Social security cover abroad
UK decision to invoke Article 50 of the TEU: More information
For the time being, the United Kingdom remains a full member of the EU and rights and obligations continue to fully apply in and to the UK:
Which country you're covered by depends on 2 factors:
- your work situation (employed, self-employed, unemployed, posted abroad, working across the border from where you live, and so on)
- your country of residence - not your nationality.
You may not choose which country you will be covered by.
When working or living abroad, you will have social security cover by either your home country or the host country. In either case, you'll need to make arrangements to make sure you stay covered after you move to your new country.
To avoid potentially serious problems and misunderstandings, find out about social security in your host country.
What to do if you are:
Living and working abroad
As a migrant worker in the EU - employed or self-employed - you should register with the social security system in your host country.
You and your dependants will then be covered by that country's social security system. Your benefits related to sickness, family, unemployment, pensions, occupational accidents and diseases, early retirement and death will be determined by the local laws.
In many countries, the benefits you're entitled to may depend on how long you've previously paid contributions for.
The country where you claim benefits must take into account all the periods you've worked or all the contributions you've paid in other EU countries as if you'd been covered in that country all along.
If it fails to do so, contact our assistance services for help.
Every period of work in the EU counts for benefits
Ania from Poland worked 6 years in Poland and then moved to Germany, where she worked for 2 years.
She then had a car accident which left her unable to walk, so she applied for an invalidity pension in both Poland and Germany.
The German authorities dismissed her application because she'd worked there for less than 5 years (the minimum period to qualify for a German invalidity pension).
However, in calculating Ania's working years, the authorities should have included the time she'd worked in Poland. This would have brought the figure to 8 years, well over the German minimum for qualifying.
So Ania was actually entitled to an invalidity pension from both Germany and Poland — each country paying a share proportionate to the years Ania had worked there.
Posted abroad on a short assignment
This will have no impact on your or your family's social security rights: health cover, family allowances, disability or old-age pension.
Access to healthcare services
To access healthcare services in the country you're posted to, make sure you get a European Health Insurance Card (EHIC). You can get an EHIC from your healthcare provider or the social security authorities in your home country.
If, however, you move your residence to your host country, you or your employer should contact the healthcare authorities in your home country and request a Portable Document S1 (PD S1) form instead. You must then register the PD S1 with the host country's healthcare authorities on arrival.
Staying covered by the social security system in your home country
The PD A1 form proves that you remain covered by the social security system in your home country while posted to another EU country. The PD A1 form is issued for a maximum period of 24 months. If your posting is longer, you or your employer may request an extension to the validity of your PD A1 form. This is subject to the mutual agreement between the authorities in your home and host countries.
If you are an employee, make sure that your employer informs the social security institution in your host country in advance and requests the PD A1 form.
If you are self-employed, you must inform the social security institution in your host country in advance, and request a PD A1 form from the social security institution in your home country. To be eligible for the PD A1 form, you have to prove that the activities you intend to pursue abroad are similar to those you pursued in your home country. To meet this requirement, you must:
- have worked as a self-employed person in your home country. The time period required varies from one EU country to another, but it can be as little as two months.
- fulfil the requirements to continue working as a self-employed person upon your return to your home country.
You should be able to present the PD A1 form to the authorities at any time during your posting abroad, for example, in case of an on the spot check by the labour inspectorate. As long as you have a valid A1 form, the authorities in your host country must recognise it.
Postings longer than 24 months
As your PD A1 form is valid for only 24 months, if your posting to another EU country lasts longer, you can either:
- switch to the social security system of your host country and pay contributions there or
- apply for an extension of your social security cover and remain covered in your home country.
A social security cover extension is granted if a mutual agreement between the countries involved in your posting is reached and if the extension is in your interest. To request an extension, you and your employer must contact the competent authority that issued your PD A1 before it expires.
When you return to your usual country of work you will be covered by the social security system there. You can be posted to another country but only after a certain period of time has elapsed since your return to your home country (two months is considered sufficient by many EU countries).
A civil servant seconded abroad
If you're a civil servant seconded to work in another EU country (at an embassy, consulate or other official institution abroad), you'll be covered by the social security system of your home country.
This means your benefits related to sickness, family, pensions, occupational accidents and diseases, early retirement and death will be determined according to your home country's laws.
A different set of rules applies if you become unemployed while on secondment.
Working in one country, living in another (cross-border commuter)
As a cross-border commuter - whether you are employed or self-employed:
- You pay social security contributions to and are covered by the EU country where you work
- You can, however, obtain medical treatment in the country where you live.
- If you lose your job, you should apply for benefits in the country where you live.
Social security contributions - paid only in the country where you work
Balázs used to live in Hungary and work in Austria. During that time, he paid his contributions in Austria. However, the Hungarian authorities are now claiming he should have paid contributions in Hungary.
Cross-border commuters in the EU are covered under one national social security system only — in the country where they work. The Hungarian authorities' claim is wrong.
Working in more than one country
The basic rule is that if you work in more than one EU country, but carry out a substantial part of your professional activities in your country of residence, you are covered by the social security system in your country of residence.
A 'substantial part' of your activities means at least 25% of your working time and/or income. If you are self-employed, turnover and the number of services provided can also be relevant when calculating this percentage.
You are covered...
are employed but have no substantial activity in your country of residence
where your employer's head office or business is located
work for two employers with head offices in different countries, one in your country of residence and one outside your country of residence but have no substantial activity in your country of residence
where your employer's head office or place of business is located outside your country of residence
work for two employers with head offices in different countries outside your country of residence but have no substantial activity in your country of residence
in your country of residence
are self-employed and have no substantial activity in your country of residence
where the centre of interest of your activities is located
are employed in one country and carry out self-employed work in another
in the country where you are employed
Looking for work
Receiving unemployment benefit?
If you're receiving unemployment benefit from the EU country where you became unemployed, going abroad to look for work won't affect your (or your family's) rights to health cover, family allowance, invalidity or old age pension rights, etc.
To ensure that you and your family have health cover during a temporary stay abroad, don't forget to get a European Health Insurance Card (EHIC).
Once you've found a job, various social security rules may apply.
Not receiving unemployment benefit?
If you're not receiving benefit from the EU country where you became unemployed and move to another EU country to look for work, the social security authorities will decide by which social security system you'll be covered (health cover, family allowance, etc…).
The social security authorities determine this with the help of a list of criteria including:
- duration of stay
- family status and ties
- housing situation
- place of latest professional or non-profit activity
- nature of professional activity
- where you reside for tax purposes.
The country responsible for your social security may make your entitlement to benefits dependent on how long you've previously paid contributions for. However, it will have to take into account all the periods you've worked or all the contributions you've paid in other EU countries as if you'd been covered in that country all along.
If it fails to do so, contact our assistance services for help.
As a newly-arrived jobseeker, you have a right to reside in that country to look for work for up to 6 months - and longer, if you can prove you're still looking for a job and have a good chance of finding one.
So be sure to keep copies of:
- your job applications
- any invitations for interview
- any other replies you receive.
EU rules don't oblige your new country to grant income support or any other kind of welfare assistance to jobseekers looking for a job for the first time in that country.
Check whether you're entitled to income support as a jobseeker in your new country
Björn from Germany had been receiving his German unemployment benefits in Belgium. When his U2 form (formerly E 303 form) expired, Björn decided to stay on in Belgium and apply for income support there.
The Belgian authorities turned down his application. Under Belgian law, Björn wasn't entitled to income support in Belgium, as he'd never worked there.
Under EU rules you have no automatic right to income support (or any other kind of assistance) as a first-time jobseeker in another EU country. But you might be entitled under national rules - it's always worth checking with the local authorities.