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A1 certificates in social security and payroll audits

Why A1 certificates matter in later employer and social security audits

Written by Hazem Emad

The table shows whether employers in each country are subject to social security, payroll or employer audits in which the authorities can review the social security coverage of employees who worked abroad.

This is relevant for A1 compliance because an employee may temporarily work in another country while remaining covered by the social security system of the home country.

For example, a UK employee working temporarily from Cyprus may remain subject to UK social security. The employer therefore continues paying UK National Insurance contributions during the period abroad. The A1 certificate documents that UK social security legislation continues to apply despite the employee physically working in Cyprus.

The same principle applies across the EU/EEA, Switzerland and the UK.

During a later employer or social security audit, the home-country authority may review whether continued home-country social security coverage during periods of work abroad was correct. The A1 certificate provides the evidence for that coverage.

This means that A1 compliance is not only relevant because an authority in the country of work might request the certificate. It can also become relevant later during an audit of the employer in the employee's home country.

The table works in both directions: the same authorities audit both the home-country case (an employee insured in that country who works abroad) and the inbound case (an employee working in that country while insured elsewhere, where the foreign A1 certificate proves that no local contributions were due).

For employers with employees working abroad, the practical consequence is therefore clear: where an A1 is required, the employer should obtain and retain it as part of its social security documentation for the relevant period abroad.

The audit frequency differs significantly between countries. Some countries carry out periodic employer audits, while others use risk-based selection, data analysis, complaints or specific audit campaigns. However, in each case identified in the table, the employer's social security treatment of employees may be subject to review.

Country

Audit / inspection possible?

Authority

Legal basis

Frequency / trigger, where known

Austria

YES

Tax authorities / ÖGK – GPLB

Sec. 41a ASVG; PLABG

Audit planning and specific concerns. No fixed four-year cycle.

Belgium

YES

Social Inspectorate / NSSO

Social Criminal Code, Arts. 22–49

Ex officio, complaints, authority referrals, judicial requests, campaigns or work accidents.

Bulgaria

YES

National Revenue Agency (NRA/NAP)

Tax and Social Security Procedure Code

Tax and social security controls. No fixed statutory audit cycle identified.

Croatia

YES

Tax Administration / competent social security and inspection authorities

Tax and compulsory contribution legislation

Employer and contribution audits. Specific selection criteria not conclusively verified.

Cyprus

YES

Ministry of Labour and Social Insurance / Labour Inspectorate

Social Insurance Law 59(I)/2010; Labour Inspectorate Law 88(I)/2020

Monthly targeted campaigns, complaints, proactive inspections and risk indicators.

Czech Republic

YES

Czech Social Security Administration / District Social Security Administration

Act No. 582/1991 Coll.; Act No. 589/1992 Coll.

Employer audits covering registration and social security contributions. No fixed cycle verified.

Denmark

YES

Danish Tax Administration

Kildeskatteloven Sec. 86

Document-based controls and business visits. No general fixed cycle identified.

Estonia

YES

Tax and Customs Board (MTA)

Taxation Act Secs. 73 et seq.; Social Tax Act

Tax audits may cover specific taxes and factual issues, including social tax. No fixed cycle.

Finland

YES

Finnish Centre for Pensions / pension insurance institutions

Employees Pensions Act (TyEL), Sec. 188

Statutory employer audit powers plus monitoring through income register data. No fixed cycle.

France

YES

URSSAF

Code de la sécurité sociale, Arts. L243-7 et seq.; R243-59 et seq.

Audit programmes and risk / case selection. No fixed cycle for every employer.

Germany

YES

German Pension Insurance

Sec. 28p(1) SGB IV

Every employer is audited at least every four years. Earlier audits are possible in specific cases.

Greece

YES

e-EFKA / PEKA

Law 4445/2016 and related social security audit provisions

Regular and extraordinary audits covering employer declarations, payroll and insurance treatment.

Hungary

YES

NAV

Act CL of 2017 on the Rules of Taxation and social contribution legislation

Tax and contribution audits. No general fixed audit cycle verified.

Ireland

YES

Revenue Commissioners

Revenue legislation and Code of Practice for Revenue Compliance Interventions

Risk-based. Level 2 Risk Reviews and audits may cover PAYE, PRSI and USC.

Italy

YES

National Labour Inspectorate (INL) / National Social Security Institute (INPS)

Legislative Decree 149/2015 and social security legislation

Audit programmes, targeted controls and case-specific inspections. No fixed cycle.

Latvia

YES

State Revenue Service (VID)

Law on Taxes and Duties and state social insurance legislation

Tax controls and audits. May be triggered by inconsistencies or information from other authorities.

Lithuania

YES

Sodra / State Tax Inspectorate

Law on State Social Insurance; Law on Tax Administration

Employer and social security audits. No general fixed cycle.

Luxembourg

YES

CCSS / competent social security authorities

Code de la sécurité sociale

Employer reporting and contribution compliance may be reviewed. No fixed audit cycle identified.

Malta

YES

Commissioner for Revenue / Department of Social Security

Social Security Act, Cap. 318 and tax legislation

Payroll and contribution compliance controls. Exact audit triggers not conclusively verified.

Netherlands

YES

Dutch Tax and Customs Administration

Algemene wet inzake rijksbelastingen (AWR)

Boekenonderzoek, business visits and other controls. Audits may focus on specific periods or issues.

Poland

YES

ZUS

Arts. 86 et seq. of the Social Insurance System Act

Audit planning and risk selection. Extraordinary audits are also possible.

Portugal

YES

Social Security Inspection Services

Social Security Contributions Code and inspection legislation

Employer and contribution audits. No general fixed cycle verified.

Romania

YES

ANAF

Fiscal Procedure Code, Law 207/2015, Arts. 113–119

Risk-based. General or partial fiscal inspections based on identified fiscal risk.

Slovakia

YES

Social Insurance Agency

Act No. 461/2003 Coll. on Social Insurance

Centrally prepared six-month audit plans. Extraordinary audits may follow reports or information received.

Slovenia

YES

Financial Administration (FURS)

Tax Procedure Act (ZDavP-2)

Tax audits may cover social security contributions and may be expanded if underpayment is suspected.

Spain

YES

Labour and Social Security Inspectorate (ITSS) / TGSS

Law 23/2015 and General Social Security Law

Inspection planning, complaints, referrals or other information. No fixed employer audit cycle.

Sweden

YES

Swedish Tax Agency

Tax Procedure Act (2011:1244)

Tax audits may cover employer contributions. No general fixed cycle.

Iceland

YES

Icelandic Revenue and Customs

Tax legislation and Social Security Tax Act (Act No. 113/1990)

Employer payroll and social security tax can be audited. No fixed audit cycle identified. Detailed selection criteria not conclusively verified.

Liechtenstein

YES

AHV-IV-FAK

Art. 28(2) AHVG; Art. 63(1) AHVV

Periodic employer audits by auditors with access to relevant accounting and personnel records.

Norway

YES

Norwegian Tax Administration

Tax Administration Act and National Insurance legislation

Tax / contribution audits plus automated controls of monthly A-melding data. No fixed audit cycle.

Switzerland

YES

AHV compensation funds / audit bodies

Art. 68 AHVG; Art. 162 AHVV

Statutory periodic employer audits. No fixed four-year cycle comparable to Germany; intervals depend on the Swiss audit framework.

United Kingdom

YES

HMRC

Finance Act 2008, Schedule 36 and NIC legislation

Risk-based Employer Compliance Checks. No fixed cycle. NIC treatment may be reviewed as part of the audit.

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