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      On 8 October 2025, the relevant EU committees agreed to begin interinstitutional negotiations1 regarding a unified platform and standardized form for mandatory digital declaration for posted workers (the “e-declaration”). This could represent the final legislative step before adoption of the system, meaning the operational e-declaration platform may become a reality as early as next year. For previous coverage, see KPMG Flash Alert 2025-210 – New Initiatives for Mobility of Workers.  

      The negotiating institutions in the EU have shared insights into the intended features and data requirements of the e-declaration for posted workers. These insights can help businesses review their processes and develop a plan for collecting the relevant data for e-declaration in a timely and efficient manner.2

      WHY THIS MATTERS

      If legislative progress continues as planned and the proposed regulation for a central e-declaration for posted workers is adopted in the coming months, the e-declaration platform could be operational by the end of 2026.

      Data collection remains one of the most challenging aspects of timely compliance with mandatory posting declarations. Employers often do not have all the necessary information readily available, and gathering relevant employee data can be delayed because of lack of responsiveness.

      It is therefore important for businesses to familiarize themselves with the proposed framework for the e-declaration, review how their data collection and compliance processes align with these requirements and make strategic decisions or necessary changes to achieve compliance with the mandatory declaration for posted workers.   

      Although participation in the e-declaration system will be voluntary for EU member states, the expanded scope of the initiative has received widespread positive feedback. As a result, it is reasonable to expect that most, if not eventually all, EU member states will adopt this solution.

      Compliance with mandatory declarations for posted workers and social security has become a hallmark of reliability and trustworthiness in the European market. Businesses should monitor ongoing developments and adjust their compliance processes as needed. Greater digitalization may impact requirements for A1 certificates for social security and mandatory declarations for posted workers. 

      General information

      In the most recently published document about e-declaration,3 the scope of the central e-declaration for posted workers has been substantially expanded. It now includes mandatory declarations for posted self-employed individuals, posting from non-EU countries, and inclusion of social security information.

      Additionally, the e-declaration must be available in all official EU languages, with a translation facility provided to enable national authorities to translate documents to and from any official EU language.

      The mandatory e-declaration for posted workers is essential for correct enforcement of legislation, improved data collection, and cross-border information exchange. It enables more targeted inspection and evidence-based policy making. 

      1.     Process Simplification and Data Standardization

      • A central, standardized form will improve the collection, cross-referencing, and comparability of data across EU member states.
      • This reduces non-compliance resulting from differing posting declaration requirements.

      2.     Public Interface and Data Validation

      • The public interface should validate posting declarations data for accuracy and format.
      • Validation may include cross-referencing information against relevant EU or national registries (e.g., address or business registries).
      • The interface should be user friendly, multilingual, and provide clear guidance and support to service providers.

      3.     Data Reusability and Integration

      • Service providers must be able to save relevant data for future declarations.
      • The European Commission should explore integrating e-declaration interface with A1 certificate applications for potential future consolidation.

      4.     Personal Data and Data Controllers

      • Certain personal data regarding posted workers, service providers, contractors, service recipients, contact person, and legal representative must be collected for factual workplace control.
      • The controller of personal data must be indicated, because the proposed regulation concerns data processing. For example, when posting e-declarations are received through the public interface and stored in national back-end systems, the competent national authority is considered the data controller.

      5.     Data Access, Logging, and Retention

      • Data on e-declarations should be accessible to the European Labour Authority4 for joint inspections, analysis, and risk assessment.
      • Appropriate logging of user activity and transparency regarding changes to posting declarations is required.
      • Automatic deletion of posting-related information should occur 10 years after the posting period ends; information in the service provider’s reserved area should be deleted 36 months after the latest declaration.

      6.     Document Submission and Availability

      • Service providers should be able to submit e-declarations and relevant documents to national competent authorities of the host member state via the public interface.
      • Information and documents submitted through the public interface must be made available in e-declaration platform to competent authorities in both the host member state and the member state of establishment.

      Many member states have integrated their posting declarations into robust back-end systems, enabling national labor inspectorates and enforcement authorities to develop digital tools for targeted inspections and analysis. The e-declaration should allow member states to receive posting declarations directly into these national back-end systems.

      KPMG INSIGHTS

      Based on the developments described above, it is likely that companies posting workers will be required to provide more data than before.

      For instance, the proposed regulation for e-declaration mentions mandatory information about the legal representative. Currently, only a few EU member states require such data, and it is often debated—the legal representative may question why this information is needed, how it will be used, and what personal responsibility it bears in the context of posted workers.

      Another point concerns the contact person. Several EU member states no longer require that the contact person is physically present in the host country, as technology now allows authorities to reach them anywhere in Europe. It remains to be seen whether the new requirements will mandate physical presence, or place restrictions on who can serve as the contact person. In some countries, for example, only the posted worker can be designated as the contact person.

      A further change is the proposal to make posting data available to both the home and the host country authorities. At present, posting declarations are typically only accessible to the host country.

      If this initiative receives broad support from EU member states, then companies should prepare for both an increase in the volume of required data and higher expectations for data quality. The e-declaration process will likely involve more extensive validation, cross-checking, and analysis, especially when comparing data across areas such as social security and tax.

      One aspect that remains unclear is the final output of the e-declarations. Currently, national declarations often include all submitted data, including sensitive personal information about, for example, the contact persons or legal representatives, which may not be necessary for compliance checks. That data can be made available broadly, for example posted workers themselves.

      For example, Luxembourg uses an ‘e-badge’ (badge social) 5—a QR code generated from the declaration that posted workers can carry and present to authorities when requested. It would be beneficial for the EU Commission to consider similar solutions, aligning with the European Digital Identity Wallet initiative,6 which aims to help individuals verify and store relevant documents for cross-border activities.

      KPMG can assist with compliance reviews, process optimization, and support in the execution of compliance with A1 certificates, as well as notifications about posting and working conditions for posted workers. 

      FOOTNOTES:

      1  European Parliament, “2024/0301(COD) Public interface connected to the Internal Market Information System for the declaration of posting of workers,” 8 October 2025.

      2  European Parliament, “Report on the proposal for a regulation of the European Parliament and of the Council on the Public interface connected to the Internal Market Information System for the declaration of posting of workers and amending Regulation (EU) No 1024/2012,” 10 September 2025.  

      3  Ibid.  

      4  European Labour Authority website.  

      5  The Government of the Grand Duchy of Luxembourg, “Posting of workers to Luxembourg,” 31 May 2017.

      6  European Commission: EU Digital Identity Wallet, website. 

      Contacts

      Daida Hadzic
      Daida Hadzic

      Director, Washington National Tax – Global Mobility Services

      KPMG in the U.S.

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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.

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