A1 Certificate for Business Trips: When a Short Trip Needs One Today and What Changes on 2 November 2028

From 2 November 2028, business trips are exempt from prior notification and the A1 request (Article 15(1b) of Regulation (EC) No 987/2009 as amended by Regulation (EU) 2026/2359); the "A1 form" itself stays.

The A1 is the attestation under Article 19(2) of Regulation (EC) No 987/2009 that a State's legislation applies and, where appropriate, until what date and under what conditions. It is used in the EU, the EEA and Switzerland, and with the UK under the Trade and Cooperation Agreement, as part of the rules on the posting of workers.

The sections cover today's rule, Germany, the UK, the definition, the 2028 exemptions and five steps.

Does a Business Trip Need an A1 Certificate Today?

Until 2 November 2028 no EU rule exempts a business trip: Article 15(1) of Regulation (EC) No 987/2009 asks the employer to inform the competent institution of the sending State whenever possible in advance, and the A1 is the evidence the host State's institutions accept. The business-trip definition in Article 1(2)(eb) of the same Regulation has applied since 1 November 2026, but it exempts nothing until 2 November 2028.

EU law does not make the A1 a precondition for travelling: whether to request it before a one-day trip is the employer's decision, weighed against the risk of a host-State check. What an A1 certificate proves does not depend on the length of the trip.

Why a Short Trip Falls under the Posting Rule

Article 12(1) of Regulation (EC) No 883/2004 keeps an employed person under the sending State's law when the employer normally carries out its activities there, the person is sent on its behalf, the anticipated duration does not exceed 24 months and the person does not replace another posted person. These 24 months run on the social security clock.

Article 12(1) of Regulation (EC) No 883/2004 sets no minimum duration, so a one-day meeting abroad meets the same four conditions as a year-long posting. Self-employed persons pursuing a similar activity fall under its Article 12(2), again for up to 24 months.

An employee who normally works in two or more Member States falls under Article 13(1) of Regulation (EC) No 883/2004 instead. The conditions of the posting rule are explained under the 24-month posting rule.

How Germany Handles Short Business Trips

The Federal Ministry of Labour and Social Affairs (BMAS) says in its Merkblatt (leaflet) of 16 July 2024 that for non-regular, short-notice or short business trips and other very short postings of up to one week it may be sensible not to apply for an A1. The same BMAS leaflet notes that EU law sets no duty to carry the A1.

The Deutsche Rentenversicherung A1 FAQ (status 1 January 2026) states that an A1 for business trips of up to seven days may be applied for afterwards if needed, and advises applying in advance for trips to France, Austria and Switzerland. German A1 requests have been electronic only since 1 January 2025 (same FAQ).

Business Trips between the EU and the United Kingdom

A trip between the United Kingdom and an EU Member State falls under Article SSC.11 of the Protocol on Social Security Coordination of the EU-UK Trade and Cooperation Agreement, which keeps a detached worker under the sending State's law for up to 24 months. Every Member State opted in to this provision (GOV.UK change log, 12 February 2021).

The 2028 exemption is a change to Regulation (EC) No 987/2009. The UK has no posting declaration for inbound postings. How UK employers obtain the A1 from HMRC is explained under HMRC A1 certificate.

What Counts as a Business Trip under Article 1(2)(eb)?

Since 1 November 2026 Article 1(2)(eb) of Regulation (EC) No 987/2009 defines a business trip as a "temporary activity as an employed or self-employed person, limited in time and related to the business interests of the employer or the self-employed person, excluding the provision of services or the delivery of goods, but including attending business meetings, cultural and scientific events, conferences and seminars, or receiving training". The table sorts six activities against its words.

Regulation (EU) 2026/2359 of 7 October 2026, published in the Official Journal on 27 October 2026, inserted the definition and entered into force on 1 November 2026. A definition of fraud (Article 1(2)(ea) of Regulation (EC) No 987/2009) and the standardised A1 format (Article 19(2)) apply from the same date.

Meetings, Conferences and Training versus Services and Deliveries

The dividing line is what the traveller does on site: meetings, events, conferences, seminars or training make a business trip, while a service or a delivery of goods does not, however short. The definition in Article 1(2)(eb) of Regulation (EC) No 987/2009 has three cumulative elements: temporary and limited in time, related to the business interests of the employer or self-employed person, and neither a service nor a delivery.

A trip outside the definition, such as a two-day software support visit, can still fall under the three-day exemption from 2 November 2028. Business trips, postings and secondments are set side by side in posting compared with a business trip.

What Changes for Business Trips on 2 November 2028

From 2 November 2028 Article 15(1b) of Regulation (EC) No 987/2009 provides that the prior notification and the A1 request of Article 15(1) and (1a) do not apply to business trips. Every other posting is then notified before the activity starts, with an A1 request, and the institution sends an automatic acknowledgement of receipt where the A1 is not issued at once (Article 15(1) and (1a) as amended by Regulation (EU) 2026/2359). The table compares seven rules.

The exemption removes the prior notification only: the Article 12 conditions of Regulation (EC) No 883/2004 and the applicable legislation stay the same.

Every article the revision amends, with the application date of 2 November 2028 set by Article 97 of Regulation (EC) No 987/2009 as amended, is listed under what Regulation (EU) 2026/2359 changes.

The Three-Day Rule for Other Short Activities

A second exemption in Article 15(1b) of Regulation (EC) No 987/2009 covers activities of no more than three consecutive days of work within 30 consecutive days, from 2 November 2028.

It covers work that is not a business trip, such as a short service visit, but not the construction activities in Annex 6; a business trip, tested separately, is exempt in every sector. A fourth consecutive day of work, or a construction activity, brings back the duty to notify before the activity starts.

Construction Activities Listed in Annex 6

Annex 6 to Regulation (EC) No 987/2009, inserted by Regulation (EU) 2026/2359 and applying from 2 November 2028, lists 13 construction activities for which the three-day exemption does not apply. It covers all building work for the construction, repair, upkeep, alteration or demolition of buildings, in particular the 13 below.

• excavation
• earthmoving
• actual building work
• assembly and dismantling of prefabricated elements
• fitting out or installation
• alterations
• renovation
• repairs
• dismantling
• demolition
• maintenance
• upkeep, painting and cleaning work
• improvements

For these activities every posting is notified before it starts, whatever its length, unless it is a business trip.

Evidence on Request under Article 15(1c)

From 2 November 2028, where no A1 was issued, the employer shows the acknowledgement of receipt or evidence of an exemption, on paper or electronically, when the host State's institution asks for it (Article 15(1c) of Regulation (EC) No 987/2009).

A missing notification does not automatically change the applicable legislation (recital 40b inserted into Regulation (EC) No 883/2004). Member States may take proportionate measures against the employer (recital 13c of Regulation (EU) 2026/2359); no EU fine amount exists.

How to Handle the A1 for Business Trips

Decide for each trip which rule applies today, request the A1 where the trip is a posting, and prepare the evidence the 2028 rules will ask for.

The A1 is one item of the posting compliance checklist; five steps apply it to travelling staff.

1. Classify the trip against Article 1(2)(eb) of Regulation (EC) No 987/2009: meetings, events, conferences, seminars or training, or a service or delivery.
2. Inform the competent institution whenever possible in advance before 2 November 2028 (Article 15(1) of Regulation (EC) No 987/2009) and see how to apply for an A1 certificate.
3. Check Article 13(1) of Regulation (EC) No 883/2004 for regular travellers (working in two or more Member States); for posting from Germany, weigh the BMAS and DRV practice above.
4. Check the host State's labour-law notification (posting declarations) and its fines (posting penalties) separately.
5. Keep the classification and any acknowledgement of receipt ready from 2 November 2028 for a request under Article 15(1c) of Regulation (EC) No 987/2009.

The 2028 exemptions are not part of the rules applied in Norway, Iceland, Liechtenstein and Switzerland while their take-over of Regulation (EU) 2026/2359 is pending (as of 5 November 2026).

Business Trips Beyond the A1: Declarations, Pay and Other Clocks

The A1 settles only the social security question, and five neighbouring rules decide what else a business trip can trigger.

• Declarations: under Directive 96/71/EC, which covers posting in the transnational provision of services (Article 1(1)), a host declaration is due "at the latest at the commencement of the service provision" (Article 9(1)(a) of Directive 2014/67/EU). Exemptions differ: the Dutch Besluit WagwEU exempts business meetings of up to 13 weeks within 52 (Article 10(1)(k)); see posting to the Netherlands.
• Labour-law clock: after 12 months, or 18 on a motivated notification, further host terms apply (Article 3(1a) of Directive 96/71/EC), separate from the 24-month A1 period; see long-term posting after 12 months.
• Documents: for workers posted to Austria, § 21(1) LSD-BG requires the A1 at the workplace or electronically accessible; see posting to Austria.
• Telework: telework of at least 25 % and less than 50 % in the State of residence can be covered by the Framework Agreement under Article 16(1) of Regulation (EC) No 883/2004; see cross-border telework and workation.
• Construction: the building-work Annex of Directive 96/71/EC is a labour-law list, separate from Annex 6; see posting in construction.

Questions on A1 Certificates for Business Trips

Five questions come up most often about the A1 and short trips.

Do I need an A1 certificate for a one-day business trip?

In the EU no short-trip exemption exists until 2 November 2028: a one-day work trip falls under Article 12(1) of Regulation (EC) No 883/2004. Article 15(1) of Regulation (EC) No 987/2009 asks for information whenever possible in advance, not a certificate before departure.

Is the A1 certificate abolished for business trips?

No: Regulation (EU) 2026/2359 keeps the A1 and, from 2 November 2028, only removes the prior notification and A1 request for business trips in the EU (Article 15(1b) of Regulation (EC) No 987/2009). A digital A1 is proposed in COM(2026) 980 of 15 September 2026, pending as of 5 November 2026.

Does attending a conference abroad count as a business trip?

Yes: Article 1(2)(eb) of Regulation (EC) No 987/2009, applying in the EU since 1 November 2026, names conferences and seminars, business meetings, cultural and scientific events and training as business trips. Until 2 November 2028 it creates no exemption.

Does an employee have to carry the A1 on a business trip?

EU law sets no duty to carry the A1, as the German Federal Ministry of Labour and Social Affairs notes in its leaflet of 16 July 2024. A host State's act can require it: § 21(1) LSD-BG does so for workers posted to Austria.

Do the 2028 business-trip rules apply in Norway, Iceland, Liechtenstein or Switzerland?

Not yet: the take-over of Regulation (EU) 2026/2359 by Norway, Iceland, Liechtenstein and Switzerland is pending as of 5 November 2026. There, Regulation (EC) No 987/2009 applies in its current wording, with information on a posting whenever possible in advance.