What is a Certificate of Coverage?
A Certificate of Coverage is proof that a person remains covered exclusively by their home country's social security legislation during a foreign assignment – and is therefore exempt from social security obligations in the host country. It applies whenever two countries have a bilateral social security agreement (called a "Totalization Agreement" in the US) that operates outside the EU/EEA/Switzerland coordination framework.
The term is a generic umbrella: depending on the country pair, the specific form has a different name – between Germany and the US it is D/USA 101, in the United Kingdom it is CA9107. Within the EU, the EEA and Switzerland, the A1 certificate takes on this function instead.
Why do you need a Certificate of Coverage?
Without coordination, employees on foreign assignments would often be liable for social security contributions twice – once in the home country, once in the host country. The US Social Security Administration (SSA) describes the purpose of bilateral agreements as follows: "International Social Security agreements, often called 'Totalization agreements,' have two main purposes. First, they eliminate dual Social Security taxation, the situation that occurs when a worker from one country works in another country and is required to pay Social Security taxes to both countries on the same earnings. Second, the agreements help fill gaps in benefit protection for workers who have divided their careers between the United States and another country."
According to the SSA, the United States has concluded 30 such agreements – including with Germany (since 1 December 1979), the United Kingdom (since 1 January 1985), Canada (since 1 August 1984), Switzerland (since 1 November 1980) and Australia (since 1 October 2002). Each agreement follows the same basic principle: anyone who can prove continued coverage in their home country does not have to pay social security contributions in the host country – and vice versa.
Certificate of Coverage vs. A1 certificate
For German employers, the key distinction is this: within the EU, EEA and Switzerland, the A1 certificate governs which country's legislation applies, based on EU Regulations (EC) No. 883/2004 and 987/2009. For every other country with a bilateral social security agreement – for example the USA, Canada, India or Australia – a country-specific Certificate of Coverage form applies instead.
| Feature | A1 certificate | Certificate of Coverage (bilateral) |
|---|---|---|
| Scope | EU, EEA, Switzerland | Countries with a bilateral social security agreement (e.g. USA, UK, Canada, India, Australia) |
| Legal basis | Regulations (EC) 883/2004 & 987/2009 | The respective bilateral agreement |
| Form | Uniform EU form A1 | Country-specific, e.g. D/USA 101 (Germany-USA), CA9107 (UK) |
| Branches covered | All social security branches | Usually only individual branches, e.g. pension insurance only |
| Issuing body (Germany) | Health insurance fund or DRV | Health insurance fund (collection agency) or GKV-Spitzenverband/DVKA |
Germany-USA: the D/USA 101 form
Postings between Germany and the USA are governed by the Germany-US Social Security Agreement of 7 January 1976. According to DVKA, it covers pension insurance only. The proof is called D/USA 101 and, according to DVKA, is requested "at the statutory health insurance fund to which pension insurance contributions are paid (the collection agency), or at GKV-Spitzenverband, DVKA, if no pension insurance contributions are paid to a statutory health insurance fund in Germany."
A posting under the agreement is limited to a maximum of five years: "for the maximum five-year duration of the posting to the USA, German social security legislation continues to apply. If the assignment is planned in advance to last longer than 5 years, a posting within the meaning of the agreement is not possible." According to DVKA, applications must now be submitted exclusively electronically. If an assignment is expected to last longer than five years, continued coverage under German legislation is only possible via an exception agreement with DVKA.
For more detail on the Germany-US case – including the gap in health insurance coverage – see A1 certificate for the USA.
Certificate of Coverage in other countries
Other countries with US agreements or their own bilateral arrangements use their own forms too. In the United Kingdom, employers, employees or authorised agents apply for form CA9107 with HMRC according to GOV.UK – but only for a defined list of countries outside the EU/EEA/Switzerland coordination framework: "You can apply if you're going to work in: Barbados, Bermuda, Canada, Chile, Guernsey, India, Israel, Jamaica, Japan, Jersey, Mauritius, the Philippines, Republics of former Yugoslavia […], South Korea, Turkey, USA." For EU countries, Gibraltar, Iceland, Liechtenstein, Norway or Switzerland, a different EU coordination procedure applies according to GOV.UK.
| Country | Form/name | Responsible body |
|---|---|---|
| Germany ↔ USA | D/USA 101 | Health insurance fund (collection agency) or GKV-Spitzenverband/DVKA |
| United Kingdom | CA9107 | HMRC |
| Canada ↔ USA | CPT56A or QUE/USA 101 (Québec) | Canada Revenue Agency or Retraite Québec |
| Switzerland ↔ USA/non-EU countries | A1/CoC certificate | Compensation office (Ausgleichskasse, EAK) |
For individual country cases with a Germany link, see also Canada Digital Nomad Visa, Australia Digital Nomad Visa and A1 certificate for Switzerland.
What this means for employers
For companies with international teams, the takeaway is: the A1 logic from EU business doesn't automatically carry over to third countries. As soon as a posting or workation takes place outside the EU, EEA and Switzerland, companies first need to check whether a bilateral social security agreement with a formal certificate even exists – and if so, which body is responsible, which branches are covered, and how long the exemption lasts. Tools like premote help automatically detect, apply for and track deadlines for country-specific Certificate of Coverage procedures alongside the A1 certificate.
FAQ
What is a Certificate of Coverage?
Proof that a person remains covered by their home country's social security system during a foreign assignment and is therefore exempt from social security obligations in the host country – based on a bilateral social security agreement between two countries.
Is a Certificate of Coverage the same as an A1 certificate?
No, but functionally comparable: the A1 certificate only applies within the EU, EEA and Switzerland. For every other country with a bilateral agreement – such as the USA – a separate, country-specific Certificate of Coverage form applies, such as the D/USA 101.
What is the form called for postings between Germany and the USA?
D/USA 101. It is requested at the responsible health insurance fund (the collection agency for pension insurance contributions) or at GKV-Spitzenverband, DVKA.
How long is a Certificate of Coverage valid for the USA?
For postings from Germany, a maximum of five years. For longer assignments, an exception agreement via DVKA is required.
Does the Certificate of Coverage also cover health insurance?
Usually not. Most bilateral social security agreements – including the Germany-US agreement – cover pension insurance only. Private international health insurance is strongly recommended for the time abroad.
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.