The Pre-Move Checklist That Keeps EU Secondments Compliant
Approve the move only after the prior-affiliation screen, certificate request, and cap check are in the file.
| By | The Petition File — Newsroom |
|---|---|
| Filed | 5 October 2026 |
| Read | 3 MIN |
When a mobility manager opens the travel request, the first line is the social-security gate, not the itinerary. In some jurisdictions, obtaining an A1 certificate can take more than six months, while in others it can take days. The deadline is before work starts in the destination country, and a late request may force a delay or a different legal basis. The gate must be in the file before the travel request is approved.
The European Parliament approved the Provisional Agreement on EU social security contribution coordination on 7 July 2026, after the agreement was reached on 23 April. The revised EU framework keeps the 24-month secondment limit for employees and self-employed workers who remain under their country of origin's social security rules, provided they do not replace another posted worker.
The assignee must have been subject to home-country social security for at least three months before the secondment starts. The revision requires advance notification to the competent institution and a request for a Portable Document A1, or PDA1, certificate.
Put the screen at selection. If the candidate has not been in the home-country system long enough, the secondment may need a different start date or a different legal basis. Payroll confirms the contribution history in writing, and the mobility file shows the source, the date, and the person who checked it.
Build the gate into the travel approval
Use a list in the mobility file. Make each item testable quickly, and have it produce a document or a dated note. The list is the point of the approval.
- Confirm the 3-month prior-affiliation screen.
- Check the 24-month cap.
- Check the replacement screen.
- Notify the competent institution and request the PDA1 certificate.
- Attach the PDA1 request to the travel approval before the first workday.
- Flag activity over three consecutive days in a 30-day period.
- Note the short-activity and business-trip exceptions, including construction.
- Log the request date and expected processing time.
The affiliation item protects the home-country basis. The cap and replacement items keep the file audit-ready before arrival. The certificate items keep the proof attached to the work, not to the itinerary.
A named person owns the checklist. HR mobility runs the screen, in-house counsel signs off on the cap and replacement check, and payroll confirms the contribution history. Give each item a date; a dated note keeps the file usable for review.
Make the cap and replacement check a file
The cap is easy to miss in a long-running assignment, and a replacement issue is harder to spot because the assignee may not know who was posted before. The PDA1 is the document that proves which legislation applies. If the activity is short, the advance obligation may not apply, but the documentation still shows why.
The Provisional Agreement would require an A1 certificate when activities last more than three consecutive days within any 30-day period. The advance PDA1 requirement would not cover short assignments of fewer than three straight workdays in a 30-day window, or business travel, except in construction. Start the A1 request before the travel approval is final, and put the request date in the approval record. By the time the assignee boards, the file answers the key questions: who pays social security, which certificate covers the work, and when the posting ends.
Extensions make the cap visible. If the assignment is extended, the record shows the new end date and the reason for the extension. The prior-worker check is a fact question: the note identifies the prior worker, the role, and the dates, if any. The sign-off shows who reviewed the extension and who approved it.