When an employee works temporarily in another country, the employer must decide which country's social security applies, which host employment rules apply and whether the home system can be kept. Inside the EU, a posted worker can stay in the home system for up to 24 months with an A1 certificate, but after 12 to 18 months almost all host employment terms apply. Outside the EU, bilateral totalisation agreements do the same job, but the US and India have no agreements with the Gulf states or Singapore, so double contributions are common on those routes.
Postings within the EU
Under Regulation (EC) No 883/2004 a worker posted by the employer to another EU country for up to 24 months remains insured in the sending country if the posting conditions are met, and the Portable Document A1 certifies which legislation applies. Employment terms follow separate rules: under the revised Posting of Workers Directive, once a posting exceeds 12 months, or 18 months after a motivated notification, the employer must apply all the host country's applicable terms and conditions of employment, except contract conclusion and termination procedures and supplementary occupational pensions.123
Totalisation agreements outside the EU
US totalisation agreements generally keep an employee sent abroad by the employer for five years or less in the home system, with a certificate of coverage as proof. The Social Security Administration lists 31 agreement countries, including France, Germany and the UK, but not India, the UAE, Saudi Arabia or Singapore.
India's provident fund treats any employee with a non-Indian passport as an international worker who contributes on full salary without the usual wage ceiling, unless they are from a country with which India has a social security agreement and hold a certificate of coverage, or are Singapore nationals contributing at home under the 2005 India-Singapore agreement. India's listed agreements cover mainly European countries, Canada, Australia, Japan, Korea and Brazil.456789
Gulf and Singapore postings
The Gulf systems largely exclude foreign staff. In the UAE, non-GCC nationals are not subject to social security, and other GCC nationals contribute under their home system, so a seconded expatriate usually has no host contribution. Singapore's CPF does not cover foreign employees on work passes. The cost on these routes is more often the home-country contribution that continues during the secondment, and in India the full-salary provident fund contribution for an incoming foreign worker.10117
| Route | Rule | Maximum period or condition | Source |
|---|---|---|---|
| Within the EU | Home social security with Portable Document A1 | Up to 24 months | Regulation (EC) No 883/2004 (INPS explanation) |
| Within the EU (employment terms) | Host terms apply in full after a long posting | After 12 months, or 18 months with notification | Directive (EU) 2018/957 |
| US to or from an agreement country | Detached-worker rule; certificate of coverage | Five years or less (three for Denmark to US) | SSA; IRS |
| Into India | International worker contributes on full salary | Excluded if from an agreement country with a certificate of coverage, or a Singapore national | EPFO |
| Into the UAE | No social security for non-GCC nationals | GCC nationals follow their home system | PwC (secondary) |
Decisions to make
- Is there a social security agreement between the home and host countries?59Without one, the employee may be covered, and charged, in both countries.
- How long will the assignment last?134EU home coverage lasts up to 24 months, host employment terms apply in full after 12 to 18 months, and US agreements generally cover up to five years.
- Have we obtained the A1 or certificate of coverage before the move?26The certificate is the evidence of exemption in the host country.
- Is a foreign employee moving into India excluded from the provident fund?78Otherwise contributions apply on full salary without the usual ceiling.
Documents usually needed
- Secondment or assignment letter stating duration, home employer and host entity
- Portable Document A1 or certificate of coverage from the home institution
- Host-country posting declaration where required
- Comparison of home and host employment terms for postings over 12 months in the EU
- Immigration permission for the host country
Common mistakes
- Starting an assignment before the A1 or certificate of coverage is issued
- Assuming the US has a totalisation agreement with India, the UAE, Saudi Arabia or Singapore
- Overlooking India's full-salary provident fund contribution for incoming foreign staff
- Keeping home employment terms unchanged on an EU posting that passes 12 months
Questions businesses ask
How long can an employee stay in the home social security system on an EU posting?
Up to 24 months under Regulation (EC) No 883/2004, if the posting conditions are met and a Portable Document A1 is obtained.12
Does a US employee seconded to Dubai keep US social security?
The US has no totalisation agreement with the UAE, so the agreement route is not available. Whether US social security continues depends on US domestic rules, which were not researched here. Non-GCC nationals are not subject to UAE social security.510
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- The UK-EU social security coordination rules for detached workers after Brexit could not be confirmed: the GOV.UK pages failed to load.
- The SSA status page listing agreements in force could not yet be checked; the list comes from the agreement descriptions page.
- Any India-UK social security arrangement and India's current provident fund rules for international workers under the Code on Social Security were not confirmed.
- Singapore, Saudi Arabia and Germany bilateral agreements were not researched.
- Host-country posting declarations and tax residence effects of secondments were not covered.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Questions on this topic
10 statements on secondments, posted workers and social security agreements
