Key data
| Regulation | Decision of the EEE Joint Committee No. 292/2025, of 5 December 2025 — Amendment of Annex VI (Social Security) of the EEE Agreement [2026/638] |
|---|---|
| Publication | 16 April 2026 (Official Journal of the EU) |
| Entry into force | 5 December 2025 |
| Affected parties | Spanish companies with workers posted, cross-border or migrant in Norway, Iceland and Liechtenstein |
| Category | Social Security / International coordination |
| Non-EU EEE countries affected | Norway, Iceland, Liechtenstein |
| Modified areas | Applicable legislation, export of benefits, aggregation of contribution periods, posting agreements |
If your company has employees working in Norway, Iceland or Liechtenstein — whether temporarily or permanently — the rules that determine where they contribute and what social rights they accumulate have changed. The Decision 292/2025 of the EEE Joint Committee, in force since 5 December 2025, amends Annex VI of the Agreement on the European Economic Area, which is the legal framework that coordinates Social Security systems between EU countries and the three non-EU EEE countries.
This is not a minor change: it directly affects the management of international payroll, posting agreements and the rights of your posted or cross-border workers.
What does this regulation establish?
Annex VI of the EEE Agreement regulates how Social Security systems are coordinated when a worker moves between an EU country (such as Spain) and one of the three non-EU EEE countries: Norway, Iceland or Liechtenstein. Decision 292/2025 incorporates into the EEE Agreement the latest regulatory changes approved in the EU regarding the coordination of social benefits.
The four specific areas it modifies are:
| Area | What it regulates | Impact for the company |
|---|---|---|
| Applicable legislation | Determines in which country the worker must contribute when operating in several EEE territories | May change the country where the company pays social contributions |
| Export of benefits | Ensures that the worker can receive benefits (pension, unemployment, disability) in their country of residence even if they have contributed in another | Affects the planning of social benefits for the posted employee |
| Aggregation of contribution periods | Allows adding periods contributed in different EEE countries to calculate the right to benefits | Modifies the rights recognized to employees with contribution records in several countries |
| Posting agreements | Regulates agreements that allow maintaining coverage of the country of origin during temporary posting | Existing agreements must be reviewed to verify their validity under the new rules |
The objective of the update is to ensure that posted, cross-border and migrant workers maintain their Social Security rights when moving between these territories, without coverage gaps or double contributions.
Economic and operational impact
The impact is not only legal: it has direct consequences on the operations and costs of any company with international mobility to the three non-EU EEE countries.
- Contribution costs: If the determination of applicable legislation changes, the country where the company must pay social contributions may vary, with different rates and bases depending on each country's system.
- Management of international payroll: HR departments and payroll managers must update calculation criteria for employees affected by the new Annex VI.
- Posting agreements: Posting agreements in force with workers in Norway, Iceland or Liechtenstein must be reviewed to ensure they remain valid and that social coverage is correctly assigned.
- Benefit rights: The update of aggregation rules may modify the periods that count towards pensions, unemployment or disability for employees with mixed contribution records between Spain and EEE countries.
Who does it affect?
This regulation directly affects:
- Spanish companies with workers temporarily posted to Norway, Iceland or Liechtenstein (postings).
- Companies with cross-border workers who reside in one country and work in another within the EEE area.
- Companies with migrant employees who have permanently moved between Spain and one of the three non-EU EEE countries.
- HR departments and international payroll managers who manage contracts with social coverage in several countries.
- Labor advisors and accounting firms that process posting agreements or manage Social Security for workers in international mobility.
- CFOs and financial directors of companies with subsidiaries or projects in Norway, Iceland or Liechtenstein, where Social Security costs may be affected.
Practical example
A Spanish engineering company posts one of its technicians to Norway for 18 months to supervise an infrastructure project. Until now, the company had a posting agreement that allowed it to maintain contributions in Spain during that period.
With the entry into force of Decision 292/2025 on 5 December 2025, the company must verify that this posting agreement remains valid under the new rules of the updated Annex VI. If the conditions of the posting exceed the limits reviewed by the new regulation — in terms of duration, type of activity or coverage — it may be necessary to renegotiate the agreement or start contributing in Norway.
Furthermore, if the technician has previously contributed in Iceland for two years, the update of the aggregation of periods rules will determine how those years are counted to calculate their future pension or their right to unemployment benefits. An error in this calculation can generate coverage gaps or subsequent claims from the worker.
What should companies do now?
- Identify all affected workers: Draw up a list of employees posted, cross-border or migrant who operate between Spain and Norway, Iceland or Liechtenstein. This is the basis for any further action.
- Review existing posting agreements: Check that posting agreements in force remain valid under the new rules of Annex VI. If in doubt, consult with a specialist in international Social Security before an inspection occurs.
- Verify applicable legislation for each worker: Confirm in which country each employee must contribute according to the new rules for determining applicable legislation. An error here could mean double contributions or lack of coverage.
- Update international payroll management: Inform your HR department or accounting firm of the changes in Annex VI so they update the calculation criteria for contributions and benefits.
- Review aggregation of contribution periods: For employees with contribution records in several EEE countries, verify how their periods are counted under the new rules to avoid gaps in coverage or loss of rights.
- Document all changes: Keep records of the review process and any decisions made regarding the application of the new rules. This documentation will be essential in case of inspection by labor or social security authorities.
Frequently asked questions
Q: Does this affect only companies with workers in Norway, Iceland and Liechtenstein?
A: Yes, this regulation specifically affects the coordination between Spain and these three non-EU EEE countries. Companies with workers in other EU countries are not directly affected by this decision, although they may be affected by other EU coordination regulations.
Q: What happens if my company does not comply with the new rules?
A: Non-compliance can result in penalties for unpaid contributions, back payment of social security, loss of worker benefits, and potential labor inspections. It is advisable to ensure compliance as soon as possible.
Q: Can existing posting agreements continue to be valid?
A: Existing agreements must be reviewed to ensure they comply with the new rules. Some may remain valid, but others may need to be renegotiated or updated.
Q: When should companies take action?
A: Although the regulation entered into force on 5 December 2025, companies should review their situation immediately to ensure compliance and avoid penalties.
Official source
Decision of the EEE Joint Committee No. 292/2025, of 5 December 2025, amending Annex VI (Social Security) of the Agreement on the European Economic Area, published in the Official Journal of the European Union on 16 April 2026.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific guidance on your company's situation, consult with a specialist in international Social Security or labor law.