Social Security Agreements and Certificates of Coverage: Posting Outside the EU

Outside the 32 States of the EU, the EEA, Switzerland and the United Kingdom, no A1 exists. For postings between Europe and the United States, India, Canada, Turkey, China, Japan, Australia, Korea, Brazil and Serbia, a bilateral agreement decides cover where it applies, and national law decides where none does. The agreement network is the counterpart, outside Europe, of the EU rules for posted workers.

This guide defines the agreement and its certificate, compares the certificate with the A1, explains treaty posting periods and exception agreements, and indexes ten agreement guides. It then gives the German, British and French agreement lists as of 5 November 2026 and the rules that apply without an agreement.

What Is a Social Security Agreement?

A social security agreement is a bilateral treaty that coordinates two national social security systems, so that a worker sent from one State to the other for a limited period stays in the sending State's system for the branches the treaty covers instead of paying into both. Each agreement binds one pair of States only: India has separate agreements with Germany, France and the United Kingdom.

The same instrument carries different names, and the three usages below all describe a bilateral social security agreement.

• Totalization agreement: the term used in the United States.
• Reciprocal agreement or double contributions convention (DCC): the terms used in the United Kingdom.
• Sozialversicherungsabkommen (social security agreement): the German term.

Each agreement covers only the branches it lists, so one posting can fall under the treaty for the covered branches and under national law for the others. In C-55/00 Gottardo (judgment of 15 January 2002), the Court of Justice held that, under Article 39 EC, a Member State must count insurance periods completed in a non-member country by nationals of other Member States under the same conditions as for its own nationals under its bilateral convention with that country, a ruling on benefits rather than on posting.

What a Certificate of Coverage Proves

A certificate of coverage is the document, issued under a bilateral agreement by the institution of the sending State, that confirms the worker remains covered by the sending State's social security legislation during the posting. "Certificate of coverage" is the term used in the United States and the United Kingdom; in German usage the same document is an Entsendebescheinigung (posting certificate) under the agreement concerned.

The certificate is addressed to the partner country, whose authorities and employers rely on it. In the United States, for example, the Internal Revenue Service exempts a worker from US Social Security and Medicare taxes only where a certificate of coverage from the home-country agency is presented to the US employer (Rev. Proc. 80-56, Rev. Proc. 84-54 and Rev. Rul. 92-9). The British counterpart is HMRC form CA9107, described with the British list below. Each certificate is issued by the sending State's institution under the procedure of its own agreement, which the guide to that agreement sets out.

How a Certificate of Coverage Differs from the A1

A certificate of coverage is not an A1: the A1 exists only within the EU, the EEA, Switzerland and, under the TCA Protocol, the United Kingdom, while a certificate of coverage rests on a treaty with one partner country. The A1 is the attestation of Article 19(2) of Regulation (EC) No 987/2009 under Title II of Regulation (EC) No 883/2004, used in 32 States: the 27 Member States, Iceland, Liechtenstein, Norway, Switzerland and the United Kingdom under specific coordination rules. No A1 exists for the ten partner countries, so there is no "A1 for the USA". What the portable document proves inside Europe is set out under A1 certificate.

The A1 follows one EU Regulation, with the same posting rule in every State that applies it. Each certificate of coverage follows its own treaty, with its own posting period, branches and form, so two certificates issued by one State for two partner countries can differ in both period and branches.

How Long a Posting under an Agreement Lasts

Each agreement sets its own posting period, and that period is neither the 24 months of the EU posting rule nor a labour-law threshold of the Posting of Workers Directive. The German agreements allow 12, 24, 48 or 60 months depending on the agreement, while the agreements with Israel and Turkey and the Yugoslav agreement set no fixed maximum, according to the Gemeinsame Verlautbarung (joint guidance) of 18 March 2020 published by the DVKA. Under the agreement with Brazil, German law applies for the first 24 calendar months, even if a longer posting is planned, and Brazilian law applies from the 25th month unless an exception agreement is concluded.

Neither EU clock applies to a treaty period: the 24 months of Article 12(1) of Regulation (EC) No 883/2004 are a social security clock for postings within Europe, and the 12 months (18 with a motivated notification) of Article 3(1a) of Directive 96/71/EC a labour-law clock for long-term posting.

Extending a Posting: Exception Agreements under Bilateral Treaties

The two States' authorities can agree, through an exception agreement under the treaty, that the sending State's legislation continues where a posting will run beyond the agreement's period. In Germany, the GKV-Spitzenverband, Deutsche Verbindungsstelle Krankenversicherung - Ausland (DVKA) concludes these agreements, normally for at most 5 years and, in special circumstances, for at most 3 further years. The request goes in about 4 months before the extension is needed, according to the DVKA guidance on exception agreements.

This treaty route is a different instrument from the EU route. Article 16(1) of Regulation (EC) No 883/2004 serves postings between Member States, with its procedure in Article 18 of Regulation (EC) No 987/2009, and the EU exception agreement route is explained under Article 16 exception agreements.

Ten Agreement Guides: From the United States to Serbia

Ten guides cover the agreements that decide cover for postings between Europe and the United States, India, Canada, Turkey, China, Japan, Australia, Korea, Brazil and Serbia. Each guide names the European States with an agreement, the posting period, the certificate and its issuer, and what applies without an agreement. The table below gives the in-force date of each German agreement and the European agreements that official lists confirm.

Every obligation before, during and after a posting is listed in the posting compliance checklist.

Who Has Social Security Agreements in Europe?

Every European State negotiates its own agreements, so whether a worker sent to the United States or India keeps home cover depends on the sending State's list, not on an EU list. The three lists below come from the German, British and French institutions, each with its source and date.

The German Agreement States

Germany lists 23 agreement States and territories as of 5 November 2026: Albania, Australia, Bosnia and Herzegovina, Brazil, Canada, Chile, China, India, Israel, Japan, Korea, Kosovo, Moldova, Montenegro, Morocco, North Macedonia, the Philippines, Quebec, Serbia, Tunisia, Türkiye, Uruguay and the USA. The list appears in the country information of the DVKA, and all ten partner countries of the guides above are on it, with Quebec as a separate entry beside Canada.

German law gives these agreements priority over its own posting rules. Under § 6 SGB IV, rules of supranational and international law remain unaffected, so an agreement prevails over §§ 4 and 5 SGB IV for the branches it covers. The German liaison agency that publishes the list and concludes exception agreements is described under DVKA.

The British Agreements and Form CA9107

HMRC issues form CA9107, its certificate of coverage, for postings to the countries with which the UK has a social security agreement: Barbados, Bermuda, Canada, Chile, Guernsey, India, Israel, Jamaica, Japan, Jersey, Mauritius, the Philippines, the republics of the former Yugoslavia, South Korea, Turkey and the USA (as of 5 November 2026). The HMRC guidance on form CA9107 was last updated on 7 July 2026.

The British list carries three limits, set out below.

• Contribution-only conventions: the reciprocal agreements with Chile, India, Japan and South Korea cover contributions only.
• Missing partners: the UK has no agreement with China, and its agreement with Australia ended with SI 2000/3255, in force since 1 March 2001.
• A recent convention: the UK-India convention has been in force since 15 July 2026, with a 60-month limit set by SI 2026/794, which replaced the original 36 months.

The French Agreements Listed by CLEISS

CLEISS, the French liaison body, lists French agreements in force with the USA (since 1 July 1988), Canada (agreement of 14 March 2013, in force since 1 August 2017), Quebec (since 1 December 2006), India (since 1 July 2011), Japan and South Korea (both since 1 June 2007) and Turkey (since 1 August 1973). The France-China agreement was signed on 31 October 2016 and followed by an administrative arrangement on 16 September 2019, but it is not in force as of 5 November 2026, and France has no agreement with Australia, according to the CLEISS list of agreements.

What Happens Without an Agreement?

Without an agreement, nothing coordinates the two systems: the sending State's national law decides whether home cover continues, and the partner country can apply its own law at the same time. The same holds for every branch an agreement leaves out: the German agreement with China, for example, covers only German pension and unemployment insurance, so health, care and accident insurance follow German national law during a posting to China.

Under the Ausstrahlung rule of § 4 SGB IV, German law continues for a worker sent abroad within an employment relationship existing in Germany when the posting is limited in advance by the nature of the work or by contract. No fixed maximum applies, and German institutions issue no certificate for a posting to a non-agreement country. The conditions, from the employment relationship to the time limit, are explained under Ausstrahlung under § 4 SGB IV.

The United Kingdom applies its own rule for non-agreement countries: an employer pays UK Class 1 National Insurance contributions for the first 52 weeks abroad where it has a place of business in the UK and the employee is ordinarily resident in the UK and lived there before the work abroad, according to the GOV.UK guidance on paying employees working abroad updated on 7 July 2026. No CA9107 is issued for these postings.

The table below compares the three situations without agreement cover as of 5 November 2026.

What a Social Security Agreement Does Not Settle

A bilateral agreement settles social security cover for one pair of States only: it does not govern postings inside Europe, host pay and conditions, tax or the right to work. The three sections below mark where its reach ends and which rules take over.

Postings between the EU and the United Kingdom

Postings between the EU and the UK are not covered by a bilateral agreement of this kind but by the Protocol on Social Security Coordination of the EU-UK Trade and Cooperation Agreement, which keeps a detached worker in the sending State's system for up to 24 months under Article SSC.11 of the Protocol. All Member States have opted in to this rule, which is explained under posting to and from the United Kingdom.

The British list above therefore serves postings outside Europe only: a posting from London to Toronto needs a CA9107, while a posting from London to Paris follows the Protocol.

Postings within the EU, EEA and Switzerland

Between the 31 States of the EU, the EEA and Switzerland, Regulation (EC) No 883/2004 takes the place of bilateral agreements for posting, and the A1 takes the place of the certificate of coverage.

Article 12(1) of Regulation (EC) No 883/2004 keeps a posted worker under the sending State's legislation for an anticipated duration of up to 24 months, and the A1 shows which legislation applies. These coordination rules are set out under social security for posted workers.

Regulation (EU) 2026/2359 has been in force since 1 November 2026, and its new posting rules apply from 2 November 2028; until then the current Article 12 of Regulation (EC) No 883/2004 applies. Its take-over by Norway, Iceland, Liechtenstein and Switzerland is pending as of 5 November 2026.

Host Labour Law, Tax and the Right to Work

A certificate of coverage settles social security only: host pay and working conditions, income tax and the right to enter and work follow their own rules.

Under Article 1(4) of Directive 96/71/EC, the Posting of Workers Directive, an undertaking established in a non-member State must not be given more favourable treatment than an undertaking established in a Member State. Host pay and conditions in the EU follow the national rules that transpose the Posting of Workers Directive.