Why employers bear the cost risk

Under social security law, all cross-border work is classified as a "secondment" - meaning the employer has actively sent the employee abroad for work purposes. This classification creates a legal duty of care: employers are responsible for ensuring their employees can access necessary medical care without incurring personal out-of-pocket expenses during business travel.

The solution: Layered protection

The recommended approach is simple: A1 certificate + comprehensive travel health insurance. Don't rely solely on the A1 and EHIC combination for health coverage. Proper travel insurance bridges the gap between home country reimbursement rates and actual host country costs, protecting both your employees and your organization from unexpected medical expenses.

This layered protection is particularly critical for:

• Business trips / assignments lasting more than a few days
• Travel to countries with substantially higher healthcare costs than your home country
• Any situation where your employees might need specialist care or emergency treatment

‍

💡 Learn more

• Employee accidents abroad: How German employers can avoid financial risks

‍

What is a multi-State A1 Certificate?

Understanding when Multi-State A1 certificates apply can be confusing, so let's clarify the key distinction between two different types of international work arrangements.

Article 13 vs. Article 12: A critical difference

Multi-State A1 certificates fall under Article 13 of EU Regulation 883/2004, which governs cases where employees "normally pursue an activity in two or more Member States." This is quite different from Article 12, which covers "posted" workers, employees temporarily sent to work in another member state for business trips and temporary assignments. These are the situations where you'd apply for a standard A1 certificate.

There's the possibility under Article 13 to apply for a Multi-State A1 for multiple employment situations. This applies when a person is simultaneously active in more than one country and can still remain subject to social security in the first country (usually the country of residence).

To get a multi-state A1 certificate, a real multiple employment must exist. ⚠️This means the employee really has to be active in several countries according to their contract or the nature of their activity.

‍

Key requirements for Multi-State A1:

• Contractual specification: The multi-state work arrangement must be identifiable in the employment contract. The contract should clearly outline that the employee's role involves regular work in specific member states, and ad-hoc arrangements aren't sufficient.
• Normal pursuit of activity: The work pattern must represent consistent and habitual employment across member states. This means regular, planned work activities as part of the employee's standard working pattern, not occasional or needs-based travel.
• Substantial activity: The work in each country must constitute a meaningful portion of the employee's duties: regular, ongoing responsibilities in multiple locations, not just occasional meetings or short-term projects.

‍

Examples of legitimate Multi-State A1 situations:

• Becoming managing director of a subsidiary in another country (like WorkFlex Italy), requiring regular travel to carry out duties
• Sales manager DACH who's always traveling between Germany, Austria, and Switzerland as part of their core responsibilities

‍

What doesn't qualify: A sales manager who might travel abroad seven times over three years for meetings, which is not a case for Multi-State A1. Business trips, even frequent ones, typically don't meet Article 13 criteria because they're usually ad-hoc arrangements rather than contractual obligations, and they represent temporary deviations from normal work patterns rather than the "normal pursuit of activity."

Multi-State A1 certificates recognize when someone is working quite a lot in specific countries as part of their responsibility, which may also have tax implications since matrix positions often trigger tax obligations in multiple locations.

💡 Learn more:

• The multi-state A1 certificate myth: Why it's not a blanket solution for business travel

‍

Certificate of Coverage vs. A1: What's the Difference?

Certificates of Coverage (CoCs) work similarly to A1 certificates in purpose. CoCs confirm that in countries with bilateral social security agreements, the home social security law continues to apply. A key difference between the two is geographic scope – A1 certificates are used within Europe (EU plus Iceland, Liechtenstein, Norway, and Switzerland), while Certificates of Coverage are used for countries outside Europe that have bilateral social security agreements.

However, there are additional important differences including their legal basis, administrative processes, and scope of coverage. Despite these differences, both serve the same fundamental purpose: proving that the person remains in their home social security system while working temporarily abroad, for the branches covered under the respective agreement.

‍

What about countries without totalization agreements?

For countries that don't have bilateral social security agreements, the rules depend heavily on your home country's regulations, for example:

• Germany and Austria: Have specific laws stating that if an employer sends an employee abroad and the home contract remains the ruling contract, the employee stays in the home social security system
• Netherlands: Business trips don't break employment coverage, so employees naturally remain in the Dutch social security system
• United Kingdom: No clear statutory rule exists. For longer assignments, voluntary contributions may be required to maintain coverage

The key principle to keep in mind when your employees travel for business - even without a treaty, you should always try to keep your employee covered in the home social security system. While this doesn't guarantee you're safe from potential host country obligations, it at least ensures your employee has protection from their home country. Remember, the employer bears all responsibility and costs for proper coverage.

💡 Learn more:

• What is Certificate of Coverage

‍

How to simplify your A1 certificate process?

Based on handling thousands of A1 applications, here's what actually works for maintaining compliance:

• Plan each trip accurately: Match A1 certificates to actual travel and work dates. Don't apply for vague timeframes. Be specific about when work will actually occur!
• For workations: When in doubt about specific work versus vacation days, apply for the entire period. The A1 only activates for work activities, so covering vacation days doesn't create any problems.
• Maintain proper documentation: Keep records of all A1 certificates and ensure they're available during any potential audits or compliance checks.
• Consider professional support: With more and more international travel taking place in your organisation, professional assistance can help ensure accuracy and proper timing for A1 certificate applications. The key insight is that A1 compliance follows predictable patterns. Once you understand the requirements and establish proper processes, it becomes routine rather than a crisis-management situation.

‍

WorkFlex is an all-in-one platform that handles A1 certificates, visas, PWDs, tax requirements, and employee duty of care on your behalf – so your global business knows no borders. More than 500 employers worldwide use our platform to automate the processing of A1 certificates and other travel compliance documents in seconds, instead of weeks.

➡️ Book a free consultation with one of our experts to learn how WorkFlex can help make your company more efficient and compliant when employees travel for business.

‍

{{download-box}}