Digital nomads’ compliance bar rises

New rules

For employers, there is more to the question of working abroad than employee wishes or business needs. ‘Workforce mobility is changing and maintaining compliance is becoming more complex,’ proclaims Deloitte.

At the heart of much of this complexity lies the vexed question of social security coverage. According to the Department of Social Protection, when work requires movement into other European countries, European Union law is used to decide the country where social insurance must be paid.

In April 2026, the EU agreed new rules governing social security coordination, with a particular focus on the A1 certificate, and the timing around its application.

Available to Irish employers through Revenue, the A1 certificate is a longstanding mechanism that provides proof as to which national social security system applies to an employee temporarily working in another EU country (or Iceland, Liechtenstein, Norway or Switzerland). Munich-based employment lawyer Claudia Posluschny says it is ‘a key instrument of European social security law for cross-border activities’.

A1 coverage is time-bound – it is issued for a defined start and end date rather than offering indefinite coverage. For a standard temporary work posting, it is valid for a maximum of 24 months.

The certificate addresses social security only, not income tax residence, immigration status or employment law. For audit-readiness and compliance, A1 certificates and supporting posting records should be held for at least six years

Direct consequences

To date, a generally flexible approach in Ireland has allowed the certificate to be submitted once placements are underway or even concluded. When the updated EU rules (see ‘A1 certificate changes’ boxout) come into force, likely this October, there will be a much greater emphasis on obtaining it in advance of cross-border work being undertaken.

‘The proposed changes have direct consequences for employees who work remotely from another EU country, undertake frequent business travel or participate in cross-border work arrangements,’ says Michelle Dunne, Grant Thornton Ireland’s employment tax director. ‘The most significant change for employers is the need to shift from a reactive approach to a proactive one.’

Dunne says the reforms should prompt companies ‘to revisit their broader remote working, business travel and mobility frameworks’ and establish ‘clear procedures to identify cross-border work in advance, assess social security implications and obtain any required documentation before travel occurs’.

Stronger governance

A wait-and-see approach to how the changes will play out is inadvisable, Dunne adds. ‘Where appropriate social security documentation is not obtained, employers could face compliance challenges and potentially increased scrutiny from authorities.’

In this more heavily monitored environment, the relationship between employer and employee may also come into scope. ‘Companies may need enhanced tracking systems and stronger governance around employee mobility to ensure they remain compliant,’ Dunne says.

Other experts suggest mid-market organisations with 200 to 2,000 employees may benefit from an A1 tracking register once they have frequent travel patterns across three or more European countries, for example.

The good news is that the rule changes bring at least one welcome simplification for short business trips. Outside the construction section, the A1 will not be required for work stints of up to three working days within a 30-day window, nor for business trips (as long as no commercial services are undertaken or goods delivered).

However, the overall direction of travel of the changes should not be missed. ‘The EU is attempting to modernise social security coordination rules that were designed for a very different workforce’, Dunne says.

The new regulations will apply to a significant and growing body of employees. The Department of Social Protection says it received 10,000 A1 certificate requests in 2025, up from 3,600 in 2024. According to the European Commission, 5.6 million A1 certificates were issued in total by EU member states and EFTA countries in 2024.

Questions closer to home

The push for cross-border work flexibility is also raising questions closer to home. In July, the employer representative bodies Ibec and the CBI called on both the Irish and UK governments to ‘work together to tackle the growing barriers facing hybrid and cross-border workers across the all-island economy’.

A recent joint Ibec-CBI study highlights ‘outdated regulatory and tax frameworks that were severely restricting firms’ ability to recruit, limiting competitiveness and depressing growth potential’.

Its proposals to tackle skills shortages across the island strongly emphasise mobility and include an all-island work visa that would allow non-Irish or British citizens to ‘work seamlessly across the island’.

Strategic response

Ongoing friction points and increased compliance burdens are unlikely to dent employee expectations. A recent global Ipsos study found that 69% of workers believe international relocation will benefit their long-term career prospects, while 65% say they intend to seek remote and hybrid work opportunities when considering employment abroad.

Earlier this year Fine Gael TD Emer Currie told the Dáil that Ireland ‘should be the best country in the world for remote working’. She said: ‘We should have a strategy that targets global companies that work remotely and digitally-first and attracts them to Ireland.’

Employers in Ireland will soon find themselves going the extra mile to make working across the EU seamless for their employees, but the rewards, in terms of employee satisfaction and long-term loyalty, may go far beyond the job in hand.