What is an A1 certificate?
An A1 certificate (also called "A1 form" or "Portable Document A1", in German "A1-Bescheinigung") is the official EU document that certifies which country's social security legislation applies to a person temporarily working in another EU, EEA or Swiss state. The legal basis is Regulation (EC) No 883/2004 on the coordination of social security systems, detailed further by Implementing Regulation (EC) No 987/2009.
The European Labour Authority (ELA) gives the official definition: "Portable document certifying that a mobile worker in the European Union or EFTA countries and Switzerland is registered in the social security system of the country that issued it." In practice, the A1 certificate proves that a mobile worker remains registered in their home country's social security system – so they don't also have to pay contributions in the host country.
This page is aimed at international HR teams, US and UK corporate subsidiaries with German employees travelling for business, and expats searching for the English term "A1 certificate" or "A1 form". For the German procedural details, see our German-language guide: A1 certificate summary.
Which countries require the A1 certificate?
According to the German pension insurance (Deutsche Rentenversicherung), the A1 certificate applies to temporary work in: all 27 EU member states, the EEA states Iceland, Liechtenstein and Norway, Switzerland, and – under existing coordination arrangements – the United Kingdom. The European Commission confirms the same scope: "The rules apply across the EU, as well as Iceland, Liechtenstein, Norway and Switzerland. Specific coordination rules also apply to the United Kingdom."
| Scope | Countries | Legal basis |
|---|---|---|
| EU member states | all 27 EU countries | Regulation (EC) 883/2004 |
| EEA (additional) | Iceland, Liechtenstein, Norway | EEA Agreement in conjunction with Reg. 883/2004 |
| Bilateral | Switzerland | Switzerland–EU Free Movement Agreement |
| Special arrangement | United Kingdom | Post-Brexit coordination agreement |
New EU rules from April 2026
In April 2026, EU member states approved revised coordination rules that, according to the European Commission, "better reflect changes in labour markets and national social security systems." Two new anti-abuse rules are practically relevant for employers: workers must now have been insured in their home country for at least three months before a posting is possible. And after 24 months of posting, there must be a break of at least two months before the same person can be posted again to the same country. This rule is new and should be factored into planning for longer or repeated international assignments from 2026 onward.
How do you apply for the A1 certificate in Germany?
Applications are exclusively electronic – paper forms are no longer accepted since the procedure was digitised. German employers have two routes:
- Certified payroll software with an A1 add-on module, directly from the payroll system.
- SV-Meldeportal (app.sv-meldeportal.de), operated by ITSG, as a completion aid for employers without such software.
Depending on the employee's insurance status, the certificate is issued either by the statutory health insurance fund (for statutorily insured employees) or by the Deutsche Rentenversicherung (for privately insured employees). Self-employed persons can only apply via the SV-Meldeportal, also exclusively electronically. For the detailed German application process, see Applying for the A1 certificate.
What happens without a valid A1 certificate?
Without an A1 certificate, host-country authorities typically assume their own social security law applies – meaning local contributions can become due from the first day of work, often retroactively with interest. The United Kingdom illustrates this clearly: under the HMRC National Insurance Manual (NIM33115): "A Portable Document A1 must be produced by a person for an agreement to be made for them to be exempt from United Kingdom National Insurance; otherwise Class 1 National Insurance will be charged." Without a produced A1 certificate, UK Class 1 National Insurance is charged by default – UK A1 certificates are issued, per HMRC, by the "Personal Tax Directorate, National Insurance Contributions & Employer Office" in Newcastle upon Tyne.
Other EU states additionally impose fines during inspections – particularly France, Austria and Switzerland, where enforcement authorities consistently sanction missing A1 certificates (see A1 certificate summary for country-specific fine ranges).
Legal structure of the Portable Document A1
The exact form and content of the A1 form is not arbitrary – it is centrally defined by the Administrative Commission for the Coordination of Social Security Systems. The relevant "Recommendation No A1" (2018/C 183/06) refers to the legal basis in Article 19(2) of Regulation (EC) No 987/2009: at the request of the person concerned or the employer, the competent institution of the member state whose legislation applies under Title II of Regulation (EC) 883/2004 must issue an attestation confirming that legislation applies – indicating validity period and conditions where relevant. That attestation is the A1 certificate.
A1 certificate vs. A1-Bescheinigung – same thing?
| Term | Language | Used by |
|---|---|---|
| A1-Bescheinigung | German | German authorities, DRV, statutory health insurers |
| A1 Certificate / A1 Form | English | International HR teams, ELA, UK authorities (HMRC) |
| Portable Document A1 (PD A1) | EU official language, formal | EU Administrative Commission, legal texts |
All three terms refer to exactly the same document. For the German application process (SV-Meldeportal, health insurer, DRV), see A1 certificate basics. For postings to or from Switzerland with its own separate authorities, see A1 certificate for Switzerland. For the distinction from the German insurance number certificate, see Social security proof for postings.
FAQ
What is an A1 certificate?
An A1 certificate (Portable Document A1) is an EU document issued under Regulation (EC) No 883/2004 that certifies which country's social security legislation applies to a worker temporarily working in another EU/EEA state or Switzerland, so double contributions are avoided.
Is an A1 certificate the same as an A1 form?
Yes. "A1 certificate", "A1 form" and "Portable Document A1 (PD A1)" all refer to the same document; German authorities call it "A1-Bescheinigung".
Which countries accept the A1 certificate?
All EU member states, plus Iceland, Liechtenstein, Norway and Switzerland under EEA/bilateral coordination rules, and the United Kingdom under specific post-Brexit coordination arrangements.
What happens if I travel without an A1 certificate?
The host country's authorities may assume their own social security law applies and can charge local contributions retroactively; in the UK, for example, HMRC charges Class 1 National Insurance by default without a produced A1.
Who issues the A1 certificate in Germany?
Depending on the employee's insurance status: the statutory health insurance fund (for statutorily insured employees) or the Deutsche Rentenversicherung (for privately insured employees); self-employed persons apply exclusively via the SV-Meldeportal.
The information provided on this website does not constitute legal advice and is not intended to address any legal issues or problems that may arise in individual cases. The information on this website is of a general nature and is provided for informational purposes only. If you need legal advice for your individual situation, you should seek the advice of a qualified attorney.
"