The transitional period provides a useful planning window, but the preparatory work is substantial and largely internal. Employers can begin now.
Steps to prepare the organization:
- Reassess case classification to identify genuine posting situations, which will be subject to a prior A1 application, and distinguish them from multi-state working. Borderline cases carry the greatest exposure: a case wrongly treated as multi-state working may mean the A1 is not requested before work begins.
- Integrate an early social security assessment into existing mobility and travel workflows, so that the analysis is completed before travel is approved rather than afterwards.
- Establish a procedure confirming that, for posting situations, A1 applications are filed before work in the destination country begins, as the timing and documentation of postings will carry significantly greater weight under the revised rules.
- Screen for the three-month prior affiliation condition, which may disqualify recently hired or transferred employees from postings permissible under the current rules.
Member states and social security institutions will use the transitional period to adapt legal frameworks, adjust IT systems, and update administrative practices and guidance. Implementation is expected to vary in pace across jurisdictions, and practical detail — forms, portals, and evidentiary standards — is likely to emerge unevenly.
KPMG will monitor publication of the regulation in the Official Journal and confirm the application dates for the coordination rules once the text is available, together with further updates as national implementation develops.
For questions regarding the implications for your organization, or assistance in scoping the preparatory steps outlined above, please contact your usual KPMG Global Mobility Services adviser.