European social and health-care insurance news

Framework agreement on cross-border telework – new signatory countries

As informed in our previous article, Slovakia was one of the first countries which signed the Framework Agreement on the application of Article 16 (1) of Regulation (EC) No. 883/2004 in cases of habitual cross-border telework. The Framework agreements applies as of 1 July 2023 for the following countries:

As of 1 September 2023, Slovenia joined the above countries. Italy belongs to signatory countries as of 1 January 2024.

Convention on Social Security Coordination between Iceland, Liechtenstein, Norway and the United Kingdom of Great Britain and Northern Ireland – in place since 1 January 2024

After Brexit, the Regulation (EC) No 883/2004 on the coordination of social security systems ceased to apply to workers moving between the United Kingdom (U.K.) and the EU, Iceland, Liechtenstein, Norway, and Switzerland. To limit the negative and extensive impact of Brexit and to govern the social security position of individuals moving between the U.K. and the EU in a post-Brexit environment, the U.K. and the EU agreed on a Protocol on Social Security Coordination which entered into force on 1 January 2021.

However, the Protocol is limited to the U.K. and EU countries. As a result, the social security position for moves between the U.K. and EEA / EFTA countries and Switzerland was governed by the terms of existing bilateral agreements between the U.K. and Iceland, Norway, and Switzerland, each of them with different provisions, and no agreement was in place between the U.K. and Liechtenstein. Each of these agreements has its own conditions. Therefore, a need to govern rules for social security for workers moving between the U.K. and the countries of the European Economic Area (EEA) and the European Free Trade Association (EFTA) countries arose.

Therefore, on 30 June 2023, the U.K. and the countries of EEA and EFTA (Iceland, Liechtenstein, and Norway) reached agreement on a new social security convention, which governs rules for determination of applicable mandatory social security system for workers moving within these countries. The Convention¹ is in force as of 1 January 2024. For situations between Switzerland and the U.K., the provisions of bilateral social security agreement are still applicable.

If you need assistance on what this means for your employees working from abroad, do not hesitate to contact us.

At the same time, we offer trainings on relevant tax and social security impacts of working from abroad or on setting-up respective internal policies.

¹Convention on Social Security Coordination between Iceland, Liechtenstein, Norway and the United Kingdom of Great Britain and Northern Ireland [MS No.7/2023] - GOV.UK (www.gov.uk)