If you work remotely for a company in another European country, you’ve probably wondered: which country’s social security system am I actually in?
Until recently, the answer depended on a patchwork of bilateral agreements, case-by-case decisions, and a lot of administrative confusion. The EU Framework Agreement on Cross-Border Telework, signed in July 2023 and effective from mid-2024, was designed to change that – introducing a clear threshold that determines where your social security contributions go.
Here’s how it works, who it applies to, and what you need to do about it.
What is the EU Framework Agreement on cross-border telework?
The Framework Agreement is a multilateral deal between EU and EEA member states (plus Switzerland) that creates a simplified rule for determining social security obligations when employees telework across borders. It sits alongside – but is distinct from – the existing EU Regulation 883/2004 on social security coordination.
The core problem it solves: under the old rules, an employee who worked from home in Country A for an employer based in Country B might have been subject to Country A’s social security system – even if they only teleworked from home occasionally. The legislation wasn’t designed for remote work, and the rules on “substantial activity” (generally interpreted as 25% or more of working time in a country) created headaches for everyone involved.
The Framework Agreement introduces a more generous threshold specifically for telework, making it easier for cross-border remote workers to remain in their employer’s social security system.
If you’re unfamiliar with how social security coordination works across Europe more broadly, our guide to A1 certificates and social security covers the fundamentals.
The 50% rule explained
The central mechanism of the Framework Agreement is straightforward:
If you telework less than 50% of your total working time in your country of residence, you remain subject to social security in the country where your employer is established.
That is a significant shift from the previous 25% threshold under the general multi-state worker rules. In practice, it means an employee can work from home up to just under half the time and stay within their employer’s social security system – no change in contributions, no administrative burden, no need to register with a foreign social security authority.
Here’s how the thresholds compare:
| Rule | Threshold | Social security stays with employer’s country if… |
|---|---|---|
| General multi-state rule (Reg. 883/2004) | 25% | Less than 25% of work is performed in the country of residence |
| Framework Agreement on telework | 50% | Less than 50% of work is telework performed in the country of residence |
| Above 50% telework in residence country | N/A | Social security shifts to the country of residence |
A few important details:
- The 50% threshold applies specifically to telework – work that could be performed at the employer’s premises but is instead done remotely using information technology.
- It only covers employed persons (not the self-employed – more on that below).
- It requires both countries involved to have signed the agreement.
- The telework must be performed in the employee’s country of residence – not a third country.
That last point is critical. If you’re a Spanish resident working for a Dutch company but you spend a month working from a cafe in Lisbon, the Framework Agreement doesn’t cover your time in Portugal. For that kind of scenario, the standard multi-state rules still apply.
How this differs from the old Article 16 bilateral agreements
Before the Framework Agreement came into force, many countries addressed cross-border telework through bilateral agreements under Article 16 of Regulation 883/2004. These were ad hoc deals between pairs of countries – Germany and the Netherlands might have one arrangement, France and Belgium another – each with potentially different terms and administrative processes.
The problems with that approach were considerable:
- Inconsistency – different rules depending on which two countries were involved
- Administrative burden – each agreement required separate applications and processing
- Coverage gaps – many country pairs simply didn’t have an agreement in place
- Temporary nature – most Article 16 agreements were introduced as COVID-era emergency measures and were never designed to be permanent
The Framework Agreement replaces this patchwork with a single multilateral instrument. If both countries have signed, the same 50% rule applies regardless of which specific countries are involved.
That said, Article 16 agreements haven’t completely disappeared. They may still be relevant in cases where one or both countries haven’t signed the Framework Agreement, or where the specific situation falls outside the Framework Agreement’s scope (such as self-employment or telework from a third country).
Which countries have signed?
As of early 2026, the following countries have signed the Framework Agreement:
| Signed and active | |
|---|---|
| Austria | Lithuania |
| Belgium | Luxembourg |
| Croatia | Malta |
| Czech Republic | Netherlands |
| Finland | Norway |
| France | Poland |
| Germany | Portugal |
| Ireland | Romania |
| Liechtenstein | Slovakia |
| Switzerland | Sweden |
The list continues to grow. Countries can accede to the agreement at any time, and several more are expected to join during 2026.
Notable absences as of the time of writing include Spain, Italy, Greece, Denmark, and Hungary. If your cross-border telework situation involves a country that hasn’t signed, the Framework Agreement won’t apply, and you’ll fall back on the standard multi-state rules under Regulation 883/2004 or any existing bilateral agreement.
This is worth checking regularly – the Administrative Commission for the Coordination of Social Security Systems maintains the current signatory list, and it changes as more countries join.
For remote workers in the Netherlands or France, our country-specific guides cover local social security obligations in more detail: working remotely in the Netherlands and working remotely in France.
Practical scenarios
Let’s walk through how the 50% rule works in real situations.
Scenario 1: employee in Portugal, employer in Germany
Maria lives in Lisbon and works for a software company headquartered in Berlin. She works from home four days a week and travels to the Berlin office one day a week.
- Telework in country of residence (Portugal): 80% of working time
- Since this exceeds 50%, Maria falls outside the Framework Agreement
- Result: Maria is subject to Portuguese social security
- Her employer must register with the Portuguese social security system and make contributions there
Scenario 2: employee in Belgium, employer in France
Thomas lives in Brussels and works for a French consulting firm. He spends three days per week at the Paris office and two days working from home.
- Telework in country of residence (Belgium): 40% of working time
- Both countries have signed the Framework Agreement
- Since 40% is below the 50% threshold, the Framework Agreement applies
- Result: Thomas remains in the French social security system
- No additional registration required in Belgium
Scenario 3: employee in Spain, employer in the Netherlands
Laura lives in Valencia and works remotely for a Dutch company. She visits the Amsterdam office once a month.
- Spain has not signed the Framework Agreement (as of early 2026)
- The Framework Agreement does not apply, regardless of the telework percentage
- Result: the standard multi-state rules under Regulation 883/2004 apply
- Since Laura performs more than 25% of her work in Spain, she would likely be subject to Spanish social security
For anyone navigating Spain’s social security system as a self-employed worker, our guide to the autonomo system covers the practical details.
Scenario 4: the marginal case
Peter lives in Austria and works for a Swiss fintech company. He works from home exactly two and a half days per week (50% of his time) and spends the other half at the Zurich office.
- Telework in country of residence: exactly 50%
- The Framework Agreement requires less than 50% – not 50% or equal to 50%
- Result: Peter does not qualify, and standard multi-state rules apply
- His employer should review whether the arrangement can be adjusted to stay below the threshold
How to apply for an A1 certificate under the Framework Agreement
If the Framework Agreement applies to your situation, you (or your employer) will need to apply for a multi-state A1 certificate – the portable document that proves which country’s social security legislation applies to you. The process works as follows:
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Determine eligibility – confirm that both countries have signed the agreement, that the telework is less than 50%, and that it takes place in the country of residence.
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Submit the application – the request for an A1 certificate is typically made to the competent social security institution in the country whose legislation applies (usually the employer’s country). Some countries allow the employer to submit the request; others require the employee to do it directly.
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Provide supporting documentation – this generally includes the employment contract, a description of the working arrangement (including the split between telework and on-site work), and confirmation of the employee’s country of residence.
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Receive the A1 certificate – once approved, the certificate is valid for a specified period (usually up to three years under the Framework Agreement, compared to the typical one or two years under standard rules).
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Carry the certificate – the A1 certificate should be available during any work performed abroad, as it serves as proof of applicable legislation in case of inspections or audits.
The application process varies by country, and processing times differ significantly. In some countries, the process is entirely digital; in others, it still involves paper forms. Our detailed guide to A1 certificates walks through the country-specific procedures.
What happens above 50%?
If your telework in your country of residence equals or exceeds 50% of your total working time, the Framework Agreement simply doesn’t apply. You default to the standard rules under Regulation 883/2004.
Under those standard rules, if you perform 25% or more of your work in your country of residence, you will generally be subject to that country’s social security system. This means:
- Your employer must register with the social security authority in your country of residence
- Contributions must be paid according to local rates and rules
- You’ll be covered by the local social security system for healthcare, pensions, unemployment, etc.
For employers, this can be a significant administrative and financial burden – social security contribution rates vary considerably across Europe, and registering as a foreign employer in another country’s system is rarely straightforward.
This is one reason many companies set limits on cross-border telework or require employees to spend a minimum amount of time at the office. The 50% threshold gives employers a clear line to manage.
Interaction with digital nomad visas
Digital nomad visas (DNVs) and the Framework Agreement serve different purposes and generally don’t overlap – but it’s worth understanding where they intersect.
Digital nomad visas are designed for people who work remotely for clients or employers outside the country they’re living in. The Framework Agreement covers employed persons working across borders within signatory states. In theory, these are different populations. In practice, the lines can blur.
Key distinctions:
| Framework Agreement | Digital nomad visa | |
|---|---|---|
| Who it covers | Employees of companies in signatory states | Remote workers (employed or freelance) from any country |
| Social security | Determines applicable legislation | Usually does not affect social security (varies by country) |
| Tax implications | None directly (social security only) | Varies – some DNVs include tax benefits |
| Duration | Ongoing (as long as conditions are met) | Fixed term (typically 1-2 years) |
| Residence requirement | Must be resident in a signatory state | Grants residence in the issuing country |
If you hold a digital nomad visa in a signatory state and you’re employed by a company in another signatory state, the Framework Agreement could potentially apply. But digital nomad visas are more commonly used by freelancers and the self-employed – who are explicitly excluded from the Framework Agreement.
For more on income requirements and eligibility for digital nomad visas, see our guide to digital nomad visa requirements across Europe.
Employer obligations
For employers with cross-border teleworkers, the Framework Agreement simplifies things – but it doesn’t eliminate responsibilities entirely.
If the Framework Agreement applies (telework below 50%):
- The employee remains in the employer’s home country social security system
- No need to register in the employee’s country of residence
- An A1 certificate should be obtained to document the arrangement
- The employer should monitor the telework percentage to ensure it stays below 50%
If the Framework Agreement doesn’t apply (telework at 50% or above):
- The employer may need to register with the social security authority in the employee’s country of residence
- Contributions must be paid at local rates
- The employer must comply with local reporting and payment obligations
- Professional advice is strongly recommended – the costs and procedures vary significantly by country
General obligations regardless of the threshold:
- Employers should have clear remote work policies that address cross-border situations
- Working time should be documented, with records of where work is performed
- The arrangement should be reviewed periodically – a change in the employee’s work pattern could shift the applicable legislation
- Employment law obligations (which are separate from social security) may still apply in the employee’s country of residence
This is an area where getting it wrong can be expensive. Social security contributions that should have been paid to a foreign authority – but weren’t – can result in back payments, penalties, and interest. Employers navigating this territory should work with advisors who understand cross-border employment in Europe.
For a broader look at the regulatory landscape affecting remote work in Europe, including the EU AI Act’s implications for remote teams and general work-from-home trends, our insights hub covers the full picture.
The self-employed gap
One significant limitation of the Framework Agreement: it does not cover the self-employed. If you’re a freelancer based in one EU country working for clients in another, the agreement won’t determine your social security position.
For self-employed cross-border workers, the standard rules under Regulation 883/2004 still apply. Generally, self-employed persons are subject to social security in the country where they pursue their activity. If you’re self-employed in multiple countries, the rules on “centre of interest” and “substantial part of activity” come into play – and they can be genuinely complex.
This is a known gap, and there have been calls for the Framework Agreement to be extended to cover the self-employed in future revisions. For now, freelancers working across borders need to navigate the existing regulations – and should get professional advice on their specific situation.
Frequently asked questions
Does the 50% rule apply to self-employed workers?
No. The EU Framework Agreement on cross-border telework applies only to employed persons. Self-employed workers are covered by the standard rules under Regulation 883/2004, which use different thresholds and criteria.
What counts as “telework” under the agreement?
Telework is defined as work that could be performed at the employer’s premises but is instead carried out at the employee’s home or another location in their country of residence, using information technology. Travel days, client meetings, and work performed in a third country do not count as telework under the agreement.
My country hasn’t signed the Framework Agreement. What are my options?
You’ll fall back on the standard multi-state worker rules under Regulation 883/2004, or any bilateral agreement that exists between the two countries involved. Check with your country’s social security authority – some countries that haven’t signed the Framework Agreement still have bilateral Article 16 agreements covering telework.
Can I split my time between more than two countries?
The Framework Agreement is designed for bilateral situations – one country of residence, one employer country. If you work in three or more countries, the standard multi-state rules under Regulation 883/2004 apply, and you’ll need to assess your situation based on where you perform a “substantial part” (25% or more) of your activity.
How strictly is the 50% threshold enforced?
The threshold is based on your overall working pattern, not day-by-day monitoring. Social security authorities typically look at the expected working arrangement over a period of 12 months. However, you should be able to demonstrate that your telework genuinely stays below 50% – through employment contracts, work schedules, or travel records.
Does the Framework Agreement affect my tax position?
No. The Framework Agreement deals exclusively with social security coordination. Tax obligations are governed by separate rules, including bilateral double taxation agreements between countries. It’s possible to be subject to social security in one country and income tax in another.
How long does the A1 certificate last under the Framework Agreement?
Under the Framework Agreement, A1 certificates can be issued for up to three years – longer than the standard one to two years under general multi-state rules. They can be renewed if the working arrangement continues to meet the conditions.
What happens if my working pattern changes mid-year?
If your telework percentage crosses the 50% threshold – say, because you start working from home more often – you should notify the relevant social security authority. A change in working pattern can trigger a change in applicable legislation, which may require a new A1 certificate and a switch in social security contributions.
The bigger picture: Europe’s digital transformation is converging
The Framework Agreement is part of a broader shift. As remote work becomes the norm rather than the exception, Europe’s regulatory frameworks are slowly converging – not through harmonisation, but through practical coordination mechanisms like this one.
We’re seeing a similar trajectory in company law. The proposed EU Inc – a pan-European legal entity designed for digital businesses – aims to do for corporate structures what the Framework Agreement does for social security: create a single set of rules that work across borders, rather than forcing businesses and workers to navigate 27 different systems.
The direction of travel is clear. Whether it’s social security, tax, employment law, or company formation, Europe is gradually building the cross-border infrastructure that distributed work demands. The Framework Agreement is one piece of that puzzle – imperfect and incomplete, but a meaningful step toward a continent where working from anywhere doesn’t mean drowning in bureaucracy everywhere.
This article provides general information about the EU Framework Agreement on cross-border telework. It does not constitute legal or tax advice. Social security rules are complex and depend on individual circumstances – always consult a qualified advisor for your specific situation.
Last reviewed: February 2026. Social security coordination rules are subject to change. Check the European Commission’s social security coordination page for the latest signatory list and guidance.
