How WorkFlex handles Posted Workers (PWD) notifications

The objective of the PWD is to prevent social dumping, by protecting the rights and working conditions of cheaper foreign workers within the EU.

Pieter Manden


Posted workers notifications – or PWD notifications, in German EU Meldepflichten – are notifications based on the EU Posted Workers Directive (PWD). These notifications concern registrations of employees who will temporarily be sent to work from a different country, e.g. as a business traveller or expat.

The objective of the PWD is to prevent social dumping, by protecting the rights and working conditions of cheaper foreign workers within the EU. Workationers have privately initiated the trip abroad, thus are not posted and PWD notifications are not required. Belgium is an exception to this, as it has converted the directive in national legislation that includes a broader definition of posted workers. More information in this WorkFlex whitepaper.

PWD notifications are obligatory. Incompliance can result in fines up to €500k, as well as non-financial penalties such as multi-year restrictions on doing business in a particular country. How strictly this is enforced varies per country. What also varies per country is the exact content of the registration and the method of filing it with the local authorities. Most countries provide online portals or at least an online process for doing PWD notifications. However, in some countries there is no (online) process for doing them. Also, some countries have made the process so complex that it is practically impossible to do PWD notifications. In Poland, for example, a local registration of the posting (entity) is required and all correspondence has to take place on paper in the local language. An obvious reason fora non-existent or complex process, is that social dumping – the original objective of the PWD – is not very relevant in these countries. Not surprisingly, these countries also hardly enforce the obligation of doing the notifications. As a result, these countries can be qualified as low risk.

Looking at the figure below, the low risk-countries are included on the bottom. In practice, employers do not do notifications in low risk-countries. This also applies to WorkFlex. However, as the figure shows our so-called no-risk coverage does apply for trips shorter from 1 to 5 days, and up to 8 days in Spain. This means that WorkFlex protects clients by reimbursing any fines for not doing PWD notifications in these low-risk countries for most business trips. Above the low risk-countries, the figure shows the other countries where PWD notifications are required. In all of these 24 high risk-countries, WorkFlex always does PWD notifications as part of the trip handling subscription. No additional costs are due. The notification confirmation will be uploaded to the WorkFlex platform. The combination of doing PWD notifications in so many countries and offering no-risk coverage for all other countries, should compliantly cover 98% of all business trips.

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