Social Security Obligations When Working Abroad in the EU
When taking up employed or self-employed activity abroad within Europe, the question arises – particularly with regard to a possible obligation to be insured in the other EU member state – as to which social security system applies to the person concerned. The legal basis is EU Regulation 883/2004 of 29 April 2004 on the coordination of social security systems, which has applied since 1 May 2010 and has fully replaced the earlier Regulation (EEC) 1408/71. It is supplemented by the Implementing Regulation (EC) 987/2009 and by later amending regulations. Under Art. 11(1) of Regulation 883/2004, the basic principle applies that only the legislation of a single member state applies to employment or activity carried out within the EU. Which member state’s insurance obligation applies is determined by Articles 11 et seq. of Regulation 883/2004. The Regulation also applies in relation to Iceland, Liechtenstein, Norway, and Switzerland.
1. Activity or Employment in Only One Member State
Where an employed or self-employed activity is carried out in only one member state, the person concerned is, under Art. 11(3)(a) of Regulation 883/2004, in principle subject exclusively to the social security law of that state. However, the person remains insured under their original system if one of the exceptions provided for in Articles 12 et seq. of Regulation 883/2004 applies – in particular in the case of a posting of workers or a temporary “self-posting,” each of no more than 24 months.
a) Posting of Employed Persons
A posting within the meaning of Art. 12(1) of Regulation 883/2004 requires a continuing employment relationship with an employer in the posting state, an actual posting situation, and a time limit on the posting. To prove that the legislation of the posting state applies, the posted employee presents the competent foreign institution with the A1 certificate. For persons with statutory insurance in Germany, this must be applied for from the relevant health insurance fund; for voluntarily insured persons, from the German Statutory Pension Insurance (Deutsche Rentenversicherung Bund)
b) Temporary Activity of a Self-Employed Person in Another Member State
A corresponding rule applies to self-employed persons under Art. 12(2) of Regulation 883/2004: the legislation of the home state continues to apply provided the anticipated duration of the activity in the other member state does not exceed 24 months. A longer period of applicability requires authorization from the competent foreign authority.
c) Exception Agreement
If it is established from the outset that the activity in the other member state will last longer than 24 months, an exception agreement under Art. 16 of Regulation 883/2004 may be considered, provided the person concerned has a sufficient interest in the continued application of the previous legislation – for example, because their retirement provision is already structured around the existing system. The application must be submitted to the competent authority of the state whose legislation is to continue to apply; for Germany, this is the German Liaison Office for Health Insurance Abroad (DVKA) in Bonn. In practice, the member states involved frequently agree to such an exception agreement for a period of up to five years.
2. Activity or Employment in More Than One Member State
A person who works in several member states remains subject to compulsory insurance in the state in which they reside, provided they also carry out a substantial part of their activity there. If the activity is not also carried out in the state of residence, employed persons are subject to compulsory insurance in the member state in which the employer is based, and self-employed persons in the member state in which they carry out the main part of their activity.
3. Employment and Self-Employed Activity in Different Member States at the Same Time
If a person simultaneously carries out employed work and self-employed activity in different member states, under Art. 13(3) of Regulation 883/2004 the entire economic activity is in principle attributed to the law of the state in which the employed work is carried out. If the self-employed activity is carried out in certain member states listed in Annex VII of the Regulation – including Greece – employment and self-employed activity are, by way of exception, attributed to the law of different member states.
FAQ
The legal basis is EU Regulation 883/2004 of 29 April 2004 on the coordination of social security systems. It has applied since 1 May 2010 and has fully replaced the earlier Regulation (EEC) 1408/71. It is supplemented by Implementing Regulation (EC) 987/2009 and by later amending regulations.
No. Under Art. 11(1) of Regulation 883/2004, only the legislation of a single member state applies to an employed or self-employed activity carried out within the EU. Which state that is follows from Articles 11 et seq. of the Regulation.
Yes. Regulation 883/2004 also applies in relation to Iceland, Liechtenstein, Norway and Switzerland.
If you carry out your employed or self-employed activity in only one member state, you are in principle subject exclusively to the social security law of that state (Art. 11(3)(a) Regulation 883/2004). This applies even if you live in another member state.
Yes. You remain insured under your original social security system if one of the exceptions under Articles 12 et seq. of Regulation 883/2004 applies – in particular in the case of a posting of employees or a temporary activity of a self-employed person abroad, each lasting no more than 24 months.
A posting within the meaning of Art. 12(1) of Regulation 883/2004 requires:
• a continuing employment relationship with an employer in the posting state,
• an actual posting situation, i.e. the employee works temporarily in another member state on behalf of that employer,
• a time limit on the posting (anticipated duration of no more than 24 months).
The posted employee presents the A1 certificate to the competent foreign institution. It confirms that the social security legislation of the posting state continues to apply.
Employees with statutory health insurance in Germany apply to their health insurance fund. Voluntarily insured persons apply to the German Statutory Pension Insurance (Deutsche Rentenversicherung Bund).
Under Art. 12(2) of Regulation 883/2004, the legislation of your home state continues to apply, provided the anticipated duration of your activity in the other member state does not exceed 24 months.
Continued application of the home state's legislation for a longer period requires authorisation by the competent foreign authority.
In this case, an exception agreement under Art. 16 of Regulation 883/2004 may be considered. The prerequisite is that you have a sufficient interest in the continued application of your previous legislation – for example, because your retirement provision is already structured around the existing system.
The application must be submitted to the competent authority of the state whose legislation is to continue to apply. For Germany, this is the German Liaison Office for Health Insurance Abroad (DVKA) in Bonn.
In practice, the member states involved frequently agree to an exception agreement for a period of up to five years.
You remain subject to compulsory insurance in your state of residence, provided you also carry out a substantial part of your activity there. If you do not carry out a substantial part of your activity in your state of residence:
• employees are subject to compulsory insurance in the member state in which their employer is based,
• self-employed persons are subject to compulsory insurance in the member state in which they carry out the main part of their activity.
If you simultaneously carry out employed work and self-employed activity in different member states, your entire economic activity is in principle subject to the law of the state in which the employed work is carried out (Art. 13(3) Regulation 883/2004).
Yes. If the self-employed activity is carried out in one of the member states listed in Annex VII of the Regulation – which includes Greece – employment and self-employed activity are, by way of exception, attributed to the law of different member states. In that case, you may be insured in two systems at the same time: for your employment in one state and for your self-employed activity in Greece.
As of June 2026. All information on these pages is provided without guarantee or liability.