On 15 September 2026, the European Commission adopted the Fair Labour Mobility Package, introducing a series of proposals aimed at making it easier for people to work across EU borders while improving social security coordination, recognition of qualifications and enforcement of EU labour rules.
For employers managing international teams, the package is particularly relevant to cross-border hiring, employee mobility, social security administration and qualification verification.
However, an important distinction needs to be made: the legislative proposals are not yet enacted EU law. They will now proceed through the EU legislative process involving the European Parliament and the Council.
What Is the Fair Labour Mobility Package?
The Fair Labour Mobility Package is intended to address some of the practical and administrative barriers faced by workers and employers when employment crosses national borders within the EU.
According to the European Commission, the package is intended to support fair labour mobility, make cross-border recruitment easier, improve the portability and recognition of skills and qualifications, simplify social security administration and strengthen enforcement of EU labour rules.
The package consists of one Communication on fair labour mobility and five legislative proposals.
Together, they focus on three key areas: social security coordination, skills and qualification recognition, and cross-border labour enforcement.
1. European Social Security Pass (ESSPASS)
One of the key proposals concerns the further digitalisation of EU social security coordination and the establishment of a framework for the European Social Security Pass (ESSPASS).
The proposed system is intended to make it easier for individuals, employers and relevant authorities to issue, store, present and verify social security documents digitally across borders.
The first implementation area is expected to involve the Portable Document A1 (PD A1), which is commonly used to demonstrate which country’s social security legislation applies when an employee works temporarily in another EU country.
Further implementation is expected to cover other social security documents, including the European Health Insurance Card.
Why employers should watch this
For organisations managing employees who work across multiple EU countries, greater digitalisation could eventually simplify some of the administrative processes associated with proving social security coverage.
HR, payroll and mobility teams should therefore monitor how ESSPASS develops, particularly if they regularly manage posted workers, business travellers or employees working temporarily across EU borders.
2. Skills Portability Act
The proposed Skills Portability Act aims to make skills and qualifications easier to recognise and use across EU Member States.
Differences in qualification recognition can create obstacles when companies recruit across borders, particularly where employers need to understand whether a candidate’s qualifications meet requirements in another country.
The proposal seeks to improve the transparency, comparability and portability of skills and qualifications, supporting both workers moving between countries and employers recruiting internationally.
Why employers should watch this
If implemented, the measures could make it easier for HR and recruitment teams to assess qualifications obtained in another country and could reduce some of the administrative barriers involved in cross-border recruitment.
This may be particularly relevant to organisations recruiting for specialised or regulated roles.
3. Changes to the Professional Qualifications Framework
The Commission has also proposed amendments to the EU framework governing the recognition of professional qualifications.
The existing framework facilitates recognition for certain regulated professions across EU Member States. The proposed changes are intended to modernise and further digitalise recognition procedures and improve the functioning of the existing system.
Why employers should watch this
Companies recruiting professionals for regulated occupations should continue checking the specific qualification and licensing requirements that apply in the country where the employee will work.
Even with greater EU-level coordination, requirements can differ depending on the profession and Member State.
4. Recognition of Qualifications Held by Third-Country Nationals
Another proposal focuses on the recognition of qualifications held by third-country nationals, meaning nationals of countries outside the EU.
The proposal aims to introduce more consistent approaches to recognising qualifications obtained outside the EU. Its scope includes third-country nationals already residing within the EU as well as certain individuals seeking to migrate to the EU for employment.
This is particularly relevant as European employers increasingly look beyond the EU when recruiting for roles affected by skills shortages.
Why employers should watch this
More consistent qualification recognition could eventually help employers assess international candidates more efficiently.
However, qualification recognition and immigration remain separate considerations. Employers hiring third-country nationals will still need to consider the relevant immigration, work authorisation and employment requirements in the destination country.
5. Strengthening the European Labour Authority
The package also includes a proposal to strengthen the role of the European Labour Authority (ELA).
The ELA supports cooperation between national authorities in relation to cross-border labour mobility and the enforcement of EU labour rules.
The proposed changes are intended to strengthen cooperation and enforcement capabilities, including efforts to address fraud, abuse and non-compliance in cross-border employment situations.
Why employers should watch this
For businesses employing people across multiple EU jurisdictions, stronger cooperation between labour authorities reinforces the importance of maintaining accurate employment, payroll and social security documentation.
Companies should ensure that cross-border employment arrangements comply with the applicable requirements in each country involved.
What Does “Adopted” Mean?
The word “adopted” can sometimes create confusion.
In this case, adoption by the European Commission does not mean that all of the proposed measures became law on 15 September 2026.
The Commission has adopted its proposals and submitted the legislative measures for consideration under the EU legislative process. The European Parliament and the Council will now consider the proposals and may amend them before final texts are agreed.
The five legislative proposals may also progress at different speeds.
For the proposed Directives, Member States would generally need time to transpose the final requirements into national legislation after adoption. Regulations generally apply directly once they become applicable under their final terms.
Therefore, there are no immediate new employer obligations arising solely from the Commission’s adoption of the package on 15 September 2026.
What Should Employers Do Now?
Businesses do not need to overhaul their HR or payroll processes immediately because of the package.
However, employers operating across Europe should start monitoring its development.
HR, payroll, legal and global mobility teams may want to:
- Monitor the legislative progress of each proposal separately.
- Review current social security processes, particularly the handling of PD A1 documentation for employees working across borders.
- Assess qualification verification procedures for international recruitment and regulated professions.
- Review cross-border employment documentation to ensure records relating to employment, payroll and social security remain accurate and accessible.
- Monitor developments affecting third-country nationals, particularly where international recruitment forms part of the organisation’s workforce strategy.
- Follow official EU sources as the proposals progress through the legislative process.
What This Means for Global Employers
The Fair Labour Mobility Package reflects the EU’s broader effort to make cross-border employment easier to administer while strengthening compliance and enforcement.
For employers, the most immediate action is awareness rather than implementation.
The details may change as the proposals move through the legislative process. Businesses operating across multiple European countries should therefore avoid treating the proposals as current legal requirements while preparing for potential changes to social security administration, qualification recognition and cross-border labour enforcement.
For organisations expanding internationally, these developments also highlight a broader challenge: hiring across borders involves more than finding the right talent. Employers must consider employment law, payroll, tax and social security obligations, immigration requirements and local compliance in each market.
Link Compliance supports businesses with Employer of Record (EOR), Recruitment Solutions and HR Outsourcing, helping companies manage international hiring and workforce requirements across multiple markets.
Whether you are hiring your first employee overseas or managing an established international workforce, staying informed about changing employment requirements is an important part of building a compliant global workforce.
More information: info@linkcompliance.com
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Sources:
- European Commission — Commission proposes ambitious measures to strengthen fair labour mobility, 15 September 2026
- European Commission — Fair Labour Mobility Package
- European Commission — EU Social Security Coordination
- European Commission — Working in another EU country
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Disclaimer: This article is intended for general informational purposes and reflects the status of the European Commission’s Fair Labour Mobility Package as of October 2026. The proposals remain subject to the EU legislative process and may change before final adoption.
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