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

If you work remotely from your country of residence for an employer based in another country, two thresholds apply. From 25% of working time or remuneration earned in your country of residence, you are generally covered by that country's social security system. A framework agreement then allows you to remain affiliated with the employer's country, provided, in particular, that your remote work remains below 50% of your working time. The 50% threshold is therefore not the switching threshold; it is a condition of the framework agreement.

This page is based on information from the Cleiss (Centre for European and International Social Security Liaison). It deals with social security. It does not cover income tax, health insurance contributions in Switzerland, contribution amounts, or the procedures on the Swiss side.

The threshold of 25 %: the basic rule

Cleiss writes that an employee who works in several states (EU, EEA, Switzerland) falls under the jurisdiction of their state of residence if they carry out a substantial part of their activity there: "at least 25% of 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 %, the employer can request that you maintain your affiliation in the state where the company is located. The Cleiss writes that the employer can, "with your agreement and in your best interest, request your continued or renewed affiliation." This process requires the agreement of your state of residence.

The employer submits the application to the relevant institution in the country where the company is established. If the company is established in France, the relevant body is the Urssaf (or the MSA for agricultural workers). The Cleiss indicates that you must be in possession of the portable document A1, which certifies the applicable social security legislation.

The framework agreement on cross-border teleworking

The Cleiss describes a framework agreement in force since July 1, 2023. It allows for an accelerated procedure: it "presupposes the agreement of the competent institutions." It only applies under several conditions.

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.

Has your country signed the framework agreement?

The Cleiss writes that the framework agreement "has not been signed by all EU/EEA/Swiss states." The list published by the Cleiss, updated as of February 1, 2026, includes France and Switzerland. A state can accede later. A signatory state can also denounce the agreement at any time, after giving three months' notice.

The list is subject to change. Cleiss advises checking it before taking any action: Greece, for example, was not a signatory on January 1, 2026, while Estonia is on the list as of February 1, 2026. Cleiss also refers to the interministerial instruction DSS/DACI/2023/155 of September 27, 2023, concerning the implementation of the framework agreement.

The case of a Swiss employer and a French resident

Cleiss itself provides an example: an employer established in Switzerland, a French resident employee who teleworks two days a week from their home in France and works the other three days at the company's premises in Switzerland. Cleiss categorizes this example under the heading "Examples of situations covered by the Framework Agreement".

Note above all that Switzerland and France are both included in the list published by Cleiss, updated on February 1, 2026. It remains to check the other conditions of the framework agreement for your case: only one employer or employers in the same State, no other activity in the State of residence, no self-employed status.

Cross-border 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 can she do without exceeding the Cleiss thresholds?

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

Result. The calculation yields:

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 50 % condition is met in this respect. Maintaining the company in the state where it is located requires a request from the employer and compliance with other conditions. At three days, the 50 % condition is no longer met: the framework agreement is not applicable, and the derogation from the employer's request, described above, 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.

What this page doesn't say

• Income tax. The Cleiss website deals with social security. Teleworking also has tax implications, which are determined by the applicable tax treaty. For cross-border workers, the France-Switzerland agreement refers to an agreement dated April 11, 1983 (Article 17 § 4); this page does not read its contents.
• Health insurance and contributions. Cleiss simply states that Switzerland applies European social security coordination regulations. No rates are given here.
• The independents. The framework agreement does not cover them.

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.
• Membership of your country of residence and that of your employer to the framework agreement, on the date of your request.
• Your status : employee or self-employed.

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