Why the whole chain must work

Even an early application can come too late

Under the current rules, the challenge is that clarifying social security coverage often takes time.  

Imagine that a decision is made roughly a year before the start date that an employee is to work in Norway. The employer and employee begin the process of applying to clarify social security coverage as early as practically possible. Before the application can be submitted, however, the facts must be established, the correct coordination rule identified and the necessary documentation gathered. Processing time may then run over several months, and further time may pass before the decision has been transmitted through official channels, registered with NAV and the information is available to the Norwegian Tax Administration (Skatteetaten).   

In such an example, based on the current rules, a substantial part of the working period may have elapsed before the A1 document is in place, and it may approach a year from when the process starts until the Norwegian authorities can fully rely on the clarified foreign social security coverage. 

If the information is not in place when the employee's tax return is to be filed, Norwegian social security contributions may initially be assessed even though, under the substantive rules, the person should be covered by another country's social security system.   

For the employer, the issue can arise even earlier. Registration of the employment in Norway may trigger questions about other Norwegian employer obligations long before foreign social security coverage has been fully verified in the Norwegian systems.  

And this is a relatively favourable example, where the mobility is known well in advance. In our experience, employers rarely know a year ahead that an employee will work in another country. Six months or less is often a more realistic planning window. 

Norwegian systems already depend on exchange between authorities

Today's Norwegian process illustrates how much depends on the flow of information actually working. 

An employee who considers that they should not pay Norwegian social security contributions should not send the A1 document directly to the Tax Administration. The documentation is to be handled by NAV, and if NAV registers that the employee is not a member of the National Insurance Scheme (folketrygden), a message is sent on to the Tax Administration.  

The same applies to employer's social security contributions (arbeidsgiveravgift). No Norwegian employer's social security contribution is payable when the employee is covered by the social security legislation of another EEA country, but the Norwegian tax authorities rely on an electronic message from NAV. An A1 document that the employer or employee presents on their own is, under current guidance, not in itself sufficient documentation for an exemption.  

It is worth noting that the Norwegian authorities do not, strictly speaking, rely on the public-facing form itself. The A1 is the form the employee receives from their social security authority, but it is the structured electronic message (SED) from that same authority that is relied upon when NAV registers that the employee is exempt from the National Insurance Scheme. The bottleneck therefore lies in the exchange between institutions, not in the citizen-facing document. 

That a final exemption from Norwegian charges should rest on a decision verified through the relevant official channels is understandable, but it creates significant practical challenges if the authorities' exchange of information does not keep pace with labor mobility. It makes the employer dependent not only on a correct substantive assessment and a correct A1 decision, but also on the flow of information between authorities actually working.   

Workers' mobility, moreover, does not necessarily follow the borders of the EU's digital infrastructure. The United Kingdom is a practically important example of a country with which Norway has extensive social security cooperation, but which stands outside the EU system.

Digitalization is the right direction – but the whole chain must work

Digitalizing social security documents is the right direction. The aim is to make key documents digital and easier to verify across borders. Another aim is better interplay between national portals for A1 applications and the authorities' systems for exchanging information.  

Regulatory development and digitalisation are connected. When the legislator requires that the applicable legislation be clarified faster than today, digitalisation and strengthened electronic information exchange are the tools meant to make that ambition practically achievable.  But the gain depends on implementation. A requirement for faster clarification only has real effect if the infrastructure meant to carry it is actually in place. 

It is not enough for the A1 document itself to become digital if processing times remain long, the exchange of information between authorities is not fast enough, or national systems do not receive the information in time. 

As long as the digital document flow is not yet complete, it is important that administrative practice takes this into account. Reporting solutions that make it possible to apply a well-founded expected social security coverage while the A1 application is being processed should, in our view, not be tightened before the exchange of information between authorities is sufficiently fast and robust. Such a starting point also finds support in the coordination rules themselves, which provide that the applicable legislation is determined regardless of whether an A1 has been applied for or issued.  

Otherwise, there is a risk that stricter documentation requirements and inadequate digital infrastructure will increase – rather than reduce – the administrative burden on employers and employees. 

Digitalising the A1 is a benefit. But only when the whole chain works – from application and decision to exchange between authorities and practical handling in payroll and tax – will employers and employees obtain the flexibility and simplification that digitalisation is meant to deliver. 

Status of regulatory developments (updated October 2026) 

The rules in this area are evolving, and several processes are running in parallel. On 15 September 2026, the European Commission presented its Fair Labour Mobility Package. A central measure is the introduction of a digital European Social Security Pass (ESSPASS), which is to make it possible to request, store and present key social security documents digitally through the EU Digital Identity Wallet. The A1 document for posted workers is, according to the plan, to be first out, one year after the ESSPASS Regulation enters into force.  ESSPASS must still be considered by the European Parliament and the Council before it can enter into force.   

In parallel, on 28 September 2026 the Council adopted the revision of the social security coordination rules themselves (Regulation (EC) No 883/2004 and 987/2009), which, after nearly a decade of negotiations, is intended to make the rules clearer, fairer and easier to enforce. The revision includes, among other things, new procedures for the A1 – the social security authority must either issue a confirmation immediately or acknowledge receipt of the application, and a provisional determination becomes final after two months unless an institution objects. The substantive A1 changes apply only 24 months after the regulation is published in the Official Journal. 

For Norway, a further step is added: the rules apply here through the EEA Agreement, and the amending regulation must be incorporated into the EEA Agreement before it takes effect in Norway. The 24-month deadline is therefore an earliest point in time seen from the Norwegian side.  

This section will be updated when the rules are published and incorporated into the EEA Agreement.