Social security when living in two EU countries: insurance periods, pensions, healthcare and the 2028 changes

In brief

• At any given time you are insured in one country only and pay contributions only there. Usually that is the country where you work, not where you live.
• Insurance periods from all EU countries, Iceland, Liechtenstein, Norway and Switzerland are added together. Each country pays a pension for its own period, and the money arrives in an account in your country of residence.
• A pensioner who moves receives healthcare on an S1 form at the expense of the country paying the pension. The European Health Insurance Card only works for temporary stays and only in public healthcare.
• Unemployment benefit can be taken to another country for 3 months, up to 6 in some countries, if you were registered as a jobseeker for at least 4 weeks before leaving.
• Non-EU nationals with a legal residence permit benefit from these rules when they move between EU countries, except for Denmark.
• Regulation (EU) 2026/2359 entered into force on 1 November 2026. Most of the new rules on postings, unemployment, family benefits and long-term care apply from 1 November 2028.

The core principle: one country

The system rests on Regulations 883/2004 and 987/2009, which have applied since 2010. The Commission sums them up in four principles. First, you are covered by the legislation of one country only and pay contributions only there. Second, in that country you have the same rights and obligations as its nationals. Third, insurance, work or residence periods in other countries are taken into account where needed to qualify for a benefit. Fourth, cash benefits such as pensions or family benefits can generally be received even if you or your family live in another EU country.

It is just as important to understand what the rules do not do. There is no single European pension and no single European health insurance. Each country decides who is insured, which benefits it grants, how they are calculated and what contributions are due. Coordination only settles which system is responsible for you, and makes sure you are neither left without cover nor paying contributions in two places at once.

The rules apply across the EU and in Iceland, Liechtenstein, Norway and Switzerland; for Switzerland they have applied since 1 April 2012. EU coordination rules stopped applying to the United Kingdom on 1 January 2021. People not covered by the Withdrawal Agreement fall under the protocol to the Trade and Cooperation Agreement, which is similar to the EU rules but does not offer identical protection.

What this means for you. Social security and tax are separate systems. The country where you pay contributions may differ from the country where you are tax resident. We cover the tax side in our article on tax residency for digital nomads and in the glossary entry on the 183-day rule.

Working in one country, living in another

The basic rule is simple: you are subject to the legislation of the country where you actually work, whether employed or self-employed. Where you live and where your employer is based do not matter. If you live in Slovakia and work in Austria, your contributions go to the Austrian system and your benefits follow Austrian rules.

Cross-border workers, also called frontier workers, are a separate category: people who work in one country and return home to another daily or at least once a week. The country of work is responsible for their social security. Such a worker can be treated in both countries on the same terms as local insured people: they register where they work and receive an S1 form, which they register where they live.

There is a limit for families. If you work in Denmark, Ireland, Croatia, Finland, Sweden, Iceland, Norway or the United Kingdom, your family is entitled to medical treatment in those countries only in limited situations. Their main care will be in the country of residence.

Unemployment follows its own logic for frontier workers. If you become fully unemployed, you can claim benefits only in the country where you live. The exception: if during your last period of commuting you went home less than once a week, you can choose between your country of residence and the country where you last worked.

Working in two countries and postings

People who work in several countries at once face the hardest questions. The deciding factor is the share of work done in the country of residence. If a substantial part of your activity, at least 25%, takes place there, you are insured in your country of residence. If it is less, you are insured in the country where your employer's registered office or place of business is located.

If you have several employers based in different countries, you are insured in your country of residence even if most of your work happens elsewhere. A self-employed person without a substantial part of their activity in the country of residence is insured where the centre of interest of their activities is. If you are employed in one country and self-employed in another, the country of employment insures you.

A posted worker, meaning someone sent by an employer to work in another country, or a self-employed person who goes there to work, currently stays in the home system if the posting lasts no more than 24 months. Form A1 confirms this; it is issued by the institution of the country where you are insured. A1 is also needed by people who work in several countries: it shows where your contributions go, so a local inspection will not ask you to pay twice.

What this means for you. If you work for a company in one country but live and do part of your work in another, calculate the share of work done where you live. The 25% threshold decides where you are insured, and therefore where your pension builds up. Get the A1 in advance, not after an inspection.

Insurance periods and pensions from several countries

Insurance periods earned in different countries are not lost. Pension authorities must take into account periods worked in other EU countries as if you had worked in their country all along. This matters where a country sets a minimum insurance period for a pension: years from neighbouring countries help you reach it.

Each country then calculates its pension under a common method. First comes a theoretical amount: what you would receive if your entire career had been in that country. That amount is then reduced in proportion to the time you were actually insured there. This is the pro-rata, or EU, pension. If you qualify for a pension in that country without counting foreign periods, it also calculates a national pension. You receive whichever amount is higher.

If you were insured in a country for less than a year and it does not pay a pension for such short periods, those months are not lost. They are taken into account by the countries where you worked longer.

You apply to the pension authority of the country where you live or where you last worked. If you have never worked in your country of residence, it forwards the claim to your last country of work. Once all countries have decided, you receive form P1, a summary of who has awarded you what.

Each country has its own retirement age. You receive the pension from your country of residence or last work once you reach its legal retirement age, and the parts from other countries when you reach the retirement age of each of them. Each country generally pays into a bank account in the country where you live, if you live in the EU. If you move outside the EU, you may need an account in each country that pays you a pension.

What this means for you. Collect proof of insurance periods from each country while employers and records are still easy to reach. The earlier you have confirmations in hand, the fewer questions when the pension is awarded. Documents in another language may need a sworn translation.

Retiring to a sunny EU country is one of the most common scenarios. We have covered it for Portugal, Cyprus and Greece. For retirees from outside the EU, options include the Portugal D7 residence permit, Spain's non-lucrative visa and Greece's financially independent person permit; the first two are compared in D7 versus the Spanish NLV.

Healthcare: S1, S2 and the European card

A pensioner who moves to another EU country receives healthcare under one of two scenarios. If your country of residence itself pays you a pension that includes healthcare rights, you and your family are covered by its system, even if you also receive pensions from other countries. If your country of residence pays you no pension, you can be treated there if you would be entitled to treatment in the country that pays your pension. To do this, you request an S1 form from that country and register it with the local health insurance institution after you move. From then on you have full coverage where you live.

Full treatment in the country that pays your pension is only available if that country is on a specific list. If it is not, you have full coverage only where you live. Retired frontier workers who are no longer insured in their former country of work keep the right to treatment there with form S3.

The European Health Insurance Card is for temporary stays: travel, study or short assignments. It is free and issued by your health insurer before you leave. It gives you the same rights as people insured in the country you are visiting, but only with providers in the public system. The card does not cover private healthcare, planned treatment, rescue or repatriation. Without the card you may have to pay upfront and claim reimbursement later.

Planned treatment abroad is arranged separately with form S2: your public health insurer issues it if it approves the treatment, and you send it to the counterpart insurer in the country where you will be treated.

The main forms you will meet when living and working in two countries are listed in the table.

We have written separately about how public healthcare works in specific countries: Portugal, Greece and social insurance and GeSY in Cyprus.

Unemployment benefit while looking for work abroad

If you lose your job and want to look for a new one in another EU country, you can take your benefit with you. The conditions are as follows. Before leaving, you must have been registered with the employment services of the country where you became unemployed for at least 4 weeks, although exceptions are possible. You need form U2, the authorisation to export the benefit. In the new country you must register with the employment services within 7 days of ceasing to be available to the employment services at home.

The benefit is paid abroad for at least 3 months and up to 6 months, depending on the country paying it. An extension must be requested before the end of the first three months from the employment service of the country where you became unemployed, and not every country grants one. To keep your entitlement, return to the paying country no later than the day it expires.

If you claim benefit in a country where you worked recently but built up your record elsewhere, ask for form U1 in your last country of work. It shows the insurance periods to be taken into account. Institutions can obtain this data themselves, but the form speeds up the claim.

Family benefits

If the whole family lives and is insured in one country, that country pays family benefits. If parents work or live in different countries, the family may be entitled to benefits in several countries at once, but it will not receive them twice. Priority rules decide who pays.

• Rights based on employment or self-employment come first: the country where the family has that basis is responsible.
• If the parents work in both countries, the country where the children live is responsible, provided one parent works there. Otherwise, the country paying the highest benefits is responsible.
• If pensions are paid in both countries, the children's country of residence is responsible if it pays one of the pensions. Otherwise, it is the country where you were insured or lived longest.
• If the only basis in both countries is residence, the country where the children live is responsible.

If the benefit from the first responsible country is lower than what the second would pay, the second country pays a supplement for the difference. Families whose parents work in different countries should therefore apply in both countries rather than choosing one.

Non-EU nationals with residence permits

Coordination does not stop at EU citizens. According to the Commission, the rules cover nationals of non-EU countries who are legally resident in the EU and have moved between EU countries. The legal basis is Regulation (EU) 1231/2010, which extends the coordination rules to third-country nationals legally resident in the EU who are in a cross-border situation, as well as to their family members and survivors.

The key words are "legally resident" and "cross-border situation". A residence permit in one EU country does not by itself change anything. The rules come into play when, with that status, you have worked or lived in two countries, for example moving from Portugal to Spain, or working in Germany and later obtaining long-term residence in Cyprus. The standard forms S1, U2, A1 and others are valid if you legally live in an EU country, regardless of nationality.

There are exceptions. Regulation 1231/2010 does not apply to Denmark. Non-EU nationals cannot use the European Health Insurance Card for treatment in Denmark, Iceland, Liechtenstein, Norway and Switzerland, apart from specific cases such as refugees and certain family members of EU citizens. Periods worked outside the EU are not aggregated under these rules; only bilateral social security agreements can help there, where they exist.

What this means for you. If you are choosing a country for residence in Europe and plan to work or live in another one later, the coordination rules will work in your favour. If Denmark or an EFTA country is in your plans, check their rules separately.

What changes from 1 November 2028

On 1 November 2026, Regulation (EU) 2026/2359 on the coordination of social security systems entered into force. The European Parliament adopted it on 7 July 2026 and the Council of the EU on 28 September 2026. To give countries time to adapt their procedures, most of the rules apply after two years, from 1 November 2028. This covers applicable legislation, prior notification of postings, long-term care, family benefits and unemployment benefits. More on the decision itself in our news on the new regulation.

The most concrete changes concern postings. A worker must be insured in their home country for at least three months before being posted to another EU country. After 24 months of posting, there must be a break of at least two months before the next one. Postings must be notified in advance, except for business trips and short postings of up to three days in all sectors other than construction. The regulation also introduces a new definition of fraud in social security coordination.

For the unemployed, there will be new arrangements for cross-border cases and a longer period during which you can look for work in another country while keeping your benefit. The Commission's announcements do not give the exact length of the new period; it should be checked in the text of the regulation. Long-term care benefits get a coherent coordination regime for the first time, and family benefits get new rules. The rules on work in two or more countries become clearer. The regulation also clarifies when countries may limit access to benefits for people who are neither working nor looking for work.

Cooperation between authorities will also be strengthened: better exchange of information on the social security status of people working in another country, clearer procedures and timelines when there are doubts about the validity of documents, and new tools against fraud, abuse and errors.

What this means for you. Until November 2028 the current rules apply. If you are planning a long posting or work in two countries for 2028-2030, build in the new requirements now: three months of insurance before posting and a break after 24 months.

Where to start

If you are moving together with a business, our business relocation support can help, and we align taxes across several countries through our tax coordination service. Documents for applications are covered in the documents section. The glossary explains habitual residence, remote-work programmes are listed under digital nomad visas, and for a permanent status consider Cyprus permanent residence and Malta permanent residence. You can discuss your situation in an online consultation.

How this article was prepared

Sources: the news item of the European Commission's Directorate-General for Employment, Social Affairs and Inclusion of 1 November 2026 on the entry into force of Regulation (EU) 2026/2359; the Commission's section on EU social security coordination, including the pages "Which rules apply to you?", "Family benefits" and "EU legislation"; the EU portal Your Europe, pages on state pensions abroad, transferring unemployment benefits, unemployment abroad, health insurance cover when living abroad, the European Health Insurance Card, planned treatment and standard social security forms; Regulations 883/2004, 987/2009 and 1231/2010. Information as of 1 November 2026. National pension and benefit conditions should be checked with the authorities of the country concerned. This article does not replace advice on your individual situation.