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      On 28 September 2026, the Council of the European Union formally adopted the regulation revising the EU rules on coordination of national social security systems,1 closing nearly a decade of negotiation.

      The regulation will enter into force upon publication in the Official Journal of the European Union. Although the regulation enters into force when published, the revised coordination rules determining applicable legislation are subject to a deferred application date, which is expected to be around two years from now, to be confirmed against the published text.

      For previous coverage see KPMG GMS Flash Alert 2026-120 and KPMG GMS Flash Alert 2026-191.

      WHY THIS MATTERS

      Formal adoption converts a set of expected changes into a fixed compliance timetable. Although it will likely be around two years before the revised coordination rules take effect, it is not too early for organizations with mobile workforces to familiarize themselves with the changes, particularly the new procedural rules.

      For posting situations, submitting an A1 application before work in the destination country begins will become critical, not only to establish coverage and obtain exemption from local social security, but also to avoid additional administrative steps if an A1 is not requested before deployment.

      Employers can already start reassessing how they classify cases — posting versus multi-state working — and reviewing their internal processes for A1 applications, so that applications are submitted before work in another country begins. The shift is from retrospective to prospective compliance for posting: the paperwork has to exist before the work happens.

      Scope and Timing of the Revised Rules

      The revision focuses on five areas: unemployment benefits, long-term care benefits, access to welfare benefits for economically inactive persons, family benefits, and applicable legislation for mobile workers. 

      The regulation enters into force on publication in the Official Journal. No publication date has been announced.

      The regulation applies on a staggered basis: its recitals record that while a number of provisions can apply immediately because they require no implementation, a later date of application is provided for certain provisions to allow member states sufficient time for implementation.

      The Title II coordination rules sit firmly in the second group, systems, forms, and administrative practices all have to change before mandatory prior notification can work. The expectation reported throughout the negotiation is a transitional period of around two years.

      KPMG INSIGHTS

      The transitional period provides a useful planning window, but the preparatory work is substantial and largely internal. Employers can begin now.

      Steps to prepare the organization:

      • Reassess case classification to identify genuine posting situations, which will be subject to a prior A1 application, and distinguish them from multi-state working. Borderline cases carry the greatest exposure: a case wrongly treated as multi-state working may mean the A1 is not requested before work begins.
      • Integrate an early social security assessment into existing mobility and travel workflows, so that the analysis is completed before travel is approved rather than afterwards.
      • Establish a procedure confirming that, for posting situations, A1 applications are filed before work in the destination country begins, as the timing and documentation of postings will carry significantly greater weight under the revised rules.
      • Screen for the three-month prior affiliation condition, which may disqualify recently hired or transferred employees from postings permissible under the current rules. 

      Member states and social security institutions will use the transitional period to adapt legal frameworks, adjust IT systems, and update administrative practices and guidance. Implementation is expected to vary in pace across jurisdictions, and practical detail — forms, portals, and evidentiary standards — is likely to emerge unevenly.

      KPMG will monitor publication of the regulation in the Official Journal and confirm the application dates for the coordination rules once the text is available, together with further updates as national implementation develops.

      For questions regarding the implications for your organization, or assistance in scoping the preparatory steps outlined above, please contact your usual KPMG Global Mobility Services adviser.

      Contacts

      Daida Hadzic

      Director, Washington National Tax – Global Mobility Services

      KPMG in the U.S.

      More Information

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      The above information is not intended to be “written advice concerning one or more federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230 as the content of this document is issued for general informational purposes only.

      The information contained in this newsletter was submitted by the KPMG International member firm in the United States.

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