Posting Workers to and from the United Kingdom: UK-EU Social Security Rules, Documents and the A1

Inside the EU, posted workers fall under Directive 96/71/EC and Regulation (EC) No 883/2004; the UK left both frames.

Five key figures apply as of 5 November 2026.

• TCA in force since 1 May 2021
• Detached workers: up to 24 months under Article SSC.11
• Postings to the UK: no posting declaration
• EU workers in the UK: home certificate, up to two years
• Postings from the UK: certificate from HMRC

Which Rules Govern Posting between the UK and the EU since 2021

Social security for postings between the UK and the EU is decided by the Protocol on Social Security Coordination of the EU-UK Trade and Cooperation Agreement (CELEX 22021A0430(01)), signed on 30 December 2020, provisionally applied from 1 January 2021 and in force since 1 May 2021. Its personal scope has no nationality condition (Article SSC.2 of the Protocol).

Article SSC.11 of the Protocol keeps a detached employee or self-employed person in the sending State's system for up to 24 months. All Member States opted in to this rule (GOV.UK change log, 12 February 2021).

Labour law follows Directive 96/71/EC of 16 December 1996, which covers the EU and the EEA, not the UK. A UK employer posting into the EU meets the host State's transposition on the matters listed in Article 3(1), and undertakings from non-member States "must not be given more favourable treatment" (Article 1(4) of Directive 96/71/EC). The Posting of Workers Directive page covers host-State declarations and long-term posting after 12 or 18 months (the labour-law clock, Article 3(1a)).

Posting Workers to the UK: No Declaration and No Posting Regulations

An employer that posts workers to the United Kingdom files no posting declaration, because the Posted Workers (Enforcement of Employment Rights) Regulations 2016 (S.I. 2016/539) were revoked at the end of 2023 by the Retained EU Law (Revocation and Reform) Act 2023 (ss. 1(1), 22(3) and Schedule 1 Part 1). S.I. 2016/539 was made on 25 April 2016 and came into force on 18 June 2016; legislation.gov.uk shows its revocation from 1 January 2024.

As of 5 November 2026, no UK posting act requires documents, a contact person or a representative, and no UK posting fine exists.

GOV.UK states that the UK certificate of coverage is not a work permit; entry and work permission follow UK immigration rules.

Drivers on EU-UK Routes and Cabotage in the UK

Drivers of EU road haulage operators carrying goods between the UK and an EU Member State are exempt from the posting rules, while cabotage inside the UK counts as posting (TCA Annex 31 and Article 463(4); Commission Q&A, checked 5 November 2026).

Inside the EU, Directive (EU) 2020/1057 has governed the posting of drivers since 2 February 2022. The posting of drivers page covers cabotage.

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

Cover for Workers Sent from the EU to the UK

A worker sent from an EU State to the United Kingdom stays insured at home where the detached-worker conditions of Article SSC.11 are met, with a certificate of coverage from the social security institution of the State where they live, valid for up to two years (GOV.UK guidance as of 17 January 2024).

The certificate comes from the sending State, not from HMRC, and a foreign employer liable in the UK fulfils its obligations as if established there (Article SSC.14 of the Protocol).

Inside the EU, the same 24 months come from Article 12(1) of Regulation (EC) No 883/2004, a different instrument. The 24-month posting rule page explains that EU counterpart.

The table below shows the proof of cover by direction, checked 5 November 2026.

The A1 for Workers Sent from the UK to the EU

An employer in the United Kingdom proves that a worker sent to an EU State stays in UK National Insurance with HMRC's certificate of coverage, also referred to as a PDA1, issued by its NIC and Employers Office (Commission contact list of 2021). In the EU, the PD A1 replaced the E101 form from 1 May 2010.

Article SSC.11(1) of the Protocol bars sending a worker to replace another detached worker. Under Annex SSC-7 of the Protocol, the employer informs the institution "whenever possible in advance" (Article SSCI.14(1)), and the attestation states "that such legislation is applicable and, where appropriate, until what date and under what conditions" (Article SSCI.16(2)).

Recommendation No 1/2024 of the Specialised Committee on Social Security Coordination (5 June 2024) provides for at least one month of prior affiliation for employees, two months of prior activity for the self-employed and a two-month gap before a new detachment. The A1 certificate page explains what the document proves.

The Protocol has no equivalent of Article 16 of Regulation (EC) No 883/2004; GOV.UK keeps UK National Insurance beyond the detached-worker conditions only for persons in scope of the Withdrawal Agreement, in exceptional circumstances.

Three related rules have their own pages.

• exception agreements beyond 24 months between EU States
• work in two or more States: activity under 25 % is no substantial part (Article SSCI.13(11) of Annex SSC-7)
• A1 for business trips within the EU

What the EU Changes of 2 November 2028 Mean for UK Postings

Regulation (EU) 2026/2359 of 7 October 2026 has been in force since 1 November 2026 and its new posting rules apply from 2 November 2028, but it amends only Regulations (EC) No 883/2004 and No 987/2009, not the TCA Protocol.

Inside the EU, prior notification before the activity starts applies from 2 November 2028 (Article 15 of Regulation (EC) No 987/2009 as amended); today's rules apply until then. The take-over of Regulation (EU) 2026/2359 by Norway, Iceland, Liechtenstein and Switzerland is pending as of 5 November 2026. The revision of Regulation 883/2004 page lists every EU change.

Postings between the UK and Ireland, Iceland, Liechtenstein, Norway and Switzerland

Postings between the UK and Iceland, Liechtenstein or Norway follow the Convention on Social Security Coordination signed on 30 June 2023, whose Article 14 keeps a detached worker in the sending State's system for up to 24 months (GOV.UK guidance since 17 January 2024). For Switzerland, GOV.UK points to the 1968 UK-Switzerland Convention, and UK service providers notify Swiss postings under the Swiss-UK Services Mobility Agreement.

Ireland keeps its Common Travel Area arrangements with the UK (Article SSC.4(2) of the Protocol). The UK-Ireland Convention, signed on 1 February 2019, commenced on 31 December 2020 (Department of Social Protection). The instruments are listed below, checked 5 November 2026.

The United Kingdom Compared with EU Posting Countries

Unlike Germany, France or Belgium, the United Kingdom has no posting declaration and no posting-specific fine, so only the social security coordination rules remain for a posting to the UK.

The posting rules by country compare 32 States; three host States with a declaration follow.

• posting workers to Germany
• posting workers to France
• posting workers to Belgium

Detail Page on the UK Application Procedure

The step-by-step application for the UK certificate has its own page.

Pending Changes Affecting UK Postings

As of 5 November 2026, Commission proposal COM(2026) 550 of 15 October 2026 (procedure 2026/0315(NLE)) on adding derogation agreements to Annex SSC-7 is pending: neither the Council nor the Specialised Committee has decided.

The Protocol ceases to apply 15 years after the TCA entered into force (Article SSC.70(1) of the TCA), computed as 1 May 2036, unless updated. The HMRC A1 certificate procedure page tracks the proposal.

Questions on Posting to and from the United Kingdom

Four questions recur on posting to and from the United Kingdom.

Do workers posted to the UK have to be declared in advance?

No. The UK has had no posting declaration since its posted workers regulations (S.I. 2016/539) were revoked at the end of 2023. A worker detached from an EU State shows cover with the home State's certificate under Article SSC.11 of the EU-UK Protocol.

How long can a worker sent from the UK stay in UK social security?

Up to 24 months under Article SSC.11 of the EU-UK Protocol on Social Security Coordination, for employees and the self-employed. The Protocol has no equivalent of an Article 16 exception agreement under Regulation (EC) No 883/2004; a proposal to add derogation agreements (COM(2026) 550 of 15 October 2026) is pending as of 5 November 2026.

Does the Posting of Workers Directive still apply in the UK?

No. Directive 96/71/EC covers the EU and the EEA, and the UK revoked its own posting regulations at the end of 2023. A UK employer posting into the EU may not be treated more favourably than an EU employer (Article 1(4) of Directive 96/71/EC).

Which countries outside Europe have a social security agreement with the UK?

Outside Europe, HMRC's CA9107 guidance (updated 7 July 2026) lists Barbados, Bermuda, Canada, Chile, India, Israel, Jamaica, Japan, Mauritius, the Philippines, South Korea and the USA; the agreements with Chile, India, Japan and South Korea cover contributions only.

Guernsey, Jersey, Turkey and the former Yugoslav republics complete the list; certificates of coverage under these social security agreements are explained separately.