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UK-EU TCA Social Security Rules

UK-Germany Social Security & A1 Certificate Guide 2026

Understand when a UK employee temporarily posted to Germany can remain covered by UK National Insurance, how the 24-month detached-worker rule works, and how to obtain the HMRC certificate of coverage.

What the UK-Germany Rule Actually Does

The UK and EU coordinate social-security coverage so that a worker in a cross-border situation is generally subject to the social-security legislation of one country at a time. The normal rule is linked to where the work is carried out, but the UK-EU Trade and Cooperation Agreement contains a detached-worker exception for eligible temporary postings.

Germany participates in the detached-worker arrangements under the TCA. For an eligible UK employee sent temporarily from the UK to Germany, the detached-worker rule can allow UK National Insurance legislation to continue for a maximum period of 24 months. HMRC must issue the certificate of coverage (also referred to as a PDA1/A1 certificate) for the worker to rely on UK National Insurance coverage and use the certificate as evidence that German social-security contributions are not payable for the covered period.

Key 2026 Rules

IssueCurrent rule
Main frameworkUK-EU Trade and Cooperation Agreement, Protocol on Social Security Coordination
Normal principleWorkers are generally subject to one country's social-security legislation, normally linked to where work is performed
Detached-worker periodUp to 24 months where the applicable conditions are satisfied
UK evidenceHMRC certificate of coverage (PDA1/A1)
UK employee applicationHMRC CA3822 for temporary work in an EU country
Self-employed temporary workSeparate HMRC CA3837 process
Tax and immigrationSeparate from social-security coordination

When Can a UK Employee Stay in the UK National Insurance System?

The detached-worker route is designed for a worker who normally works in one country for an employer established there and is temporarily sent by that employer to work in the other country. For the UK-to-Germany scenario, the UK employer should normally carry out its activities in the UK and the employee should be sent to Germany to work on that employer's behalf.

Typical qualifying pattern
UK employer that normally carries out its activities in the UK → UK employee → temporary assignment in Germany → employee continues working for the sending employer → anticipated posting does not exceed 24 months → HMRC certificate confirms the applicable UK social-security legislation.

The 24-month limit is not the only condition. The detached-worker rule also requires the sending employer to normally carry out its activities in the UK, the employee to be sent to Germany to perform work on that employer's behalf, and the worker not to replace another detached worker. People who normally work in several countries, work for different employers, or change employer during the assignment can fall under different rules. The facts must therefore be checked rather than treating every UK-to-Germany assignment as automatically covered.

How to Obtain the UK Certificate

HMRC's CA3822 process is used to apply for a certificate confirming that an employee working temporarily in an EU country continues to pay UK National Insurance. Germany is within the EU countries covered by this process.

Before applying

The employer must have confirmation from HMRC that its business is eligible to apply for certificates using the process.

The application requires information such as the worker's identity and nationality details, the employer's PAYE reference and details of the overseas assignment.

When to apply

HMRC's CA3822 guidance says an application cannot be made more than 12 months in advance. The application should be made before the assignment where possible so that the worker has evidence of the applicable social-security legislation.

After approval

The certificate demonstrates to the host country that UK National Insurance legislation applies. Where the conditions are met, HMRC may also issue an S1 healthcare entitlement certificate for a worker resident in an EU country.

What Happens at 24 Months?

The 24-month detached-worker rule is a maximum period for the ordinary exception. If the assignment is expected from the outset to last longer than 24 months, the normal detached-worker rule cannot simply be used for the entire assignment.

If an assignment unexpectedly extends beyond 24 months, the applicable legislation needs to be reconsidered from the point at which the detached-worker conditions cease to apply. A separate exception agreement can sometimes allow the sending state's legislation to continue, but this requires the competent authorities to agree; it is not an automatic extension of the A1 certificate.

A1 Does Not Solve Every Germany Compliance Issue

IssueDoes the A1 certificate decide it?
UK National Insurance vs German social securityYes — this is its core purpose
German income taxNo
UK income taxNo
German work/residence permissionNo
German posted-worker notification or labour-law dutiesNo
Healthcare entitlementRelated certificates such as S1 may be relevant where the conditions are met

Frequently Asked Questions (6)

Potentially, yes. Under the UK-EU Trade and Cooperation Agreement social-security rules, an eligible detached worker can remain subject to UK social-security legislation for a posting to Germany of up to 24 months. The worker must satisfy the detached-worker conditions and obtain the appropriate certificate of coverage from HMRC.

An A1 certificate is evidence of which country's social-security legislation applies. For an eligible UK worker temporarily posted from the UK to Germany, HMRC can issue a certificate confirming that UK National Insurance remains payable. The certificate is evidence of social-security coverage; it is not a German work permit or immigration document.

The employee must normally work for an employer in the UK, be sent by that employer to Germany to work on the employer's behalf, and the posting must be temporary and not exceed 24 months under the applicable rule. The employee must also not be sent to replace another detached worker. Other cross-border situations, including multi-state work, can be subject to different rules.

For an eligible employee temporarily working in an EU country such as Germany, the employer, employee or authorised agent can use HMRC's CA3822 process to apply for a certificate confirming continued UK National Insurance coverage. The employer must first have HMRC confirmation that it is eligible to use the process. HMRC may also issue an S1 healthcare certificate where the conditions are met.

The 24-month detached-worker rule does not automatically keep UK social-security legislation applicable beyond the permitted period. If the posting is expected from the outset to exceed 24 months, or unexpectedly goes beyond the permitted period, the applicable legislation must be reconsidered. An exception agreement may be possible in appropriate cases, but it is not automatic and should be arranged with the competent authorities.

No. An A1 certificate concerns social-security legislation only. It does not grant permission to work in Germany, determine German income-tax liability, or replace German immigration, labour-law, posted-worker notification or other compliance requirements. Those issues must be assessed separately.

Official 2026 Sources

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2026 Quick Reference

AgreementUK-EU TCA
Detached-worker limit24 months
UK certificateHMRC coverage certificate (PDA1/A1)
Employee applicationCA3822

Important Distinction

A certificate of coverage confirms the applicable social-security legislation. It does not prove that the worker has the right to enter or work in Germany and does not determine where employment income is taxable.