Quick Overview of the Posted Worker Model in Europe
What is a posted worker, and when do you use it?
A posted worker is a model where you send an employee from your company in one country to provide services in another European country for a specific period. The employee retains their employment contract and insurance obligations in the sending country while executing a project in the host country. You achieve strong results in construction, industrial assembly, maintenance, IT, consulting, and field commissioning projects.
This model accelerates project-based work and provides access to the field without establishing a permanent legal entity. However, you must manage notifications, A1 social security, equal pay, and local occupational health and safety regulations comprehensively; thus, you proceed risk-free during audits.
- EU Directive 2018/957: Strengthens the principle of “equal pay for equal work in the same place.”
- 12/18 month threshold: In long-term assignments, the broader working conditions of the host country come into play.
- A1 certificate: Allows you to maintain social security in the country of origin for up to 24 months.
Emerging Trends and Updates as We Enter 2025
Joint inspections coordinated by the European Labour Authority (ELA) are increasing. Many countries are moving notifications entirely to digital portals. The Netherlands will switch to an hourly minimum wage in 2024; Germany will raise its hourly minimum wage to €12.82 in 2025. These changes will directly impact your wage and payroll calculations. Site inspections in construction and logistics are becoming more frequent; shared responsibility in the subcontractor chain is becoming widespread.
Corpenza standardizes notification processes in this context, manages country-specific requirements through a single window, and clarifies wage/benefit comparisons according to your project.
For Which Profiles is it Most Efficient?
- Short and medium-term field projects (assembly, commissioning, maintenance)
- Temporary assignments in roles requiring high expertise
- Warranty/service teams on the client’s site
- Subcontracting and subcontractor agreements within the EU
Fundamentals of Compliance: Notification, A1, and Compensation
Mandatory Notification and Portal Map by Country
You must notify before starting the assignment. You appoint an authorized representative on-site and keep essential documents ready at the construction site. The following portals are primary examples:
- France: SIPSI
- Germany: Zoll Meldeportal-Mindestlohn
- Netherlands: Posted Workers Notification (WagwEU portal)
- Belgium: LIMOSA
- Luxembourg: e-Détachement
- Italy: Regional processes via Cliclavoro
- Portugal: ACT – Comunicaçao Prévia de Destacamento
The notification includes employer information, project address, scope of work, duration, working hours, wage items, and contact information of the representative on-site. You complete the notification before the start date; otherwise, you may face administrative fines and project delays.
A1 Social Security: 24-Month Rule and Practical Limits
With the A1 certificate, you maintain social security in the country of origin for up to 24 months. The employee does not fill a permanent replacement; the employer conducts significant activities in the country of origin. If an extension is necessary, you plan an exception consultation between the relevant authorities. The absence of an A1 can lead to social security risks in the host country and a retrospective premium agenda.
- You initiate the A1 application alongside the project timeline.
- You present the A1 physically or digitally on-site and during audits.
- You anticipate the possibility of an extension in the 9th to 12th months and initiate contacts.
Equal Pay, Benefits, and the 12/18 Month Threshold
You base your understanding of “wage” on the host country’s definition; you consider not only the minimum wage but also bonuses, overtime, field premiums, industrial supplements, and collective agreement provisions. You manage travel, accommodation, and meal expenses outside of wages; you do not make deductions from payroll. If the assignment exceeds 12 months (extendable up to 18 months with reasonable justification), you apply the broader working conditions of the host country.
- You formalize the wage comparison in writing.
- If there is a collective agreement, you verify the scope and regional applicability.
- If you provide accommodation, you obtain a compliance report according to local standards.
Operational Design: Payroll, EOR, and Temporary Employment
Payroll and Expense Management: Legally Managing Remote Teams
In international payroll design, you consolidate wage, benefit, and expense management under one roof. When you structure payroll through Corpenza, you expense the salaries of remote employees and those working under contract in compliance with local legislation. This ensures your accounting records progress transparently, and your files appear consistent during audits.
- Gross-net simulation and cost projection
- Multi-country “shadow payroll” scenario
- Tax impact of benefits and reporting
Temporary Employment and Posted Worker Scenarios
When project-based fluctuating capacity needs arise, you implement the temporary employment (staff leasing) model. Corpenza acts as a temporary employment agency, quickly moving the workforce to the field with posted worker services; it manages contracts, payroll, and on-site representation from a single source. This clarifies responsibilities in the chain and reduces the risk of disruptions on the client’s site.
- Clarity in assignment contracts and job descriptions
- Site safety and training records
- Responsibility maps in the subcontractor chain
Tax, Economic Employer, and Permanent Establishment (PE) Risk
A long-term field presence can trigger corporate tax and PE risks. The management of the role, the instruction chain, and the contract flow affect the “economic employer” analysis. You plan double taxation agreements, withholding obligations, and potential “split payroll” structures from the outset. Corpenza models tax optimization within the legal framework; you strengthen document flow with transfer pricing and service contracts.
- You work on the PE risk matrix at the project start.
- You write invoice texts in line with the activity.
- You align reporting with local timelines.
Residency, Work Permits, and Alternative Paths
EU Citizens, Non-EU Citizens, and the Van der Elst Exception
EU citizens enjoy the advantage of free movement in the posted worker process; however, you still fully apply notification, wage, occupational health and safety, and representation responsibilities. The situation differs for non-EU citizens; most countries require additional work permits or visas. In some countries, the Van der Elst exception opens doors under certain conditions; however, you carefully read the sensitive rules that vary by sector, duration, and previous residency status.
- You determine the need for a visa/work permit based on the role, duration, and country in advance.
- You plan immigration regulations separately with the A1.
- You schedule document translation and apostille processes.
Golden Visa, Citizenship by Investment, and Mobility Strategy
Golden Visa and citizenship by investment options in founder and investor profiles provide permanent comfort in mobility. If you have goals such as family reunification, children’s education, and Schengen access, you clarify the investment amount, source proof, and duration criteria. Corpenza strengthens the application file with financial and legal evidence; you eliminate risky items from the start.
Company Formation, Permanent Residency, and Work Permits
If your project gains continuity, you plan local company formation and local payroll for permanent residency. The Blue Card, Highly Skilled, ICT, and entrepreneur visas transfer talents to permanent positions and accelerate knowledge transfer between teams. Corpenza breaks down the establishment, tax numbers, banking, accounting, and payroll flow into weeks; you align activity permits and sector licenses on the same timeline.
Tax Optimization: A Clear Model Within Legal Limits
The essence of tax planning is determined by “tangible assets and functions.” You support intra-group services, pricing, and contract flow with documentation. You track withholding provisions, stay durations, and executive visits on a single dashboard. This way, you prevent unexpected tax liabilities before the project ends.
Field Tips, Country Examples, and 2025 Opportunities
Country-Based Practical Checklists
- France (SIPSI): You prepare the representative appointment and French document set; you document the accommodation standard according to local criteria.
- Germany (Meldeportal): You meticulously maintain records of minimum wage, working hours, and site entry-exit; you are ready for Zoll audits.
- Netherlands (WagwEU): You make the notification before starting work; you verify the collective agreement scope at the regional and sector level.
- Belgium (LIMOSA): You add site card (e.g., Checkin@Work) requirements based on the project type.
- Luxembourg (e-Détachement): You monitor ITM announcements and complete site safety documentation thoroughly.
- Portugal (ACT): You prepare assignment letters in Portuguese and transparently list wage items.
Audit, Document Retention, and Representation
The auditor requests understandable documents on-site. You keep the file ready before a request comes:
- A1 certificate and insurance policies
- Employment contract, assignment letter, wage breakdown
- Working hours, overtime, and leave records
- OHS training, risk assessment, equipment certifications
- Accommodation and travel expense policy
- Local representative authorization letter and contact information
Presenting documents in the local language speeds up the audit. In construction and industrial facilities, you keep personal protective equipment, site briefings, and emergency plans visible.
2025 Agenda: Regulations and Market Opportunities
- Digital portals become widespread; notifications accelerate, and errors become more visible. You automate the pre-notification checklist.
- Minimum wage and collective agreement updates become more frequent; you establish a periodic wage benchmark cycle.
- ELA-focused sector inspections increase; you clearly write the sharing of responsibilities in the subcontractor chain in the contract.
- Cross-border service demand grows with energy transformation, data centers, and infrastructure modernization; you plan your mobile teams according to the competency matrix.
A Clear Roadmap with Corpenza
- Pre-analysis: We map the country, duration, role, and contract flow together.
- Implementation: We establish notifications, A1, wage comparisons, representation, and OHS documents end-to-end.
- Operation: We manage payroll, expense management, and reporting in a monthly cycle.
- Strategy: We link company formation, tax optimization, and permanent residency/work permits to your growth plan.
Clear rules, correct documents, and discipline in the field accelerate you in the posted worker model. Corpenza offers residence permits, company formation, golden visa, international accounting, payroll, staff leasing (posted worker), citizenship by investment, and tax optimization services under one roof in Europe and globally. You grow your projects in a compliant, predictable, and sustainable manner.
