Cross-border teleworking: what social security coverage is available?

You work remotely from your country of residence for an employer based in another country. Two figures appear frequently in the Cleiss website: 25 % and 50 %. They do not serve the same purpose. From 25 % of working time or remuneration earned in your country of residence, it is generally the social security system of that country that applies. A framework agreement then allows you to remain affiliated in the employer's country, provided, in particular, that remote work represents less than 50 % of your working time. The 50 % threshold is therefore a condition of the framework agreement, not the threshold for switching to the other system.

This page is based on information from the Cleiss (Centre for European and International Social Security Liaison). It deals with employee social security. It does not cover income tax in detail, contribution amounts, the procedures in Switzerland or Luxembourg, or self-employed workers.

Two thresholds, two roles

Cleiss states that the framework agreement requires that teleworking represent less than 50% of total working time. The page does not address the case of teleworking that represents exactly 50% of total working time.

The threshold of 25 %: the basic rule

The Cleiss writes that an employee working in several countries (European Union, European Economic Area, or Switzerland) falls under the jurisdiction of their country of residence if they carry out a substantial part of their activity there: "at least 25% of their working time or remuneration." The criterion is therefore time or remuneration.

These two lines are the basic rule, before any exception.

The exemption at the employer's request

Beyond 25 % hours, the employer may request that you maintain your social security affiliation in the country where the company is located. The Cleiss writes that Article 16 of the Coordination Regulation allows for an exception to Articles 11 to 15, and that this exception is not specific to cross-border teleworking. The employer may request it "with your agreement and in your interest," subject to the agreement of the country of residence.

The employer submits the request to the competent institution in the country where the company is established. For France, the Cleiss cites the Urssaf, or the MSA for an agricultural worker. According to the Cleiss, this institution then contacts the competent institution in the employee's country of residence, whose agreement is required. Box 3.11 of portable document A1 relates to the framework agreement procedure, described below.

The framework agreement on cross-border teleworking

The Cleiss describes a framework agreement that entered into force on July 1, 2023. Between signatory states, joint agreement between institutions is presumed, thus allowing for a simplified procedure. The framework agreement can only be used if all the conditions are met.

When the conditions are met, the competent institution in the employer's state issues the A1 form with box 3.11 checked. The maximum duration of the exemption is 3 years. Extensions may be granted upon a new request from the employer.

The situations that Cleiss places outside the framework agreement

Cleiss also lists situations that are not covered by the framework agreement:

• a self-employed activity; ;
• employers headquartered in different states; ;
• teleworking that goes too far; ;
• teleworking less than 25 %, which remains subject to affiliation in the State of the company (article 13); ;
• an activity other than teleworking in the State of residence; ;
• 100% teleworking %, which leads to affiliation to the State teleworking scheme (Article 11, paragraph 3 a).

Has your country signed the framework agreement?

The Cleiss report notes that the framework agreement has not been signed by all member states of the European Union, the European Economic Area, and Switzerland. The list published by Cleiss, updated as of February 1, 2026, includes France, Luxembourg, and Switzerland. A state can join later: Estonia has been on the list since February 1, 2026. A signatory state can also withdraw from the agreement after three months' notice.

Greece, for example, was not a signatory as of January 1, 2026. Check the updated list for your country of residence and that of your employer before taking any action. The Cleiss also refers to the interministerial instruction DSS/DACI/2023/155 of September 27, 2023.

Two examples that Cleiss includes among the situations covered

Cleiss gives two examples under the heading "Examples of situations covered by the Framework Agreement":

• an employer established in Switzerland, an employee residing in France who teleworks 2 days a week from home and works the other 3 days at the company's premises in Switzerland; ;
• An employee who teleworks from Luxembourg 2 days a week works 2 days at the French headquarters and 1 day for another employer established in France.

In both cases, teleworking represents 2 out of 5 days, or 40 %, assuming a 5-day week (an assumption not explicitly stated by Cleiss). The other conditions remain to be verified on a case-by-case basis.

Social security is not a tax

The two topics are not governed by the same rules. The Cleiss website deals with social security. Income tax depends on the tax treaty between the two countries. For Luxembourg, the sister page on Luxembourg cross-border workers explains the 34-day tax threshold. For Switzerland, the Q&A on impots.gouv.fr, "Am I a cross-border worker?" (updated May 21, 2026), states that two amicable agreements concluded between France and Switzerland on December 22, 2022, "introduce a new tolerance regarding days of temporary assignments." This page has not reviewed the content of these agreements: it does not specify a number of days.

Claire, 20, 40 or 60, % of teleworking: a numerical example (fictitious profile)

Situation. Claire, a fictional employee, lives in France and works for a company based in Switzerland. Her work week consists of 5 days. She has only one employer. Assumptions in this profile: her salary is distributed in line with her working hours, so the amount of teleworking is the same in terms of both time and pay.

Issue. How many days of teleworking per week before crossing the Cleiss thresholds?

Strategy. Compare the share of teleworking to the two thresholds: 25 % (basic rule) and 50 % (condition of the framework agreement).

Result.

At one day per week, the basic rule refers to the state where the company is located. At two days, the threshold of 25 % is reached, and the condition of 50 % is met in this respect: remaining in the state where the company is located then requires a request from the employer and the other conditions of the framework agreement. At three days, the condition of 50 % is no longer met: the framework agreement is not applicable, and the derogation under Article 16, at the employer's request, requires the agreement of the state of residence.

This profile is fictitious. The days, the 5-day week, and equal pay for work are assumptions. The calculation illustrates the thresholds. It does not predict your situation.

Cross-border teleworking: what changes depending on your situation

• Your share of teleworking, measured in time or in remuneration.
• Your employers : one, or several established in the same State.
• Your other activities in the state of residence.
• The accession of the two states to the framework agreement, on the date of your request.
• Your status : salaried employee or self-employed worker.

The rule depends on your situation. No results are guaranteed.