Posting Declarations and Posted Worker Notifications: Who Must Notify, When, Where and What to File in Each Country

The same notice is called a posted worker notification or a prior declaration of posting, and each host State decides whether it requires one, what it contains and through which system it is filed. Drivers posted within Directive (EU) 2020/1057 do not use these national systems: they are declared in an EU portal, which has its own guide below.

The declaration matters because it is the first contact between a posting undertaking and the host State's inspectors. According to the European Commission's proposal COM(2024) 531, all 27 Member States run a prior declaration tool, and none of these tools is connected to another, so an undertaking posting to three States files three different declarations. It is one of the duties that apply to posted workers.

This guide sets out the EU rule in Article 9(1)(a) of Directive 2014/67/EU (content, deadline and language), who files and who checks, the national systems of 19 States with deadline, legal basis and authority as of 5 November 2026, the thresholds and update deadlines, how the declaration differs from the A1 certificate and how many declarations are filed each year.

What Is a Posting Declaration?

A posting declaration, also called a posted worker notification, is a simple declaration in which a service provider established in another State tells the host Member State's authority who it posts, where, for how long and for which service. The declaration is an administrative requirement, not a permit: the host State is informed of the posting, and the posting needs no approval.

The legal basis is Directive 2014/67/EU, adopted on 15 May 2014, in force since 17 June 2014 (Article 25) and due for transposition by 18 June 2016 (Article 23(1)). Article 9(1)(a) of Directive 2014/67/EU lets Member States impose the declaration; it does not impose it directly, so each State sets its own rule in national law. Article 9(2) of the same Directive allows further administrative requirements only where the existing ones are not sufficient or efficient, and only if they are justified and proportionate. The other control measures of Article 9 of the Directive are explained under the Enforcement Directive 2014/67/EU.

The territorial reach of the Directive extends beyond the EU. Directive 2014/67/EU has been in force in the EEA since 1 January 2020 (EEA Joint Committee Decision 215/2018 of 26 October 2018), so Iceland, Liechtenstein and Norway are bound by it as well. Switzerland is not bound by Directive 2014/67/EU and runs its own notification under its Posted Workers Act, and the United Kingdom has no declaration for postings into the UK.

What Article 9(1)(a) of Directive 2014/67/EU Requires to Be Declared

Article 9(1)(a) of Directive 2014/67/EU lists the minimum the declaration contains, and the word "including" leaves Member States room to ask for more. The six items of the list are set out below.

• Identity of the service provider
• Anticipated number of clearly identifiable posted workers
• The persons designated under Article 9(1)(e) and (f): the liaison person and the contact person
• Anticipated duration of the posting, with its start and end dates
• Address or addresses of the workplace
• Nature of the services justifying the posting

The Commission's Your Europe business page on posting staff abroad (last checked by the Commission on 30 September 2026) adds a practical point: changes to the posting must be reported. National forms go beyond the six items. Italy's notification under art. 10 of Legislative Decree 136/2016 also names the recipient of the services, and Czechia's notification under § 101a of Act No. 435/2004 Coll. asks for the type and number of each worker's identity document.

When the Declaration Is Due and in Which Language

Under EU law the declaration is due at the latest at the commencement of the service provision, and it is made in an official language of the host Member State or another language that State accepts.

The Commission phrases the same deadline for employers on Your Europe: the declaration is made "before the posting begins or at the latest when it starts" (page last checked by the Commission on 30 September 2026). EU law sets no fixed number of days in advance; any such period comes from a national act.

The Commission has also given its reading of earlier deadlines. In its report COM(2019) 426 of 25 September 2019 on the application of Directive 2014/67/EU (section 3.6.1), it said that a deadline of hours or days before the posting goes beyond what Article 9(1)(a) expressly authorises. Two States in the table below set waiting periods today: Switzerland under its own Posted Workers Act, and Liechtenstein for employers established in third countries.

Who Files a Posting Declaration and Who Checks It

The service provider that posts the workers files the declaration, not the worker; three host States, France, the Netherlands and Sweden, also make the client check that a declaration exists.

The filer rules checked on 5 November 2026 show four patterns. In Germany, the employer established abroad notifies in the sectors covered by § 18 AEntG and § 16 MiLoG, and for hired-out workers only the temporary-work agency notifies. In Czechia, the foreign employer files through the portal of the State Labour Inspection Office (SÚIP) for postings starting after 30 June 2024, whereas in 2019 the Czech service recipient filed. Austria separates postings from hiring-out: the employer files form ZKO 3 for posted workers and form ZKO 4 for hired-out workers (§ 19 LSD-BG). In Spain, art. 5 of Ley 45/1999 makes temporary-work agencies notify every posting.

Client duties add a second line of control in these three States. In France, the client asks the posting employer for the receipt of the SIPSI declaration before each posting (Article R1263-12 of the Code du travail). In the Netherlands, the client checks the notification within 5 working days (Article 8(3) WagwEU). In Sweden, a client that receives no proof of notification informs Arbetsmiljöverket, the Swedish Work Environment Authority, within 3 days (31 § lag (1999:678)). EU law contains no general rule that makes the client liable for a missing declaration; each of these duties rests on its national act.

Two Declaration Guides: Drivers and the Planned EU Interface

Two cases have their own guides: drivers posted under Directive (EU) 2020/1057, who declare in the EU's IMI public interface, and the EU e-declaration, which is still a proposal. The e-declaration is the Commission's proposal COM(2024) 531 of 13 November 2024 (procedure 2024/0301(COD)); after the European Parliament's first-reading position of 20 October 2026, it awaits the Council's first-reading position as of 5 November 2026, and it would let host States opt in to an EU interface that replaces their national declaration (OEIL procedure file).

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

National Declaration Systems: Deadline, Legal Basis and Authority

Each host State runs its own declaration system, and the deadlines checked on 5 November 2026 range from "before work starts" to "at the latest on the day the service starts", with Switzerland, and Liechtenstein for third-country employers, asking for 8 days' notice. The table gives four facts per State: the system, the deadline with its trigger, the legal basis and the authority that receives the declaration.

Portal steps, forms and logins stay in the country guides linked from each row, and drivers posted within Directive (EU) 2020/1057 never use these national systems. A row shows the deadline exactly as the national act or the authority words it, because "before work starts", "at the latest when the service begins" and "no later than the day work starts" are three different triggers.

Table: national posting declaration systems, as of 5 November 2026.

The rows outside the EU follow their own legal bases. Liechtenstein lets employers from EEA States start once the notification is filed and employers from third countries at the earliest 8 days after filing, with immediate starts in emergencies such as repairs, accidents and natural disasters (Art. 6a Entsendegesetz). Switzerland applies its Posted Workers Act (EntsG, SR 823.20), under which work may start at the earliest 8 days after the notification (Art. 6(3) EntsG). The United Kingdom revoked its posting regulations, S.I. 2016/539, at the end of 2023.

Sanctions for a missing or late declaration are national as well. Article 20 of Directive 2014/67/EU requires penalties that are effective, proportionate and dissuasive, and leaves the amounts to each State. Two examples as of 5 November 2026: Austria fines up to EUR 20,000 per offence, regardless of the number of workers (§ 26(1) LSD-BG), and Germany fines up to EUR 30,000 for notification and document breaches (§ 23(3) AEntG). Every State's amounts are compared under posting penalties.

Short Postings, Sector Rules and Minimum Durations

No EU rule exempts short postings from the declaration, so the threshold, if any, comes from national law. Three States require a declaration from the first hour: Austria sets no minimum duration for the ZKO notification (§ 19 LSD-BG), Sweden has no short-stay exemption in force under lag (1999:678), and Luxembourg requires eDetach even for a few hours on one day, according to the Inspection du travail et des mines. Two States use a duration threshold instead. Iceland asks for the notification only where the provider operates for more than 10 working days in total during a 12-month period, and Switzerland requires notification for work of more than 8 days per calendar year, except in listed sectors such as construction, hospitality and cleaning, where it applies from the first day (Art. 6(1) and (2) EntsV).

Other States tie the duty to a sector or an activity. Germany requires the notification only in the AEntG sectors or the 11 sectors of § 2a SchwarzArbG, but there before each work regardless of its duration. Spain exempts only postings of up to 8 days under art. 2.1.1.º a) and b) of Ley 45/1999 (service contracts and intra-group postings). Denmark exempts technical installation of up to 8 days by specialised fitters, installers, inspectors or repairers (§ 7 b udstationeringsloven). Poland exempts initial assembly or installation of up to 8 days a year, but not construction work (Art. 5 of the Act of 10 June 2016). The Netherlands lists exceptions for its Meldloket, such as initial assembly of up to 8 days outside construction. An 8-day threshold therefore exists in four of the five States in this paragraph, each with its own activity condition, and none of them exempts every posting under 8 days.

Updating a Declaration and the Filing Language

Changes to a filed declaration have their own deadlines, which run from "without delay" to 10 calendar days. Austria (§ 19 LSD-BG) and Germany (§ 18 AEntG) require changes "unverzüglich", without delay, and Sweden immediately under lag (1999:678). Denmark requires the update by the first following weekday (§ 7 a stk. 6 udstationeringsloven). Italy allows 5 days under art. 10 of D.Lgs. 136/2016, but a new start date must be reported by midnight of the day before the posting starts (DM 170/2021). Poland allows 7 working days (Art. 24(5) of the Act of 10 June 2016), and Czechia 10 calendar days under Act No. 435/2004 Coll.

The filing language follows the host State's choice under Article 9(1)(a) of Directive 2014/67/EU. Germany and Liechtenstein take the notification in German; Poland accepts Polish or English (Art. 24(6) of the Act of 10 June 2016); Romania requires Romanian; Ireland's Form of Declaration is in English. Luxembourg's eDetach works in French, German or English, and Denmark's RUT register in English, German, Polish or Danish. Switzerland asks for the official language of the place of work (Art. 6(1) EntsG).

Declaration and A1: Two Separate Duties

A posting declaration and an A1 certificate answer different questions: the declaration informs the host State's labour authority under its posting law, while the A1 shows which State's social security legislation covers the worker. Neither replaces the other: a filed declaration does not prove social security cover, and an A1 does not inform the labour inspectorate.

The two duties also run on two clocks. On the labour-law clock, long-term posting starts after 12 months, or 18 months on a motivated notification (Article 3(1a) of Directive 96/71/EC). On the social security clock, the sending State's legislation continues for an anticipated duration of up to 24 months (Article 12(1) of Regulation (EC) No 883/2004). For the A1 side, Article 15(1) of Regulation (EC) No 987/2009 today asks the employer to inform the competent institution "whenever possible in advance".

From 2 November 2028, Regulation (EU) 2026/2359 of 7 October 2026, in force since 1 November 2026, turns this into a prior notification with an A1 request before the activity starts (Article 15(1) of Regulation (EC) No 987/2009 as replaced). This social security notification does not replace the labour-law declaration to the host State. The take-over of the 2028 rules by Norway, Iceland, Liechtenstein and Switzerland is pending as of 5 November 2026. What the A1 proves is explained in the A1 certificate guide.

How Many Posting Declarations Are Filed?

Member States received about 2.3 million posting declarations in 2022 for about 1.9 million posted workers and 4.7 million postings, according to the Commission's proposal COM(2024) 531 of 13 November 2024. These figures describe the year 2022 and come from the proposal's explanatory memorandum, not from a current count.

The same proposal describes the systems behind these figures. All 27 Member States had a prior declaration tool, and the national systems are not interconnected (recital 3 of COM(2024) 531). This fragmentation is the problem the proposed EU interface addresses, through voluntary participation by host States.

What a Posting Declaration Does Not Cover

A declaration covers the notice only: documents on site, the contact person, the long-term posting notice and permits for third-country staff follow separate rules.

Does a Declaration Replace Documents, a Contact Person or the 18-Month Notice?

No: Article 9(1) of Directive 2014/67/EU lists the declaration next to other measures, and each has its own rule. The three measures most often confused with it are listed below.

• Documents kept at the workplace under Article 9(1)(b) of Directive 2014/67/EU: see documents for posted workers.
• The contact person for collective bargaining, who does not have to be present in the host Member State under Article 9(1)(f) of Directive 2014/67/EU: see contact person and representative.
• The motivated notification that extends long-term posting from 12 to 18 months under Article 3(1a) of Directive 96/71/EC, a notification and not an authorisation.

Do Posted Third-Country Nationals Need More Than a Declaration?

A host State may ask for a simple prior declaration for third-country staff lawfully employed by a provider in another Member State, but not for a work permit. In C-43/93 Vander Elst (9 August 1994), the Court of Justice held that work permits are precluded for third-country nationals lawfully and habitually employed by a service provider established in another Member State. In C-244/04 Commission v Germany (19 January 2006), it added that a simple prior declaration suffices (paragraph 41). Residence and immigration procedures follow their own rules, and the case line and national rules are set out under posting third-country nationals.