Posted Worker Notification: Complete Guide to EU Posted Workers Directive 2026

A complete guide to the posted worker notification for Global Mobility managers

What Is a Posted Worker?

A posted worker is an employee sent by their employer to work in another EU Member State temporarily. This covers three main arrangements:

• Service provision: Your company provides services to a client in another country and sends employees to deliver them.
• Intra-group transfers: You second employees between related companies across borders.
• Temporary agency work: Your agency supplies workers to clients in other Member States.

The legal foundation is the freedom to provide services within the EU. But this freedom has limits. Host countries can impose their labour standards on posted workers to prevent ‘social dumping’ (undercutting local wages and conditions through cheap foreign labour).

The Posted Workers Directive

The rules have changed significantly over the past 30 years.

Key Directives

The transformative 2018 revision replaced ‘minimum rates of pay’ with ‘remuneration’. This means that posted workers are now entitled to all components of pay mandated by national law or universally applicable collective agreements, not just the bare minimum wage.

Seniority bonuses, holiday pay, shift premiums, and industry allowances must all accord to host country rates, even if your home country doesn’t require them.

For Mobility managers: You need a detailed analysis of local collective bargaining agreements, particularly in construction, agriculture, and transport, where these agreements are often universally applicable.

What Is a posted worker notification (PWN)?

The PWN is a mandatory filing that must be completed before a worker begins an assignment in the host country. It serves two purposes:

• Advance notice to authorities: Labour inspectorates use PWN data to conduct targeted inspections and monitor compliance.
• Proof of compliance: The notification receipt shows you’ve followed the rules when inspectors arrive at the worksite.

The concept is centralised at the EU level, but implementation is decentralised. This means 31 different national registration systems across the EU and EFTA, each with its own portal, data requirements, and language rules.

Standard Data Requirements

Despite national variations, most portals require four clusters of information:

Don’t forget: Appoint a designated representative in the host country. This person must be available to receive documents and respond to inquiries from the labour inspectorate. Some countries, such as Romania, have recently relaxed the requirements for those who can serve in this role.

The A1 certificate connection

Labour law and social security create one of the most complex areas of compliance: your workers’ social security status, which is determined by Regulation (EC) No 883/2004.

The general rule: social security contributions are paid where work is physically performed. But the ‘posting exception’ allows workers to remain in their home country’s social security system for up to 24 months, provided they obtain an A1 Certificate.

The link between PWNs and A1s has tightened. Countries like Luxembourg and Spain now require the A1 certificate to be uploaded to the labour notification portal or kept in the worker’s on-site file.

The 2025 fraudulent A1 ruling

The authenticity of A1 certificates became a major legal issue in 2025. In Case C-421/23, the European Court of Justice addressed fraudulent A1 certificates issued for workers in the Belgian construction sector.

Key points from the ruling to bear in mind:

• Uniform application: Regulation 883/2004 applies even to fraudulently obtained certificates, preventing workers from being left without coverage or facing double contributions.
• Mandatory dialogue: Host country authorities must engage with the issuing state before declaring a certificate fraudulent.
• Finality of denial: If the issuing authority confirms a certificate is invalid, the host country can instantly apply local social security laws.

For employers: Conduct strict due diligence when working with subcontractors or labour intermediaries. Relying on fraudulent certificates (even unknowingly) can lead to back-payment liabilities and potential criminal charges.

Country Requirements: 2026 Update

Germany: Zoll Oversight and High-Risk Sectors

Germany runs one of the EU’s most rigorous enforcement environments, overseen by Customs (Zoll). 

• All notifications go through www.meldeportal-mindestlohn.de before work begins. 
• Documents must be available in German.
• High-earning employees may be exempt if their salary exceeds €4,461 pcm.
• Exemptions don’t apply to construction, meat processing, industrial cleaning, and hospitality. In these sectors, every posting must be reported regardless of salary.

Unique requirement: ‘Operational schedules’ when employees work at multiple locations in a single day.

France: SIPSI and Tense Occupations

France uses the SIPSI portal for all declarations.

• The SMIC rose to €12.02 per hour (€1,823.03 monthly) as of 1 January 2026.
• This automatically lifts salary thresholds: EU Blue Card (€59,373 yearly), ICT Manager (€5,460.20 monthly), Talent Qualified Employee (€39,582 yearly).
• French authorities intensified focus on ‘occupations in tension’ (nursing, carpentry, agriculture). Employers face enhanced scrutiny to ensure posted workers aren’t bypassing local hiring obligations.

Unique requirements: Appoint a representative and pay the ‘Versement Mobilité’ payroll levy in certain regional zones.

Netherlands: False Self-Employment Crackdown

• The Dutch Meldloket portal handles notifications under WagwEU law. 
• 2026 enforcement trend: Crackdown on ‘false self-employment’ (ZZP’ers). Tax authorities (Belastingdienst) are investigating whether individuals registered as independent contractors are actually performing employment work, leading to back-dated payroll taxes and fines.

Unique requirements: The Netherlands offers a unique ‘one-year notification’ (jaarmelding) for small businesses or self-employed individuals within 100 kilometres of the border with frequent short-term assignments.

Romania: Law 16/2017 Controls

• Notifications must be submitted to the local ITM territorial office no later than the day before activity begins.
• The Romanian system emphasises maintaining the employment relationship between the home employer and the posted worker throughout the assignment. The 2026 minimum wage rose to 4,050 RON monthly (approximately €814).

Unique requirement: Meal vouchers and assignment allowances cannot offset the basic minimum wage.

Digital transformation: the 2026 Unified Portal and ESSPASS

Managing 31 separate systems is a thorn in the side of global businesses. This is why, in 2026, the European Union started discussing how to streamline the process through two major digital initiatives:

• The EU e-Declaration Portal: A centralised EU e-declaration portal, which member states can use voluntarily. It aims to reduce submission time by up to 73% and lower administrative costs by 25%.
• The European Social Security Pass (ESSPASS): Integrates digital A1 certificates and the European Health Insurance Card (EHIC) into the EU Digital Identity Wallet, enabling labour inspectors to verify a worker’s social security coverage via a digital QR code or wallet.

As adoption is voluntary, a hybrid approach is required for now, with some countries managed through the central EU system, and others requiring national portals. 

Risk Management: Inspections, Penalties, and the ELA

As of 2026, the European Labour Authority (ELA) conducts hundreds of joint and concerted inspections annually, targeting high-risk sectors like construction and road transport.

Documents required for a labour inspection

A typical inspection in 2026 usually involves the authorities requesting a comprehensive ‘compliance pack’ that must be produced within very tight deadlines (often as few as five working days). Mandatory documents include:

• PWN Receipt: Proof that the notification was filed before work started.
• A1 Certificate: Proof of social security exemption in the host state.
• Employment Contract: Verification of role, salary, and home country link.
• Detailed Timesheets: Proof of compliance with working time and rest rules.
• Proof of Payment: Bank transfer receipts or payslips confirming remuneration.

Financial and reputational consequences

The cost of non-compliance has risen sharply. Financial penalties are often calculated per employee and per violation, meaning a single non-compliant project can result in millions of euros in fines.

• Financial penalties: Fines range from €70 for minor administrative errors to €225,000 for severe or systemic non-compliance. In some countries, such as Norway, the maximum administrative fine has been raised to NOK 3.2 million (approximately €280,000).
• Operational bans: Repeat offenders or those found guilty of social dumping, can be banned from providing services in the host country for a set period.
• Reputational risk: Authorities in countries like Belgium and Luxembourg have begun publishing the names of non-compliant companies, leading to blacklisting by major clients and negative press coverage.
• Immigration suspensions: For companies posting third-country nationals, non-compliance can lead to the revocation of the company’s sponsorship licence or a ban on future work permit applications.

Strategic roadmap for Global Mobility professionals

To navigate the posting requirements of 2026, organisations must transition from a reactive model to a proactive, technology-driven compliance strategy.

Implementing day one compliance

The focus must be on ensuring that every worker has a valid posted worker notification and an A1 certificate before they cross the border. Best practices include:

• Pre-trip assessment: Use automated tools, such as Centuro Global’s AI Travel Compliance Assistant, to determine if a trip triggers a PWN or A1 requirement based on the specific activities performed and the destination country’s thresholds.
• Centralised data management: Move away from local spreadsheets to a centralised HRIS or mobility platform that serves as a single source of truth for all cross-border movements.
• Local expertise network: Partner with local representatives and legal experts who can stay current with the rapidly changing salary thresholds and collective bargaining agreement updates in each Member State.

Managing the long-term posting threshold

Organisations must strictly monitor the 12-month (or 18-month) threshold. As a posting approaches the one-year mark, the mobility team must assess whether the worker should be transitioned to a full local employment contract or if a ‘motivated notification’ can be filed to extend the posting period. 

Failure to manage this transition can lead to the worker being retrospectively claimed as a local employee, triggering massive social security and tax liabilities.

Feedback loops and cancellation policies

One major risk factor is the mismatch between notified dates and actual travel. In jurisdictions like Spain, failing to cancel a notification for a cancelled trip is a violation. 

Implement a post-trip verification process in which employees confirm their actual travel dates.

Posted worker compliance made easy

Posted worker notification compliance can be overwhelming. While the rules are complex – 31 portals, changing thresholds, strict deadlines – the right tools make all the difference. 

Centuro Global’s Travel Compliance Assistant automatically flags when trips trigger PWN requirements, guides you through country-specific filings, and keeps your team compliant from day one. It’s compliance made simple.

Book a demo today.