EU-Norway, Iceland and Liechtenstein Social Security Cooperation: What Changes in 2026 for Companies with Seconded Workers

Key data

Spanish companies that send workers to Norway, Iceland or Liechtenstein—or that hire them from there—operate under a social security framework that has just been updated. The Council Decision (EU) 2026/1322, adopted on 4 June 2026 and published on 10 June, sets the official position of the EU to modify the Protocol 31 of the EEA Agreement, the instrument that regulates cooperation in areas not covered by the four fundamental freedoms of the internal market.

The modification specifically affects the budget line 07 20 03 01, corresponding to social security, and aims to align the EEA Agreement with the latest EU legislative advances in coordination of social protection systems. The practical result: greater clarity and legal certainty for companies managing international mobility to these three countries.

What does this regulation establish?

The Agreement on the European Economic Area (EEA) integrates Norway, Iceland and Liechtenstein into the European single market without them being EU members. Its Protocol 31 regulates cooperation in specific sectors that fall outside the four classic freedoms (free movement of goods, persons, services and capital).

The decision adopted by the Council establishes the position that the EU will defend in the EEA Joint Committee—the parity body that manages the Agreement—to introduce a modification to that Protocol 31. The specific change affects the field of coordination of social security systems, updating the cooperation framework to reflect the most recent European legislation in this area.

In practical terms, the modification facilitates the mobility of workers and citizens between the EU and non-member EEA countries, ensuring that social security rights acquired in one country are recognised and protected in the other. This includes aspects such as the accumulation of contribution periods, access to benefits and the avoidance of double contributions.

Economic and operational impact

For companies, this regulatory update has direct consequences for the management of their international mobility policies. The new framework strengthens legal certainty in three key dimensions:

• Avoidance of double contributions: Workers seconded between the EU and Norway, Iceland or Liechtenstein should not contribute simultaneously to two systems, which avoids labour cost overruns for the company.
• Recognition of accumulated rights: Contribution periods in one EEA country are counted towards accessing benefits (retirement, unemployment, disability) in the country of destination or origin.
• Update of the legal framework: By aligning with the latest EU legislative developments, the EEA Agreement eliminates possible gaps or contradictions that could generate uncertainty in the management of international payroll and contributions.

Companies that do not have properly documented the social security situation of their seconded workers in these countries may face retroactive claims for contributions or loss of rights by their employees. The update to Protocol 31 is, therefore, an opportunity to review and organise that management.

Who does it affect?

• Spanish companies with seconded workers to Norway, Iceland or Liechtenstein (technology, energy, construction, consulting, maritime transport sectors, among others).
• Companies from EEA countries with employees in Spain or in other EU member states.
• HR and Compensation and Benefits departments that manage expatriates or international assignments.
• Labour advisors and management firms that process social security documentation for companies with international mobility.
• CFOs and financial directors who must forecast the cost of contributions in cross-border contexts.
• Self-employed workers who operate between the EU and EEA countries and need to prove their social security registration status.

Practical example

A Spanish energy company seconded an engineer to Norway for 18 months to participate in an infrastructure project. Under the updated Protocol 31 framework of the EEA Agreement:

• The company must obtain the portable document A1 (or equivalent EEA) that certifies that the worker continues to contribute in Spain and is not obliged to contribute in Norway during the secondment.
• Thanks to the coordination of systems strengthened by this modification, the 18 months contributed in Spain during the secondment are fully counted towards access to benefits both in Spain and, where applicable, in Norway.
• If the secondment is extended and the worker begins to contribute in Norway, the periods accumulated in both countries will be added together to calculate access to retirement or other benefits, avoiding loss of rights.

Without this updated coordination framework, the company could face the obligation to contribute in both countries simultaneously or disputes over which system is competent, with the resulting cost overrun and legal risk.

What should companies do now?

1. Identify all seconded or expatriate workers in Norway, Iceland and Liechtenstein and verify that they have proper social security documentation (A1 certificate or equivalent EEA).
2. Review international secondment contracts to ensure they correctly reflect the country of contribution and the social security conditions applicable under the updated EEA Agreement.
3. Consult with the labour advisor or management firm if there are situations of workers who have been seconded for some time without updated documentation, to regularise their situation before claims arise.
4. Update internal HR procedures to incorporate the new developments of the EEA framework in international mobility management protocols.
5. Verify with Spanish Social Security (General Treasury) whether the bilateral agreements and EEA coordination instruments in force have been updated in their management systems, especially for new secondments from June 2026 onwards.

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601322