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EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 980 final

2026/0271 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC) No

883/2004, (EC) No 987/2009 and (EU) No 2018/1724

{SEC(2026) 980 final} - {SWD(2026) 981 final} - {SWD(2026) 982 final} -

{SWD(2026) 983 final}

(Text with EEA relevance)

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EXPLANATORY MEMORANDUM

1. CONTEXT OF THE PROPOSAL

• Reasons for and objectives of the proposal

The free movement of persons is one of the four fundamental freedoms at the heart of the

EU single market and a major achievement of European integration. By facilitating

labour mobility, it helps address labour and skills shortages and supports economic growth

and competitiveness across Member States. Beyond its benefits for Europe’s economy, the

free movement of persons expands professional and personal opportunities for individuals,

encourages cultural exchange and a shared sense of community, thereby advancing the

integration of the European Union.

The effective exercise of this freedom requires clear rules, robust enforcement mechanisms

and coordinated policies among Member States to support mobility while guaranteeing

fairness, legal certainty and the protection of rights. A key pillar in this regard is the EU

social security coordination framework1. This ensures that individuals continue to receive

their benefits – such as pension, unemployment and family benefits – and are covered by

healthcare when moving to, staying in or travelling in other Member States. A revision to

modernise this framework has recently been provisionally agreed by the European Parliament

and the Council2. Once adopted, the revised framework will facilitate the exercise of citizens’

rights, achieve greater legal clarity and ease of enforcement, and make it easier for businesses

and workers to engage in short-term cross-border activities and business trips.

At the same time, there is still strong potential to make the EU social security coordination

rules easier to apply. This can be achieved through increased and better use of digital

technologies in this area, as part of the EU broader efforts to: (i) simplify procedures; (ii)

reduce burdens on individuals, businesses and national, regional and local authorities; and (iii)

support competitiveness in the EU single market.

Digital transformation is a central part of the EU’s strategic priorities, serving as a key

driver of innovation and competitiveness. In line with the Digital Decade policy

programme 2030 and the European Declaration on Digital Rights and Principles, the Union is

promoting the development of seamless and human-centric digital public services across

Europe.

Recent reports by Enrico Letta and Mario Draghi on the future of the single market and

Europe’s competitiveness emphasise the urgency of accelerating this digital transformation

and removing barriers that undermine the single market’s dynamism. Similarly, the 2026

single market and competitiveness report identifies persistent gaps in cross-border digital

1 Regulation (EC) No 883/2004 on the coordination of social security systems and Regulation (EC)

No 987/2009 laying down the procedure for implementing Regulation (EC) No 883/2004. These

Regulations also apply to Norway, Iceland, Liechtenstein and Switzerland. Specific rules are in place in

the agreements with the United Kingdom. 2 The European Parliament approved the provisional agreement on 7 July 2026, whereas formal adoption

by the Council is still pending.

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services and mobility challenges as significant obstacles – especially for small and medium-

sized enterprises (SMEs)3 – hindering Europe’s economic expansion and the seamless

functioning of the digital single market. Furthermore, the 2025 EU Startup and Scaleup

Strategy highlights the negative impact of regulatory fragmentation on the ability of startups

and scaleups to operate efficiently within the single market and to attract talent.

While the Commission and Member States have already taken steps under the current

framework to digitalise cross-border procedures, services and data exchanges in the area of

social security coordination, further action at EU level is required. This aligns with repeated

calls from the European Parliament, including in its 2021 Resolution on a European Social

Security Pass, echoed in the Commission’s Communication on digitalisation in social security

coordination, in the Council Conclusions of November 2023 and in the above-mentioned

Letta report. It also responds to requests from European social partners4 and civil society

organisations to strengthen the protection of workers’ social security rights, enhance

enforcement and facilitate labour mobility, while reducing administrative burdens.

The Electronic Exchange of Social Security Information (EESSI) system5 has

significantly improved the handling of cases under the EU social security coordination rules.

Covering areas such as sickness, accidents at work, pensions, unemployment and family

benefits, EESSI enables over 3.100 social security institutions across the 32 participating

countries (the 27 Member States as well as Iceland, Liechtenstein, Norway, Switzerland and

the United Kingdom) to exchange information electronically and securely, replacing paper-

based communication. Since its implementation, more than 42 million cases have been

handled, delivering tangible benefits for millions of individuals who now experience a more

efficient processing of their social security claims.

Despite this progress, some obstacles to fully realising the benefits of the system remain.

These include delays in the treatment of cross-border pension cases, which risk leaving

individuals without timely access to their entitlements, thus undermining people’s trust in the

EU’s social security coordination framework. The experience of implementing EESSI has

also revealed the technical, procedural and coordination challenges involved in the

digitalisation of cross-border social security procedures. Given the involvement of thousands

of institutions and the coverage of all branches of social security, more agile cooperation and

streamlined decision-making are necessary.

While improving the exchange of information among social security institutions through

EESSI is of paramount importance, it is only the first step. Further digitalisation is required

to:

3 See the 2024 SMET report: https://ec.europa.eu/internal_market/smet/_docs/2024/smet-report-

2024_en.pdf, p. 12. 4 BusinessEurope position paper: Stepping up EU simplification efforts in the field of social affairs,

ETUC contribution to the public consultation. 5 The EESSI project was launched in 2008, with the system entering into operations in 2019. For more

information see: Electronic Exchange of Social Security Information (EESSI) - Employment, Social

Affairs and Inclusion.

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• reinforce the protection of individuals and workers by facilitating more effective

access to social security rights across Europe;

• reduce administrative hurdles and costs for individuals accessing social security

benefits in other Member States and for businesses operating across borders;

• increase the quality of cross-border public services;

• provide Member States with more effective tools to fight against fraud, thus

strengthening the protection of rights and fair mobility.

Challenges continue to exist in the exchanges of information between individuals, businesses

and national authorities in cross-border social security scenarios. Individuals often struggle to

prove their social security rights promptly when moving, travelling or working across borders.

At the same time, social security institutions, labour inspectorates and healthcare providers

lack efficient, secure ways to confirm this information across Member States. Meanwhile,

businesses – particularly small and medium-sized enterprises (SMEs) – encounter persistent

difficulties in seamlessly complying with requirements when sending workers to work

temporarily abroad6.

The problem arises from:

• existing procedures for requesting, issuing and verifying social security documents,

including the European Health Insurance Card (EHIC), which are still largely paper-

based;

• limited cross-border interoperability and standardisation in documents’ format and

verification methods;

• processes that do not sufficiently accommodate the needs of individuals and

businesses.

This leads to inefficiencies, unnecessary procedural complexity, increased costs, time losses,

errors and fraud. This potentially makes it harder to easily access social security benefits in

other Member States, thus creating concrete barriers to intra-EU mobility7, freedom of

establishment and cross- border service provision.

To that end, the European Social Security Pass (ESSPASS) pilot project was launched as

part of the European Pillar of Social Rights action plan. The project’s aim was to explore a

digital solution for the issuing and cross-border verification of social security documents.

Between 2021 and 2025, digital solutions were tested for procedures related to the portable

6 The administrative hurdles linked to procedures for the posting of workers are considered one of the

most significant obstacles preventing businesses from expanding across Member States, according to

the 2025 Single Market Strategy. See also the SMET report, page 12. 7 The Draghi report emphasises that fears of losing access to social protection or facing difficulties

accessing social security in other Member States discourage individuals from relocating – even though

EU legislation ensures the portability of social security rights.

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document A18 and the EHIC, with the participation of a significant number of Member

States9.

The pilot’s success clearly demonstrated that the ESSPASS can:

• empower individuals to prove and exercise their rights more easily and securely

across borders;

• reduce administrative burdens for businesses;

• enhance fraud prevention through real-time verification of standardised digital

documents;

• improve efficiency for national authorities by reducing paper-based processes.

In light of these proven benefits, the Commission has announced a legislative framework

governing the ESSPASS in the Single Market Strategy and its 2026 Work Programme, as a

key component of the Fair Labour Mobility Package. The proposed regulation sets out

rules for swift deployment of the ESSPASS across all Member States. It establishes a

dedicated legal instrument covering the cross-border digital data exchanges and

procedures necessary to ensure effective implementation and enforcement of EU social

security coordination rules, including those facilitated through the EESSI system.

A standalone regulation addressing all digital aspects of social security coordination is

necessary to ensure legal clarity, consistency, enforceability and flexibility. These objectives

cannot be fully achieved through fragmented provisions within the existing social security

coordination framework. A dedicated legal instrument would establish the necessary legal

requirements, technical specifications and standards, interoperability requirements,

governance arrangements, and robust security and data protection safeguards. It would also

ensure that the corresponding binding implementation measures are applied uniformly and

effectively across all Member States. Furthermore, such an approach would provide greater

flexibility to accommodate future technological developments. By separating the digital

aspects from the core EU social security coordination framework, the proposed regulation

would enable timely updates to technical requirements, without necessitating amendments to

that framework. It would focus exclusively on the digitalisation of social security

coordination, thereby complementing the existing legal framework.

The proposed regulation will support a smooth transition from the ESSPASS pilot phase to

full-scale implementation. It will apply to the portable document A1 one year after entry into

force, and to the European Health Insurance Card after three years. After three years, it will

8 The Portable Document A1 certifies which Member State's social security legislation applies to a

person in a cross-border work situation. 9 The DC4EU project tested the use of the European Digital Identity framework. It involved 80

institutions from 22 countries, with 15 countries (AT, DE, DK, PL, BE, NL, FR, LU, BG, CZ, ES, PT,

IT, FI, CH) participating in the social security coordination work packages.

The EBSI-Vector project explored a solution relying on blockchain technologies, engaging 52 partners

from 20 countries, with five countries (AT, BE, DE, IT, NL) involved in the social security

coordination use cases. These projects were financially supported by the Digital Europe programme.

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also cover all other social security documents, except those for which an assessment shows

that digitalisation under ESSPASS would not bring added value.

By building on the European Digital Identity (EUDI) and the Single Digital Gateway

frameworks, the proposed Regulation will give individuals secure, direct access to their social

security documents via their EUDI wallets, while national authorities will benefit from instant

verification capabilities and better ways to detect fraud. The introduction of binding time

limits for issuing documents will further improve predictability for individuals and

businesses, including the self-employed, by reducing unnecessary delays. This will help

ensure the effective and timely exercise of rights under the EU social security coordination

framework. In addition, it will facilitate cross-border operations for businesses by enabling

them to plan with confidence and avoid administrative bottlenecks linked to variable

processing times. Greater transparency and direct access to proof of entitlements will make it

easier for workers and self-employed to demonstrate their coverage when working across

borders, reduce administrative hurdles linked to paper-based procedures, and help prevent

fraud and abuse that can undermine their rights. For businesses, particularly SMEs,

compliance with posting requirements will be simplified by achieving convergence in

information requirements for portable document A1 requests and reducing redundant data

submission, in line with the ‘once-only’ principle. This will lower administrative costs,

improve legal certainty when sending workers abroad, and help ensure faster, more reliable

access to the required documents. Governance will also be strengthened and simplified by

replacing the current arrangements with a more agile and structured approach. A dedicated

group on digitalisation in social security coordination composed of Member States’

representatives will be created to help develop technical specifications, monitor progress and

share experiences. This group will continue the work previously carried out by the Technical

Commission for data processing, established pursuant to Article 73 of Regulation (EC)

No 883/2004 of the European Parliament and of the Council10, and the ad hoc group of the

Administrative Commission for the coordination of social security systems on ESSPASS.

Moreover, a committee composed of Member States’ representatives will support the

Commission in the adoption of implementing acts in accordance with the examination

procedure set out in Article 5 of Regulation (EU) No 182/2011 of the European Parliament

and of the Council11 (‘comitology Committee’). This will ensure the rules remain adaptable

and future-proof, while preserving their binding nature.

The proposed regulation concerns persons covered by the EU rules on social security

coordination as defined in Article 2 of Regulation (EC) 883/2004 which includes workers,

self-employed persons, pensioners, unemployed and economically inactive insured persons,

10 Regulation (EC) No 883/2004 of the European Parliament and of the Council of 29 April 2004 on the

coordination of social security systems (OJ L 166, 30.4.2004, p. 1,

ELI: http://data.europa.eu/eli/reg/2004/883/oj) 11 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission’s exercise of implementing powers (OJ L 55, 28.2.2011, p. 13,

ELI: http://data.europa.eu/eli/reg/2011/182/oj )

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and their family members.These rules also apply, under Regulation (EU) No 1231/201012, to

third-country nationals who are legally residing in a Member State and are in a cross-border

situation. Regulation (EU) No 1231/2010 will therefore need to be amended to ensure that the

measures introduced by this proposal also apply to these third-country nationals.

In terms of territorial coverage, the proposed regulation will encompass all the Member States

and will also be relevant for the EEA countries, Switzerland and the UK, subject to the

applicable legal arrangements.

• Consistency with existing provisions in the policy area

The proposed regulation supports the objectives of the European Pillar of Social Rights and is

consistent with existing Union related legislation, particularly the EU social security

coordination rules. It complements these rules by establishing a dedicated legal instrument

governing all cross-border digital procedures and data exchanges necessary to facilitate their

effective implementation and enforcement. The proposal does not modify existing rights and

obligations established under the social security coordination framework and does not

compromise the level of individual protection it entails. The recent revision of this framework

modernised and simplified it. The proposal is consistent with that approach as it further

modernises and simplifies the application of this framework through digitalisation. By

promoting the use of digital technologies across the Member States, the proposal strengthens

the existing protection, by simplifying access to social security rights and services across

borders.

The proposal is consistent with the Single Digital Gateway Regulation (SDGR)13. The SDGR

requires Member States to ensure that individuals and businesses can access and complete

administrative procedures fully online, including: (i) requests to determine which social

security legislation covers the holder – resulting in the issuing of the portable document A1;

(ii) EHIC applications; and (iii) pension claims. To ensure that individuals can fully exercise

their rights to free movement without administrative obstacles, the proposal expands the

SDGR in order to extend the possibility to submit fully online requests to cover additional

social security documents.

The proposal forms part of the Fair Labour Mobility Package. The package includes measures

aimed at modernising and simplifying the application and enforcement of labour mobility and

social security coordination rules. This is to ensure that mobility within the EU is fair and

protects workers against exploitation or disadvantages linked to mobility, while fostering a

competitive and dynamic business environment that thrives on skills and innovation.

12 Regulation (EU) No 1231/2010 of the European Parliament and of the Council of 24 November 2010

extending Regulation (EC) No 883/2004 and Regulation (EC) No 987/2009 to nationals of third

countries who are not already covered by these Regulations solely on the ground of their nationality (OJ

L 344, 29.12.2010, p. 1, ELI: https://eur-lex.europa.eu/eli/reg/2010/1231/oj). 13 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012 (OJ L 295, 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj)

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• Consistency with other Union policies

The proposal supports the European goals of simplifying administrative procedures for

individuals, businesses and national, regional and local authorities: less red tape, more trust,

better enforcement. This helps relaunch EU competitiveness, in line with the Draghi report

and the EU competitiveness compass. It also complements the 28th regime to help companies

(start-ups and scale-ups in particular) overcome barriers to operating across Europe,

supporting growth, innovation and global competition.

The proposal builds on ongoing efforts at EU level to foster inclusive digital participation for

all people across Europe14 and to accelerate the digitalisation of cross-border public services.

This aligns with the Digital Decade programme’s targets of 100 % online provision of key

services and of individuals having access to secure electronic identification solutions by 2030.

The proposal also builds on existing cross-sectoral initiatives such as the SDGR and the

Once-Only Technical System, the European Digital Identity framework and potentially the

future European Business Wallets, the Internal Market Information System and the

Interoperable Europe Act.

The proposal complements other legislation, systems and tools supporting labour mobility,

cross-border provision of services, social protection, cross-border healthcare and enforcement

of labour law intended to further facilitate the mobility of individuals and workers in the EU,

simplify administrative procedures for people, businesses and national authorities, and uphold

workers’ rights. Such systems and tools include:

• the European tracking service on pensions;

• the proposal for an e-Declaration on the posting of workers which has been

provisionally agreed by the European Parliament and the Council and the Road

Transport Posting Declaration Portal15;

• the European Health Data Space, including MyHealth@EU infrastructure, set out in

Regulation (EU) 2025/327 of the European Parliament and of the Council16;

• initiatives to explore the potential for interoperability between different Member

States’ labour and social identity cards.

2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY

• Legal basis

The proposal is based on Article 48 of the Treaty on the Functioning of the European Union

(TFEU). That article gives the EU the power to adopt measures to coordinate Member States’

14 European declaration on digital rights and principles. 15 References are made to the road transport sector as this is the only transport mode for which a dedicated

EU posting declaration portal has been established. No equivalent system exists for the other transport

modes. 16 Regulation (EU) 2025/327 of the European Parliament and of the Council of 11 February 2025 on the

European Health Data Space and amending Directive 2011/24/EU and Regulation (EU) 2024/2847 (OJ

L, 2025/327, 5.3.2025, ELI: http://data.europa.eu/eli/reg/2025/327/oj)

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social security systems in order to facilitate the free movement of workers and the protection

of their social security rights across the Union. While Article 48 TFEU applies to employed

and self-employed mobile workers and ‘their dependants’, Regulation (EC) No 883/2004,

based on what are now Articles 48 and 352 TFEU, extends social security coordination to

persons moving within the Union who do not pursue an economic activity. Article 48 TFEU

provides a solid legal basis for adopting measures complementary to the existing social

security coordination framework in order to digitalise cross-border social security procedures

and facilitate access to social security benefits and fair mobility within the EU.

• Subsidiarity (for non-exclusive competence)

The free movement of persons and freedom to provide services are fundamental freedoms of

the European Union. To fully benefit from these freedoms, individuals and businesses must

rely on efficient public services, including when accessing social security benefits or sending

workers to work abroad. Barriers to the seamless proof and cross-border verification of social

security rights and insurance status cannot be dealt with effectively by Member States on their

own. Digital solutions implemented by a single Member State will not ensure cross-border

interoperability and the recognition and verification of social security documents.

EU-level action will improve the proof and verification of social security rights and insurance

status. This in turn will improve access to benefits and healthcare, thus establishing a more

supporting environment for workers who are relocating or considering relocation within the

EU and in cross-border situations. Given the cross-border nature of the existing problems,

effective solutions are best pursued at EU level, rather than through individual efforts by

Member States. EU-level action will benefit mobile individuals by making their social

security rights more transparent and accessible, while reducing fraudulent and exploitative

practices. By reducing unnecessary administrative difficulties and complexities, EU action

will assist businesses operating across borders, while supporting national, regional and local

authorities by simplifying processes and strengthening cross-border cooperation. This will

improve understanding and implementation of the rules and make them easier to enforce,

while fostering trust in the EU’s social security coordination framework and Europe’s single

market.

EU action will also maximise the impact of prior EU investments, complementing key digital

EU initiatives such as the SDGR and the Once Only Technical System (OOTS), the EUDI

framework, the European Businesses Wallets, the Interoperable Europe Act and the European

Health Data Space. In this way, it will form part of a coherent and cohesive EU digital

landscape that serves the interests of the EU and its Member States. If the EU does not act

now, action by Member States would likely lead to fragmented, uncoordinated and

incompatible solutions that fail to integrate with existing EU initiatives. This could result in

suboptimal outcomes and be more costly to reverse at a later stage.

• Proportionality

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The proposal respects the principle of proportionality as it does not go beyond what is

necessary and appropriate for EU action. It establishes the ESSPASS framework for the

request, issuance and cross-border verification of social security documents created under the

EU social security coordination rules. This ensures interoperability, digital exchange and

mutual recognition of such documents, without interfering with national social security

systems. By relying on the existing EU framework (particularly the EUDI framework) instead

of building a completely new solution, the ESSPASS further adheres with the proportionality

principle, employing a cost-effective strategy which minimise costs and optimise resources

efficiently.

The proposal does not introduce any new declaration, reporting or documentation

requirements for employers or self-employed persons, nor does it alter the criteria for

determining the social security legislation applicable to a person in a cross-border situation.

• Choice of the instrument

Given the cross-border nature of the problem and the need to prevent regulatory

fragmentation, a regulation is considered the most suitable, effective and proportionate legal

instrument to achieve the defined policy objectives. As a directly applicable act, it ensures

uniform application across Member States, preventing fragmentation and providing legal

certainty and effectiveness. This also aligns with the identified legal basis and the existing

social security coordinaton framework, which it complements.

3. RESULTS OF EX POST EVALUATIONS, STAKEHOLDER

CONSULTATIONS AND IMPACT ASSESSMENTS

• Ex post evaluations/fitness checks of existing legislation

N/A

• Stakeholder consultations

From the outset, the Commission placed stakeholder engagement at the forefront of its

strategic planning, acknowledging its critical role in shaping effective policies. The

Commission launched the ESSPASS as a pilot project to actively involve Member States from

the early stages of development and to foster ownership. This ensured that the initiative is

both feasible and responsive to the needs and realities of those it aims to serve. The pilot

activities not only demonstrated the ESSPASS’s viability and benefits but also provided

valuable feedback, technical expertise and insight. These directly informed decisions on the

initiative’s subsequent development.

In line with the Better Regulation principles, the Commission conducted extensive

consultations to ensure that the perspectives and interests of all relevant stakeholders were

considered and integrated into the policymaking process. The consultation process gathered

feedback on the scale and nature of the problems to be addressed, the objectives of the

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proposed initiative, the policy options under consideration, and their potential impacts –

including costs and opportunities for simplification. This comprehensive evidence gathering

included the following activities, some of them as part of a supporting study on digitalisation

in social security coordination:

– two surveys (March-April 2025) targeting social security institutions, healthcare

providers and enforcement authorities, with 87 responses from 32 countries;

– 97 stakeholder interviews (2025) with national authorities, social partners and

technical experts to assess costs, benefits and feasibility;

– two workshops (June 2025) with 62 and 44 participants respectively,

to validate problem definitions and policy options;

– meetings with experts involved in the ESSPASS pilot projects (2025-2026);

– seminars and exchanges as part of social security coordination, including dedicated

meetings on ESSPASS and impact estimates;

– an implementation dialogue on fair labour mobility (16 September 2025);

– a high-level meeting on digitalisation in social security coordination with Member

State representatives (30 September 2025);

– a hearing of EU social partners (6 November 2025), gathering the views of workers’

and employers’ organisations;

– a call for evidence on ESSPASS (14 January 2026-11 February 2026) and one on the

Fair Labour Mobility Package;

– a public consultation (22 January-16 April 2026).

These consultations revealed broad support for further digitalisation in social security

coordination and for the ESSPASS initiative as a means to simplify cross-border social

security procedures, facilitate access to social security benefits across borders, reduce fraud

and reduce administrative burdens for individuals, businesses and national authorities.

Stakeholders – including trade unions, employers and public authorities – emphasised the

need for strong enforcement mechanisms, simplified processes and real-time verification

mechanisms to increase effectiveness. There was broad consensus on the reuse of EUDI

Wallets as the primary digital solution. There was also broad consensus on ensuring a fallback

option – such as secure, verifiable and revocable physical documents – for those unable or

unwilling to use digital tools. Some concerns were raised about implementation costs and data

security.

The public consultation and the calls for evidence reinforced these findings, with 93% of

respondents to the public consultation supporting a standardised solution for the digitalisation

of social security documents, the portable documents and the EHIC. Delays in document

issuance, cross-border verification challenges and fraud risks were cited as major pain points,

while real-time verification and interoperability emerged as top priorities. Overall, the

consultation underscored the ESSPASS’s potential to boost fair labour mobility, combat fraud

and modernise social security coordination, provided it is designed inclusively, governed

robustly and integrated seamlessly with existing systems.

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• Collection and use of expertise

N/A

• Impact assessments

The proposal for a regulation is accompanied by an impact assessment report17, a draft of

which was submitted to the Regulatory Scrutiny Board (RSB) on 29 April 2026. The RSB

issued a positive opinion with reservations on 4 May 2026, and the impact assessment report

was revised in accordance with the Board’s recommendations. The RSB’s more detailed

technical comments were also addressed.

The impact assessment examined a range of policy options. The selected options draw on the

findings from the pilot activities, stakeholder insights and additional factors such as: (a)

consistency with EU objectives, particularly the EU’s simplification and digitalisation agenda;

(b) reliance on existing EU initiatives such as the SDGR and the EUDI framework to

minimise expenses and optimise resource use; and (c) the EU’s shift towards user-centricity

and privacy-by-design as well the need to address the digital divide.

Three policy options were assessed:

– Policy Option 1 establishing a solution enhancing the existing format of portable

documents and the EHIC and enabling their verification across borders. This

involves issuing the documents in a standardised format, with digital security

features, which can be either printed or stored electronically.

– Policy Option 2 introducing a solution for the issuing and instant verification of

portable documents and the EHIC, relying on the EUDI framework. Individuals and

businesses would be able to securely store these documents within their EUDI

Wallets. If they cannot or prefer not to use the EUDI Wallets, non-enhanced physical

documents would remain available.

– Policy Option 3 establishing a solution encompassing the main elements set out in

Policy Option 2. However, individuals and businesses who cannot or prefer not to

use EUDI Wallets would receive enhanced physical documents which can be verified

even when printed (as in Policy Option 1).

The following measures were common to all policy options to ensure their smooth

implementation and strengthen their impact on EU competitiveness and simplification:

– Enabling individuals across all Member States to request and receive portable

documents electronically, even those not covered by the SDGR.

– Introducing binding deadlines for national authorities to issue social security

documents, thus ensuring their timely availability for cross-border use without

compromising accuracy.

– Convergence between national information requirements for requesting the portable

document A1 as well as the possibility of using the multilingual public interface for

the declaration of posted workers (e-declaration) once established, to the extent there

17 SWD (2026) …

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would be overlap of information requirements with the e-declaration. This would

enable applicants to submit data only once (following the once-only principle), as

requested by stakeholders and several Member States during the negotiations on the

e-declaration. This would be in line with the overall EU objective to reduce

administrative hurdles for businesses operating across borders. Convergence in

information requirements would also ensure better alignment on checks conducted

before issuing the A1 form.

Following an analysis of the policy alternatives, Policy Option 3 was identified as the

preferred choice. That option was deemed the most effective at achieving the objectives, the

most efficient in terms of costs and benefits, and the option ensuring the highest level of

consistency with other EU policies.

The assessment indicates that the preferred option is likely to significantly reduce reliance on

paper-based processes by introducing standardised, simplified digital procedures for

requesting, issuing and verifying social security documents between Member States. This

ensures seamless recognition of documents throughout the EU while offering flexibility for

individuals on how data are stored and presented. Implementing this policy option is expected

to deliver significant benefits for individuals, national authorities, labour inspectorates,

healthcare providers and businesses. Among the advantages, document verification times will

be reduced to just a few seconds for documents stored in the EUDI Wallets and to around one

minute for non-Wallet documents. This is in contrast to the current 5 to 16 minutes for the

portable document A1 and 2 to 5 minutes for EHIC. Over a 12-year period, this efficiency is

expected to generate cost savings of between EUR 24 million to 72 million for verifiers (e.g.

labour inspectorates) and EUR 21 million to 64 million for businesses (this is particularly

relevant for SMEs, which constitute 99% of EU businesses) in relation to the portable

document A1. For EHIC verifications, healthcare providers’ savings are estimated at between

EUR 23 million and EUR 69 million.

Enhanced security is another key advantage. Digitally signed documents with instant

verification will make forgery almost impossible, unlike the current situation. Over a 12-year

period, this could lead to cost savings from reduced fraud of up to EUR 157 million for the

portable document A1 and EUR 120 million for the EHIC. Additionally, reduced use of

plastic – estimated at up to 1 482 tonnes – could yield up to EUR 161 million in savings.

The preferred option supports the application of the rules on the coordination of social

security systems, easing access to benefits and healthcare. It also fosters trust, fairness and

data protection by giving users control of their data and ensuring GDPR-compliant handling

of personal data. Social benefits include increased transparency and fairness: workers will

have direct access to portable documents A1 and will gain a clearer understanding of their

social security position and rights when posted abroad. With full knowledge of their social

security arrangements, workers will become less susceptible to fraudulent practices and will

gain easier access to benefits they might be entitled to in the host country.

The preferred option also supports competitiveness by simplifying procedures for companies

operating across borders and supports advancements in digitalisation and innovation.

EN 13 EN

The use of EUDI Wallets for storing and sharing high-circulation documents like the EHIC

will accelerate wallet adoption. This will create a foundation for the future integration of

additional labour mobility documents through sector-specific legislation.

The preferred option includes upfront investments and annual maintenance costs. These

would be primarily borne by national public administrations, including ministries, social

security institutions and labour inspectors, as well as by healthcare providers. Individuals and

businesses are expected to face minimal expenses. Such expenses would mainly be related to

smartphone use if they want to store their social security coordination documents in the

national EUDI Wallets. Overall, total one-off EU costs (over a period of three years) are

estimated to be between EUR 186 million and EUR 218 million, with cumulative recurrent

costs amounting to EUR 278 million over the following 12 years (EUR 23.2 million

annually). The costs reflect the necessary infrastructure and integration efforts and are

balanced by projected long-term efficiencies and cost savings.

To support this investment, deployment should be eligible for EU funding, notably under the

successor instrument of the European Social Fund + (digitalisation of public services and

institutions) and the European Competitiveness Fund for the post-2027 programming period.

• Regulatory fitness and simplification

The initiative is expected to have a positive impact on competitiveness. Businesses are likely

to experience decreased costs thanks to reduced administrative hurdles and the shorter times

required to obtain and verify the portable document A1 and provide additional information in

cases of doubts about its validity. SMEs, which constitute 99% of EU businesses and typically

face greater challenges in meeting regulatory requirements due to their limited administrative

resources, are expected to benefit more than larger companies. This is especially the case in

sectors like construction and services, where posting and activities in two or more Member

States are more common. Easier compliance with requirements can lead to greater efficiency

in allocation of resources towards value-creating activities. This in turn can boost

productivity. Improved access to cross-border labour markets will enable businesses to take

advantage of a broader talent pool and optimise operations, making them more competitive in

both local and international markets. The initiative will also promote technological

advancement by encouraging digitalisation in public services and seamless access to services

for individuals and businesses. By adopting innovative solutions for the proof and cross-

border verification of social security rights and insurance status, the initiative strengthens

capacity for further innovations within the public sector. This should further contribute to EU

economic expansion and business competitiveness.

The proposal is consistent with the ‘Digital check’. It fully aligns with core e-government

principles:

• digital by default, promoting digital procedures as preferred choice, while still

offering alternative options;

• once-only principle, reducing redundant data submission;

EN 14 EN

• interoperability by design, facilitating cross-border recognition and verification of

documents as well as cross-border data exchange, and reducing fragmentation;

• user-centricity, putting people at the centre and ensuring predictable processing

times;

• inclusiveness and accessibility, guaranteeing equal access to all, notably to persons

with disabilities, older people and individuals with limited digital skills by offering

the option to request enhanced physical documents;

• trustworthiness and security, promoting the protection of personal data and high

security standards;

• cross-border by default, establishing services available across borders and reducing

unnecessary barriers to mobility.

• Fundamental rights

The proposed regulation is expected to make it easier to coordinate social security systems by

easing access to social security benefits and healthcare across Europe (Articles 34 and 35 of

the Charter of Fundamental Rights of the European Union Charter). This is achieved through

improved proof and verification of social security rights and the insurance status of

individuals moving across the EU. No reduction in the baseline level of protection has been

identified.

By ensuring social security rights and documents are more easily transferable and verifiable

through simplified procedures and reduced administrative processing times, the initiative is

expected to have a positive impact on:

• the free movement of persons and workers, as provided for in Article 45 of the TFEU

and in Articles 15 and 45 of the Charter of Fundamental Rights;

• the freedom to provide services, as enshrined in Article 56 TFEU and Article 16 of

the Charter.

As a result, workers would be more likely to take advantage of cross-border job opportunities

and businesses would be more eager to operate across borders. The proposed regulation does

not place any limitations on these freedoms.

The proposal is also likely to have a positive impact on the right to good administration, as

provided for in Article 41 of the Charter of Fundamental Rights. By simplifying procedures

and reducing processing times, it is anticipated that requests and operations will be handled

within a reasonable time, thus increasing legal certainty for individuals and businesses.

The proposed regulation includes the processing of personal data. It should therefore ensure

that such processing complies with the requirements of Regulation (EU) 2016/679 of the

European Parliament and of the Council (the ‘General Data Protection Regulation’)18 and the

18 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data and on the free movement of

such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016,

p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj)

EN 15 EN

fundamental rights guaranteed in the Charter of Fundamental Rights, particularly the rights to

privacy and data protection in Articles 7 and 8 of the Charter, and in the TFEU, especially

Article 16 on the right to the protection of personal data. The preferred option is expected to

ensure a high level of security and data protection by giving users control, by minimising data

exposure, by guaranteeing selective disclosure, and by ensuring GDPR-compliant, secure and

transparent handling of personal data when using EUDI Wallets. Similarly, users will benefit

from legal safeguards when relying on enhanced physical documents.

4. BUDGETARY IMPLICATIONS

The proposal has very limited budgetary implications for the EU budget. The only operational

costs will be generated by organising meetings of the committee and the group on

digitalisation, and by supporting the Member States’ implementation of the digital solutions

established under the proposal. These expenses will be covered using existing internal budget

lines through redeployment of existing resources.

5. OTHER ELEMENTS

• Implementation strategy, implementation plans and monitoring, evaluation and

reporting arrangements

A comprehensive draft monitoring framework has been designed to monitor the

implementation and evaluate the initiative’s impact, thus ensuring it remains fit for purpose

and achieves the intended objectives. This framework will undergo further refinement based

on the ultimate legal specifications and implementation schedule. Progress will be tracked

through a set of operational, result and impact indicators linked to the specific objectives. The

framework will also help identify implementation challenges and help ensure that timely and

consistent implementation support is in place from the outset and throughout the rollout of the

initiative. The Commission, in close cooperation with Member States, will regularly collect

and analyse data, making use of existing reporting mechanisms. The data will be used to

identify implementation gaps and emerging implementation needs, assess the measure’s

efficiency, and provide the necessary evidence base for future evaluation.

The initiative could be evaluated no sooner than seven years following its entry into force to

assess the proposal’s actual impacts.

• Explanatory documents (for directives)

N/A

• Detailed explanation of the specific provisions of the proposal

Article 1 defines the subject matter, providing clarity as regards the proposal’s objectives.

Article 2 sets out the proposal’s material and personal scope by specifying the categories of

people and the social security branches to which the proposal applies.

EN 16 EN

Article 3 sets out the definitions of the main concepts used in the proposed regulation to

facilitate uniform interpretation and application.

Article 4 establishes the framework for the ESSPASS digital solution for the request,

issuance, cross-border verification, and recognition of social security documents, and outlines

its main features.

Article 5 determines the date from which Chapter I on the ESSPASS will apply to social

security documents. The deferred date of application is to give Member States sufficient time

to adapt to the new requirements.

Article 6 lays down an obligation for Member States to give individuals and businesses the

option to submit requests for the social security documents covered under the proposal fully

online using procedures that comply with Regulation (EU) 2018/172419.

Article 7 sets out the rules governing the issuance, validity and verification of social security

documents. It mandates a default digital format for these documents – intended for use in the

EUDI Wallets – while allowing for physical documents, enhanced with digital features to

strengthen their security. The article also provides for automatic notifications to the persons

concerned and the employers when documents are withdrawn and ensures cross-border

recognition and verification by designated verifiers to confirm authenticity, integrity and

validity. In addition, it confers implementing powers on the Commission to lay down the

functional, operational and technical specifications of the digital solution in accordance with

the examination procedure referred to in Article 5 of Regulation (EU) No 182/2011.

Article 8 introduces binding deadlines for the issuing of social security documents. This is to

prevent unnecessary delays, ensure the effective and timely exercise of rights under the EU

social security coordination rules and facilitate cross-border operations for businesses. The

article empowers the Commission to set document-specific deadlines through implementing

acts, subject to the examination procedure referred to in Article 5 of Regulation (EU)

No 182/2011.

Article 9 sets out specific provisions for the European Health Insurance Card.

Article 10 introduces convergence in information requirements for requests of the portable

document A1. This is to prevent inconsistencies across Member States in the verification of

the relevant facts before issuing such documents while streamlining request processes. The

Article also provides for a possible future technical interoperability between, on the one hand,

the national portals used to request the portable document A1 and, on the other hand, the

public interfaces connected to the Internal Market Information System for the posting of

drivers in the road transport sector and the posting declarations under Directive 2014/67/EU

of the European Parliament and of the Council20. The aim is to reduce administrative burdens

and promote reusability of data.

19 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012 (OJ L 295, 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj). 20 Directive 2014/67/EU of the European Parliament and of the Council of 15 May 2014 on the

enforcement of Directive 96/71/EC concerning the posting of workers in the framework of the

EN 17 EN

Article 11 reinforces the use of the EESSI system as the primary channel for cross-border data

exchanges between social security institutions under EU social security coordination rules.

The article provides that the system should continue to function in accordance with the

current technical and operational specifications. Any subsequent adaptations or enhancements

should be introduced via implementing acts, in accordance with the examination procedures

referred to in Article 5 of Regulation (EU) No 182/2011, to ensure their binding and uniform

application across all Member States. To further improve the trustworthiness of the system

and ensure that individuals have timely access to their social security benefits, the article also

introduces an obligation for Member States to comply with the maximum time periods for

exchanges through EESSI laid down in Annex I to the proposed Regulation. In addition, the

article empowers the Commission to adopt, where necessary, delegated acts to amend that

Annex.

Article 12 strengthens cooperation between Member States by providing a legal basis that

enables the electronic exchange of information to detect changes in circumstances affecting

social security rights and obligations and to better fight against fraud. The article empowers

the Commission to adopt technical arrangements through implementing acts, in accordance

with the examination procedure referred to in Article 5 of Regulation (EU) No 182/2011,

where the EESSI system is not deemed to be the most effective or appropriate exchange

method.

Article 13 creates a group on digitalisation in social security coordination to provide

operational support and establish a community of practice for exchanging experiences and

knowledge, thus facilitating cooperation among Member States.

Article 14 establishes a reporting obligation for Member States to ensure transparency and

accountability when implementing provisions related to Article 8(1) and Article 11(2).

Article 15 specifies the data protection requirements applicable to the processing of personal

data under the proposed regulation. It ensures that the processing of personal data carried out

pursuant to the proposed regulation complies with Regulation (EU) 2016/679 of the European

Parliament and of the Council and, where applicable, Regulation (EU) 2018/1725 of the

European Parliament and of the Council21.

Article 16 empowers the Commission to adopt delegated acts in accordance with Article 290

TFEU and lays down the conditions governing the exercise of that delegation.

Article 17 provides that the Commission will be assisted by a committee in adopting

implementing acts in accordance with Regulation (EU) No 182/2011.

Article 18 provides for the evaluation of the proposed regulation’s implementation and

effectiveness. Articles 19 and 20 provide for the amendment of Regulation 883/2004 and

provision of services and amending Regulation (EU) No 1024/2012 on administrative

cooperation through the Internal Market Information System (OJ L 159, 28.5.2014, pp. 11,

ELI: http://data.europa.eu/eli/dir/2014/67/oj) 21 Regulation (EU) No 2018/1725 of the European Parliament and of the Council of 23 October 2018 on

the protection of natural persons with regard to the processing of personal data by the Union

institutions, bodies, offices and agencies and on the free movement of such data, and repealing

Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39,

ELI: http://data.europa.eu/eli/reg/2018/1725/oj)

EN 18 EN

Regulation (EC) No 987/2009 of the European Parliament and of the Council to ensure their

alignment with the proposed regulation and the new governance framework, and to maintain

legal consistency.

Article 21 provides for the amendment of Annex II of Regulation (EU) 2018/1724 to include

in the scope of the Single Digital Gateway Regulation the online procedures for requesting the

social security documents falling within the scope of this Regulation.

Article 22 lays down the rules concerning the entry into force of the proposed regulation.

EN 19 EN

2026/0271 (COD)

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC) No

883/2004, (EC) No 987/2009 and (EU) No 2018/1724

(Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular

Article 48 thereof,

Having regard to the proposal from the European Commission,

After transmission of the draft legislative act to the national parliaments,

Acting in accordance with the ordinary legislative procedure,

Whereas:

(1) The free movement of persons is a fundamental freedom guaranteed by the Treaty on

the Functioning of the European Union (TFEU) and a cornerstone of the Union single

market. For this freedom to be fully realised, it is essential that individuals, workers

and their families can effectively exercise their social security rights when moving to,

staying in, residing or working in another Member State.

(2) To that end, the Union has established a comprehensive legal framework under

Regulations (EC) No 883/200422 and (EC) No 987/200923 of the European Parliament

and of the Council. Those rules coordinate Member States’ social security systems to

ensure that individuals in cross-border situations retain access to social security

benefits such as pensions, unemployment benefits and healthcare. However, the proper

application of those rules requires efficient social security procedures that keep pace

with technological progress and evolving societal needs.

(3) Digitalisation in social security coordination is essential to increase the efficiency of

data exchanges, accelerate claims processing, streamline access to benefits and reduce

administrative hurdles for individuals, businesses and national authorities. It also helps

strengthen fraud prevention, thereby reinforcing trust in the Union’s social security

coordination framework and contributing to making mobility free and fair for all.

22 Regulation (EC) No 883/2004 of the European Parliament and of the Council of 29 April 2004 on the

coordination of social security systems (OJ L 166, 30.4.2004, p. 1,

ELI: http://data.europa.eu/eli/reg/2004/883/oj).

23 Regulation (EC) No 987/2009 of the European Parliament and of the Council of 16 September 2009

laying down the procedure for implementing Regulation (EC) No 883/2004 on the coordination of

social security systems (OJ L 284, 30.10.2009, p. 1, ELI: http://data.europa.eu/eli/reg/2009/987/oj).

EN 20 EN

(4) The complexity of cross-border data exchanges and the further digitalisation of

procedures in social security coordination require a dedicated legal instrument, capable

of adapting to future technological, social and policy developments. That legal

instrument should complement the Union rules on social security coordination, laid

down in Regulations (EC) No 883/2004 and (EC) No 987/2009, by dealing with the

digital systems and processes necessary for those rules’ effective implementation and

enforcement. Since the provisions of this act are intrinsically linked and should

operate in conjunction with the social security coordination Regulations and

complement them, these provisions also need to take the form of a regulation.

(5) Due to the technical specificity, interoperability requirements and rapidly evolving

nature of digital processes, it is appropriate to adopt the necessary rules in the form of

a separate legal instrument. This is to ensure legal clarity and uniform application

across the Union, and to provide the flexibility to accommodate emerging digital

developments, without requiring amendments to the Union rules on social security

coordination.

(6) In order to ensure legal certainty and consistency with Regulation (EC) No 883/2004,

the scope of this legal instrument should be aligned with the personal and material

scope laid down in that Regulation.

(7) It is necessary to lay down rules for the establishment and operation of the European

Social Security Pass (ESSPASS). This is a digital solution for the electronic request,

issuance and cross-border verification of social security documents, including the

European Health Insurance Card (EHIC). The ESSPASS should ensure that

individuals are able to swiftly prove their social security rights and should support the

seamless exercise of those rights in cross-border situations, while enabling social

security institutions, labour inspectorates and healthcare providers to efficiently and

securely verify the relevant information. This in turn would facilitate fraud checks and

strengthen enforcement. The ESSPASS should also simplify compliance with

applicable requirements for businesses engaging workers, and for self-employed, in

cross-border situations.

(8) The ESSPASS pilot phase from 2021 to 2025, launched under the European Pillar of

Social Rights action plan and supported by the Digital Europe programme, proved

both the technical feasibility and the practical benefits of the ESSPASS.

(9) Procedures related to the portable document A1 and the EHIC have already

demonstrated their potential to reduce administrative burden, while the pilot phase has

provided evidence of their technical feasibility. The ESSPASS framework should first

apply to the portable document A1, reflecting its advanced state of technical

preparedness. It should subsequently apply to the EHIC, and to the other social

security documents, except those for which an assessment demonstrates no relevance,

feasibility or cost-effectiveness.

(10) To avoid duplication of effort, the ESSPASS should build on and complement existing

Union digital initiatives, particularly Regulations (EU) 2018/172424, (EU) 2024/90325

and (EU) 910/201426 of the European Parliament and of the Council.

24 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018

establishing a single digital gateway to provide access to information, to procedures and to assistance

and problem-solving services and amending Regulation (EU) No 1024/2012 (OJ L 295, 21.11.2018, p.

1, ELI: http://data.europa.eu/eli/reg/2018/1724/oj).

EN 21 EN

(11) Regulation (EU) 2018/1724 requires Member States to enable individuals and

businesses to complete certain procedures fully online. This includes requests to

determine which social security legislation covers the holder, resulting in the issuing

of the portable document A1, as well as applications for the EHIC and claims for

pension benefits. To ensure that individuals can fully exercise their rights to free

movement and labour mobility without administrative obstacles, the possibility to

submit requests fully online should be extended to cover the social security documents

within the scope of this Regulation. Annex II to Regulation (EU) 2018/1724 should

therefore be amended to include the online procedures for requesting the social

security documents falling within the scope of this Regulation.

(12) To maintain a human-centric approach to digitalisation and optimise Member States’

investments, reliance on the European Digital Identity Wallets as established by

Regulation (EU) 2024/1183 of the European Parliament and of the Council, in

combination with Regulation (EU) 2018/1724, is crucial. Those wallets provide a

harmonised, legally sound, highly secure and privacy-compliant mechanism for

securely storing and sharing digital identity data and documents.

(13) To promote efficiency and modernisation, digital social security documents should

become the default format. At the same time, it is essential that individuals and

businesses retain the right to request and receive physical social security documents.

This promotes inclusivity and avoids exacerbating inequalities in access to services.

The physical social security documents should be enhanced with standardised digital

features that enable their secure verification, thus helping to reduce the risk of fraud.

As those physical documents will contain digital features, they should fall within the

scope of this Regulation.

(14) Workers in cross-border situations often lack clear information about their social

security position. For instance, they might be unaware that employers have requested a

portable document A1 related to their cross-border activity or have had one issued.

Workers’ direct access to social security documents should therefore be facilitated,

improving transparency over social security rights and affiliation. This is expected to

reduce exposure to fraud and guarantee that workers swiftly receive the social security

benefits to which they are entitled.

(15) Given the importance of tackling cross-border social security fraud and reinforcing

mutual trust, Member States should properly verify the accuracy of the information

provided before issuing social security documents, exercising due diligence. The use

of digital tools should be promoted to support this process.

(16) Natural persons under legal representation, including minor children, might not have

access to a European Digital Identity Wallet. Therefore, legal representatives such as

parents, guardians or other duly authorised persons should be able to receive and store

the represented person’s digital social security documents in their own European

Digital Identity Wallet. This is necessary to facilitate access to digital documents of

persons under legal representation, which is particularly important when they need

medical care in emergencies.

25 Regulation (EU) 2024/903 of the European Parliament and of the Council of 13 March 2024 laying

down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act) (OJ L, 2024/903, 22.3.2024, ELI: http://data.europa.eu/eli/reg/2024/903/oj). 26 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on

electronic identification and trust services for electronic transactions in the internal market and

repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, pp. 73,

ELI: http://data.europa.eu/eli/reg/2014/910/oj

EN 22 EN

(17) To ensure equal access, the social security documents and the processes through which

they are requested, made available and shared should be accessible to persons with

disabilities in accordance with Directive (EU) 2016/2102 of the European Parliament

and of the Council27, and, where applicable, Directive (EU) 2019/882 of the European

Parliament and of the Council28.

(18) In order to ensure the timely exercise of the rights provided for in Regulation (EC) No

883/2004, competent institutions should be required to issue social security documents

to the person concerned and, where applicable, to the employer, within binding time

limits. Experience has shown that delays in the issuing of such documents can hinder

individuals’ timely access to benefits and create obstacles to the cross-border

operations of businesses. Given the importance of rapid access to healthcare during a

temporary stay abroad, the maximum deadline for the issuance of the European Health

Insurance Card should not exceed 24 hours from the submission of a complete request.

This should be achievable, as the only information to check is the actual insurance of

the person.

(19) To support seamless cross-border mobility, interoperability and synergies between the

ESSPASS and the Electronic Exchange of Social Security Information (EESSI)

system established in accordance with Regulation (EC) No 987/2009 should be

explored. Where appropriate, interoperability and synergies should also be explored

between the ESSPASS and other Union initiatives, including the Once-Only Technical

System, the proposed European Business Wallets, the Internal Market Information

(IMI) System and digital initiatives in the areas of posting of workers, pension

tracking, labour law, company law, taxation and digital health.

(20) The digitalisation of the EHIC under the ESSPASS will further improve individuals’

access to medically necessary healthcare during temporary stays in other Member

States. This in turn will enable healthcare providers across Europe to verify insurance

status swiftly and accurately, thus reducing instances of EHIC refusal and

inappropriate use of the card. To facilitate faster, more accurate and more secure

handling of reimbursement claims under Union social security coordination rules and

improve overall efficiency, it is crucial for healthcare providers to streamline the

transmission of relevant data through automated means. This should be done while

complying with data protection rules and the principle of proportionality. The

investments and adaptations for healthcare digital systems already provided for under

the European Health Data Space should be leveraged to create synergies that maximise

the efficiency of the digital healthcare systems, notably where interaction with the

EUDI Wallets is envisaged in both domains.

(21) The essential data required for requesting the portable document A1 should be aligned

across Member States. This is to ensure consistent verification of the facts relevant for

determining the applicable legislation, which is essential to help detect incorrect

declarations and fraud, as well as to reduce the administrative burden on employers

posting workers. Furthermore, national portals for requesting the portable document

A1 could be able to interoperate, through a streamlined technical implementation, with

the public interfaces connected to the Internal Market Information System (IMI) so

27 Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the

accessibility of the websites and mobile applications of public sector bodies (OJ L 327, 2.12.2016, p. 1,

ELI: http://data.europa.eu/eli/dir/2016/2102/oj).28 Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the

accessibility requirements for products and services (OJ L 151, 7.6.2019, p. 70,

ELI: http://data.europa.eu/eli/dir/2019/882/oj).

EN 23 EN

that common data can be submitted only once and then re-used where possible, in line

with the ‘once-only’ principle. Such possible interoperability should reduce

administrative burden for businesses and also facilitate cross-border provision of

services, in line with the Commission’s simplification objectives. To inform and

strengthen the development work, the Commission, with Member States’ support,

should also evaluate the cost-benefit ratio of the simplification and administrative

burden reduction, compatibility with existing systems and alignment with ongoing and

future Union initiatives, in particular any updates to the IMI regulatory framework.

Any interoperability measures should be consistent with Regulation (EU) 2018/1724

and facilitate compliance with the requirements applicable to the fully online

procedure and the once only principle for requesting the determination of the

applicable social-security legislation.

(22) ESSPASS is intended to complement the EESSI system. While ESSPASS provides a

solution for individuals and businesses to digitally interact with national authorities,

this Regulation should also govern exchanges between social security institutions,

especially those facilitated through the EESSI system. To ensure efficiency and

consistency, the EESSI system should remain the primary means for such exchanges.

(23) A comparative study by the Administrative Commission for the coordination of social

security systems has demonstrated that the processing of cross-border social security

cases takes on average four times longer than comparable national cases, across all

branches of social security. It is therefore essential to introduce measures to prevent

unnecessary delays in the treatment of cross-border cases caused by the late exchange

of data.

(24) The effective prevention and detection of errors and fraud in cross-border social

security matters requires efficient information exchange and close cooperation

between Member States. It is therefore necessary to lay down rules for data exchanges

in cases where the EESSI system cannot be used effectively. Those rules should

provide competent authorities and institutions with greater legal certainty and a robust

legal basis for exchanging data to detect fraud and inaccuracies in the information

underpinning rights provided for under Regulation (EC) No 883/2004, and for

verifying data through cross-checking with other Member States’ authorities and

institutions via electronic exchange or secure direct database access. All requests for

information and responses should remain necessary and proportionate.

(25) To support the consistent implementation of this Regulation and establish a

community of practice for exchanging experiences and knowledge, a group on

digitalisation in social security coordination should be established, composed of two

representatives of each Member State, combining technical and policy expertise on

digital aspects in the social security coordination field, and representatives of the

Commission. The details of its composition should be laid down in its rules of

procedure. That group should also continue the work previously carried out by the

Technical Commission for data processing, established pursuant to Article 73 of

Regulation (EC) No 883/2004, and the ad hoc groups of the Administrative

Commission for the coordination of social security systems, including the one on the

ESSPASS. To ensure the effective implementation of the ESSPASS framework, which

builds on the European digital identity framework, the Digitalisation Group should

cooperate, when relevant, with the Administrative Commission for the coordination of

social security systems and the European Digital Identity Cooperation Group.

EN 24 EN

(26) The European Labour Authority (ELA) should continue to play a crucial role in

supporting Member States’ efforts to digitalise cross-border social security processes.

This should consist in particular in facilitating the regular exchange of good practices

and experiences, promoting the effective use of digital tools, and providing capacity-

building measures such as training and knowledge-sharing initiatives, to boost national

authorities’ digital readiness. The ELA should also continue to raise awareness among

individuals, employers and other relevant stakeholders such as healthcare providers,

through targeted information campaigns, guidance materials and outreach activities.

This should help improve understanding and transparency regarding cross-border

social security rights and obligations, and regarding the available digital tools.

(27) Any processing of personal data under this Regulation should be undertaken in

accordance with Regulations (EU) 2016/679 and (EU) 2018/1725, and Directive

2002/58/EC29. Personal data should be processed under this Regulation only for the

specific purposes set out therein and Regulations (EC) No 883/2004 and (EC) No

987/2009, without affecting further processing for archiving purposes in the public

interest in accordance with Articles 5(1)(b) and 89 of Regulation (EU) 2016/679.

(28) This Regulation establishes a legal basis for the storage and processing of the data

contained in the social security documents for the purposes of proving and verifying

social security rights in cross-border situations. Personal data to be processed under

this Regulation should be data contained in these social security documents. That

personal data should concern, in particular, the information needed to digitally identify

natural persons, to facilitate the faster and more accurate exercise of rights under

Regulation (EC) No 883/2004, and to verify the validity and content of the

information and documents exchanged. This data shall belong to the following

categories of data: name, date and place of birth, address, personal identification

number, professional data and health data. In applying this Regulation, that personal

data will be handled by Member States’ issuers and verifiers. The Regulation limits

the storage period of personal data to the period strictly necessary for their

verification. The measures provided for in this Regulation are proportionate, as they

are strictly confined to what is required for verifying rights, managing social security

cases, ensuring compliance and combating fraud. Robust safeguards – including data

minimisation, access control and encryption – should be implemented in order to

ensure minimal intrusion while implementing acts should specify the common data

models.

(29) To ensure uniform conditions for the implementation of this Regulation, the power to

adopt acts in accordance with Article 290 TFEU should be delegated to the

Commission in respect of the list of social security documents for which the

application of the ESSPASS framework does not provide any added value and

amendments to Annex I. It is of particular importance that the Commission carry out

appropriate consultations during its preparatory work, including at expert level, and

that those consultations be conducted in accordance with the principles laid down in

the Interinstitutional Agreement of 13 April 2016 on Better Law-Making30. In

particular, to ensure equal participation in the preparation of delegated acts, the

European Parliament and the Council receive all documents at the same time as

29 Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the

processing of personal data and the protection of privacy in the electronic communications sector

(Directive on privacy and electronic communications) (OJ L 201, 31.7.2002, p. 37). 30 OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj.

EN 25 EN

Member States' experts, and their experts systematically have access to meetings of

Commission expert groups dealing with the preparation of delegated acts.

(30) In order to ensure uniform conditions for the implementation of this Regulation,

implementing powers should be conferred on the Commission to specify the

functional and technical specifications and procedures regarding social security

documents, specify the deadlines for issuing social security documents, lay down

common information requirements for requesting the portable document A1, establish

a common technical framework to ensure interoperability between national portals for

requesting that document and the public interfaces connected to IMI for the

declaration of posting of workers and drivers, specify future functional and technical

specifications of the EESSI system with regard to certain areas, establish a common

approach for the secure exchange of, or access to, data necessary for checks on the

correct application or enforcement of Regulations (EC) No 883/2004 and (EC) No

987/2009, and specify the format and structure of the Member States’ reports on the

implementation of this Regulation. Those powers should beexercisedin accordance

with Regulation (EU) No 182/2011 of the European Parliament and of the Council31.

(31) For reasons of clarity and consistency with this Regulation, obsolete provisions in

Regulations (EC) No 883/2004 and (EC) No 987/2009 related to the governance of

electronic data exchanges should be deleted. Those Regulations should therefore be

amended accordingly.

(32) To allow Member States sufficient time to adapt their administrative and technical

arrangements to the development of the ESSPASS, the application of the provisions

concerning the ESSPASS should be deferred.

(33) The European Data Protection Supervisor was consulted in accordance with

Article 42(1) of Regulation (EU) 2018/1725 [and delivered an opinion on …].

(34) Since the objectives of this Regulation, namely the establishment of a uniform, secure

and interoperable digital framework for the request, issuance and cross-border

verification of social security documents, as well as for the cross-border exchange of

social security information, cannot be sufficiently achieved by Member States acting

individually but can rather, by reason of the cross‑border nature and scale of the

action, be better achieved at Union level, the Union may adopt measures in accordance

with the principle of subsidiarity as set out in Article 5 of the Treaty on European

Union. In accordance with the principle of proportionality, as set out in that Article,

this Regulation does not go beyond what is necessary to achieve its objectives.

HAVE ADOPTED THIS REGULATION:

Article 1

Subject matter

1. This Regulation sets out rules for the digitalisation of cross-border exchanges of

social security information which facilitate the effective application and enforcement

of Regulations (EC) No 883/2004 and (EC) No 987/2009.

31 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011

laying down the rules and general principles concerning mechanisms for control by the Member States

of the Commission’s exercise of implementing powers (OJ L 55, 28.2.2011, p. 13,

ELI: http://data.europa.eu/eli/reg/2011/182/oj).

EN 26 EN

2. In particular, the Regulation lays down rules:

(a) on the establishment and operation of the European Social Security Pass

(ESSPASS), as a means to digitally and timely prove and verify social security

rights for individuals exercising their right to free movement and facilitate

compliance for employers;

(b) on the functioning, evolution and improvement of the Electronic Exchange of

Social Security Information (EESSI) system which ensures secure,

standardised and interoperable data exchanges between social security

institutions;

(c) on other digital cross-border exchanges of data between competent institutions

necessary to combat cross-border social security fraud, as well as to detect

changes in circumstances, inaccuracies, inconsistencies or errors.

3. This Regulation complements Regulations (EC) No 883/2004 and (EC)

No 987/2009. It shall not affect the rights and obligations laid down in those

Regulations, save where otherwise provided in this Regulation.

Article 2

Scope

This Regulation shall apply to persons falling within the scope of Regulation (EC)

No 883/2004, as laid down in its Article 2, and to the branches of social security listed in

Article 3(1) of that Regulation.

Article 3

Definitions

1. For the purposes of this Regulation, the definitions set out in Regulations (EC)

No 883/2004 and (EC) No 987/2009 apply.

2. The following definitions also apply:

(a) ‘European Social Security Pass’ or ‘ESSPASS’ means the digital solution for

the request, issuance, cross-border verification and recognition of social

security documents within the Union;

(b) ‘social security document’ means any set of data (irrespective of its format),

attesting to a person’s social security position, which is required for the

implementation of Regulation (EC) No 883/2004 and Regulation (EC)

No 987/2009;

(c) ‘European Digital Identity Wallet’ means a European Digital Identity Wallet

defined in Article 3, point (42), of Regulation (EU) No 910/2014 of the

European Parliament and of the Council;

(d) ‘digital social security document’ means a social security document issued by

the competent institution of a Member State, which is designed to be stored,

EN 27 EN

managed and shared via the European Digital Identity Wallet and verifiable

electronically;

(e) ‘portable document A1’ means the social security document referred to in

Article 19(2) of Regulation (EC) No 987/2009, issued by the competent

institution of a Member State, attesting that its legislation applies under Title II

of Regulation (EC) No 883/2004;

(f) ‘European Health Insurance Card’ or ‘EHIC’ means the social security

document issued in accordance with Article 25 of Regulation (EC)

No 987/2009;

(g) ‘issuer’ means any institution as defined in Article 1, point (p), of Regulation

(EC) No 883/2004, or any body or authority designated, recognised or

otherwise competent under the law of a Member State, which is responsible for

issuing, transmitting and, where necessary, rectifying or withdrawing social

security documents within the scope of Regulations (EC) No 883/2004 and

(EC) No 987/2009;

(h) ‘verifier’ means any public or private entity, or natural person acting in a

professional capacity, that is designated, authorised or recognised by a Member

State as being entitled to verify social security documents in accordance with

this Regulation.

Chapter I

European Social Security Pass

Article 4

Legal framework for the ESSPASS

1. The legal framework for the ESSPASS consists of the rules laid down in this Chapter

with regard to the following:

(a) the online submission, by the persons concerned and the employers, of requests

for social security documents to competent institutions of the Member States;

(b) the issuing of social security documents by the Member States’ competent

institutions to the persons concerned and the employers;

(c) the electronic verification of social security documents by verifiers, to confirm

their authenticity, integrity and validity.

Article 5

Scope and application of the legal framework for the ESSPASS

1. This Chapter shall apply:

(a) from [date of entry into force plus 12 months] to the portable document A1;

EN 28 EN

(b) from [date of entry into force plus 3 years] to EHIC, and to other social

security documents except those identified in the delegated acts adopted

pursuant to paragraph 2.

2. By [date of entry into force plus 18 months], the Commission may adopt delegated

acts establishing, on the basis of an assessment, a list of social security documents,

other than the portable document A1 and EHIC, for which this Chapter would not

apply.

3. The assessment shall consider the following:

(c) the operational relevance of the documents concerned, having regard in

particular to their frequency of issuance, the number of documents issued and

potential for fraud prevention;

(d) the expected costs and benefits of digitalising the documents concerned for the

exercise of social security rights and the efficient implementation of

Regulations (EC) No 883/2004 and (EC) No 987/2009, including the

administrative burden reduction for individuals and businesses.

Article 6

Online request procedures for social security documents

Persons concerned and, where applicable, employers, shall be able to submit requests for

social security documents falling within the scope of this Regulation fully online using

procedures that comply with Regulation (EU) 2018/1724. The online request procedure shall

be user-friendly, accessible and comply with the following requirements:

(a) It shall enable the electronic identification and authentication of the person

concerned and, where applicable, the employer;

(b) It shall allow for the electronic provision of the information, documents or

supporting evidence, referred to in Article 3(2) of Regulation (EC) No 987/2009,

necessary to process the request;

(c) It shall ensure that the final submission of the request can be completed remotely;

(d) It shall provide the person concerned and, where applicable, the employer with an

automatic acknowledgement of receipt after the completed submission has been

completed, unless the document is issued immediately;

(e) It shall notify the person concerned and, where applicable, the employer,

electronically that the issuing procedure has been completed.

EN 29 EN

Article 7

Issuance, validity and verification of social security documents

1. The competent institutions shall issue digital social security documents in a format

suitable for use in the European Digital Identity Wallet of the person concerned and,

where relevant, of the employer. The digital social security documents shall comply

with the technical specifications adopted pursuant to paragraph 11.

2. By way of derogation from paragraph 1, at the request of the person concerned or the

employer, the competent institutions shall issue the social security document in a

standardised and accessible physical format. Such a document shall include a QR

code or other electronic features to enhance its security and shall comply with the

technical specifications adopted pursuant to paragraph 11.

3. Each Member State shall communicate to the Commission a list of issuers and shall

keep that list up to date. The Commission shall make those lists available to the

public through a secure channel and in an electronically signed or sealed form

suitable for automated processing. With regard to issuers of the portable document

A1, the list shall be communicated to the Commission by [date of entry into force

plus 12 months]. Member States shall communicate the list of issuers of EHIC and

other social security documents falling within the scope of this Chapter by [date of

entry into force plus 3 years].

4. Before issuing a social security document, the issuers shall verify the accuracy of the

information provided by the persons concerned and, where applicable, by the

employers in support of their request, including by means of digital tools.

5. Where a social security document referred to in paragraph 1 or paragraph 2 is

revoked, the issuer shall immediately notify the person concerned and, where

applicable, the employer. Notification shall be made by electronic means, except if

other means are indicated by both the person concerned and, where applicable, the

employer.

6. The issuers shall ensure that a person is able to receive and store, within their own

European Digital Identity Wallet, the digital social security documents of their minor

children and of a natural person whom they legally represent.

7. Social security documents issued under paragraphs 1 and 2 by one Member State

shall be recognised by verifiers in all Member States.

Where a document issued in accordance with this Regulation has been verified, its

validity or authenticity shall not be subject to further proof requirements in the host

Member State. This paragraph shall be without prejudice to the procedures

applicable in the event of doubt or dispute under Regulations (EC) No 883/2004 and

(EC) No 987/2009.

8. Member States shall ensure that verifiers established on their territory are equipped

with the necessary technical means to verify the social security documents issued

under this Article, regardless of the format, in order to confirm their authenticity,

integrity and validity. They shall be able to verify that:

(a) the document was issued by an authorised institution;

(b) the data contained in the document have not been tampered with since it was

issued;

EN 30 EN

(c) the document has not expired or been revoked.

9. Personal data processed for the purposes of verifying the concerned person’s social

security document shall not be retained by the verifier after the verification is

complete, unless it is necessary to apply Regulations (EC) No 883/2004 and (EC) No

987/2009, or authorised by other Union or national legal act in accordance with

Regulation (EU) 2016/679 or Directive (EU) 2016/68032.

10. ESSPASS shall be interoperable with the EESSI system and, where appropriate, with

other relevant Union digital initiatives, including the European Health Data Space

and the Once-Only Technical system.

11. The Commission shall adopt implementing acts specifying the functional and

technical specifications regarding the documents referred to in paragraphs 1 and 2.

Those implementing acts shall include:

(a) the technical and interoperability specifications, including common data

models establishing the data to be processed, standards and accessibility

requirements;

(b) the procedures for requesting, issuing, revoking and verifying documents,

including aspects related to the lists of issuers in accordance with paragraph 3

of this Article;

(c) the technical and organisational security measures, including encryption and

access control measures;

(d) the organisational measures for processing and protecting personal data,

including with regard to the retention periods, and the roles of controllers and

processors in accordance with Regulation (EU) 2016/679.

Those implementing acts shall be adopted in accordance with the examination procedure

referred to in Article 17(2).

Article 8

Deadlines for issuing social security documents

1. Competent institutions shall issue social security documents to the person concerned

and, where applicable, the employer in compliance with the deadlines established in

accordance with paragraphs 2 and 3.

2. By [date of entry into force plus 18 months], the Commission shall adopt

implementing acts specifying the deadlines for issuing social security documents

32 Directive (EU) 2016/680 of the European Parliament and of the Council of 27 April 2016 on the

protection of natural persons with regard to the processing of personal data by competent authorities for

the purposes of the prevention, investigation, detection or prosecution of criminal offences or the

execution of criminal penalties, and on the free movement of such data, and repealing Council

Framework Decision 2008/977/JHA (OJ L 119, 4.5.2016, p. 89,

ELI: http://data.europa.eu/eli/dir/2016/680/oj).

EN 31 EN

under the scope of this Chapter, calculated from the submission of a complete

request.

3. By way of derogation from paragraph 2, the implementing act specifying the

deadline for issuing the portable document A1 shall be adopted by [date of entry into

force plus 12 months].

4. For the issuance of the European Health Insurance Card, the maximum deadline shall

not exceed 24 hours.

5. When specifying the deadlines, the Commission shall take into account the

following:

(a) the type of social security document requested;

(b) the procedural steps required for verifying the information provided before

issuing the requested social security document, including where relevant the

necessary exchanges of information between competent institutions;

(c) the need to ensure the timely exercise of rights under Regulation (EC)

No 883/2004.

Those implementing acts shall be adopted in accordance with the examination

procedure referred to in Article 17(2).

6. Upon receipt of the request, the issuer shall inform the persons concerned or the

employers, as applicable, of the expected time required to process their request and

of the applicable deadlines laid down in the implementing acts adopted pursuant to

paragraph 2.

Article 9

European Health Insurance Cards

1. From [date of entry into force plus 3 years], all newly issued European Health

Insurance Cards shall comply with the requirements laid down in Article 7. European

Health Insurance Cards already in circulation which have not yet expired at that date

shall be replaced no later than [date of entry into force plus 5 years].

2. From [date of entry into force plus 3 years], Member States shall ensure that

healthcare providers on their territory are able to transmit electronically the data

contained in the European Health Insurance Card of a patient from another Member

State, and all the data that need to be transmitted for the reimbursement process, to

the competent institutions of the Member State of treatment.

Article 10

Portable document A1

1. By [date of entry into force plus 12 months], the Commission shall adopt

implementing acts establishing common information requirements for requesting the

EN 32 EN

portable document A1, not exceeding what is necessary to determine the applicable

legislation and with due regard to administrative burden reduction.

2. The Commission shall establish, by means of implementing acts, a common

technical framework to ensure interoperability between national portals used to

request the portable document A1 and the public interfaces connected to the Internal

Market Information System33 for the declaration of posting of workers and for the

posting of drivers in road transport, as provided for in Article 1(11) of Directive (EU)

2020/1057. That technical framework shall enable the reuse of relevant submitted

data across the procedures for the request of the portable document A1 and the

submission of posting declarations, in compliance with Regulations (EU) 2016/679

and (EU) 2018/1725 and the once-only principle.

3. The implementing acts referred to in paragraphs 1 and 2 shall be adopted in

accordance with the examination procedure referred to in Article 17(2).

Chapter II

Exchanges between institutions

Article 11

Exchanges through the EESSI system

1. Member States shall exchange, access and process the data required to apply

Regulations (EC) No 883/2004 and (EC) No 987/2009 via the EESSI system in

accordance with the functional and technical specifications as laid down pursuant to

Article 78 of Regulation (EC) No 987/2009.

2. When exchanging the data via the EESSI system, Member States shall comply with

the maximum time periods laid down in Annex I to this Regulation.

3. The Commission is empowered to adopt delegated acts in accordance with Article 16

in order to amend Annex I, taking into account the following:

(a) the business use cases and the structured electronic documents involved in the

exchange;

(b) the procedural steps required for gathering the information, including where

relevant the necessary exchanges of information between competent

institutions at the national level;

(c) the need to ensure the timely exercise of rights under Regulation (EC)

No 883/2004.

33 Regulation (EU) No 1024/2012 of the European Parliament and of the Council of 25 October 2012 on

administrative cooperation through the Internal Market Information System and repealing Commission

Decision 2008/49/EC (‘the IMI Regulation’) (OJ L 316, 14.11.2012, p. 1,

ELI: http://data.europa.eu/eli/reg/2012/1024/oj).

EN 33 EN

4. For the purposes of personal data processing within the EESSI system, the

Commission shall be considered a processor as defined in Article 3, point (12), of

Regulation (EU) 2018/1725 and Member States’ joint controllers as referred to in

Article 26 of Regulation (EU) 2016/679.

5. The Commission shall further specify, by way of implementing acts, the functional

and technical specifications of the EESSI system with regard to the following areas:

(a) the business use cases and the structure, format, content and data models of the

information exchanged;

(b) the procedural and technical rules for data exchanges;

(c) the roles and responsibilities of the bodies involved in the exchanges;

(d) business continuity measures;

(e) security and data protection measures;

(f) operational and support measures;

(g) the details of the public database containing the information specified in

Article 88(4) of Regulation (EC) No 987/2009;

(h) the service levels.

Those implementing acts shall be adopted in accordance with the examination

procedure referred to in Article 17(2).

Article 12

Electronic exchange of information

outside the EESSI system

1. By way of derogation from Article 11(1), where the exchange of data necessary for

controls on the correct application or enforcement of Regulations (EC) No 883/2004

and (EC) No 987/2009, including for the purposes of detecting changes in

circumstances, inaccuracies, inconsistencies, fraud and error, cannot be effectively

carried out through the EESSI system, such data, or secure access to such data may

be provided outside the EESSI system, in accordance with the common procedures

and specifications established pursuant to paragraph 2.

2. The Commission shall, where applicable, adopt implementing acts to establish

common procedures and functional and technical specifications for the secure

exchange of data or access to data referred to in paragraph 1.

3. The implementing acts may include the following:

(a) arrangements concerning the categories of data to be exchanged or made

accessible and the role and responsibility of the bodies involved in the

exchanges;

(b) the means of exchange or access;

(c) standard formats or structures;

(d) measures ensuring the security, integrity and reliability of the exchange or

access.

EN 34 EN

Those implementing acts shall be adopted in accordance with the examination

procedure referred to in Article 17(2).

Chapter III

Governance and data processing

Article 13

Digitalisation Group

1. A group on digitalisation in social security coordination (the ‘Digitalisation

Group’) is established to facilitate cross-border cooperation on the digital aspects of

the coordination of social security systems set out in this Regulation.

2. The Digitalisation Group shall be made up of two government representatives from

each of the Member States, assisted, where necessary, by expert advisers.

Representatives of the European Commission shall also attend the meetings of the

Digitalisation Group. The Group shall be chaired by the Commission, which shall

also provide its secretariat.

3. The Digitalisation Group shall have the following tasks:

(a) support the consistent implementation of this Regulation by facilitating

coordination, the exchange of information and the promotion of best practices

across Member States and developing guidelines to support enforcement of this

Regulation;

(b) provide recommendations to the committee referred to in Article 17, where

appropriate, on further digitalisation of the coordination of social security

systems;

(c) support the development and operation of electronic data exchanges in

accordance with this Regulation;

(d) advise the Commission, as appropriate, in the early preparations of draft

implementing acts to be adopted pursuant to this Regulation.

4. The Digitalisation Group shall cooperate, when relevant, with the Administrative

Commission for the coordination of social security systems referred to in Title IV of

Regulation (EC) No 883/2004 and with the European Digital Identity Cooperation

Group referred to in Article 46e of Regulation (EU) No 910/2014.

5. The Digitalisation Group shall adopt its rules of procedure.

Article 14

Monitoring and reporting

EN 35 EN

1. Member States shall collect the data necessary for monitoring the implementation of

Article 8(1) and Article 11(2) and shall transmit those data to the Commission

quarterly, by the end of the month following each calendar quarter. The Commission

shall publish statistics based on the data collected.

2. The Commission shall adopt implementing acts specifying the format and structure

of the reports referred to in paragraph 1. Those implementing acts shall be adopted in

accordance with the examination procedure referred to in Article 17(2).

Article 15

Protection and processing of personal data

1. Personal data required for the application of this Regulation shall be processed by

Member States’ issuers and verifiers for the purposes of issuing and verifying of

social security documents as defined by implementing acts adopted under the present

Regulation. In particular, personal data shall be processed under this Regulation for

the purposes of:

(a) issuing social security documents;

(b) determining social security rights of documents’ holders;

(c) verifying the validity of social security documents and information contained

therein.

2. Personal data to be processed pursuant to this Regulation shall be those contained in

the social security documents handled, for the purposes referred to in paragraph 1 by

Member States’ issuers and verifiers. Processing of personal data under this

Regulation shall be limited to the extent necessary for the purposes set out in

paragraph 1, without affecting further processing for archiving purposes in the public

interest in accordance with Article 5(1), point (b) and Article 89 of the Regulation

(EU) 2016/679.

3. For the purposes of this Regulation, Member States’ issuers of social security

documents under the ESSPASS framework shall be regarded as controllers within

the meaning of Article 4(7) of the Regulation (EU) 2016/679. Controllers shall

ensure the security, integrity, authenticity and confidentiality of the data processed

for the purposes set out in paragraph 1.

Chapter IV

Final provisions

Article 16

Exercise of the delegation

EN 36 EN

1. The power to adopt delegated acts is conferred on the Commission subject to the

conditions laid down in this Article.

2. The power to adopt delegated acts referred to in Articles 5(2) and 11(3) shall be

conferredon the Commission for an indeterminate period of time from [the date of

entry into force of this Regulation].

3. The delegation of power referred to in Articles 5(2) and 11(3) may be revoked at any

time by the European Parliament or by the Council. A decision to revoke shall put an

end to the delegation of the power specified in that decision. It shall take effect the

day following the publication of the decision in the Official Journal of the European

Union or at a later date specified therein. It shall not affect the validity of any

delegated acts already in force.

4. Before adopting a delegated act, the Commission shall consult experts designated by

each Member State in accordance with the principles laid down in the

Interinstitutional Agreement of 13 April 2016 on Better Law-Making.

5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to

the European Parliament and to the Council.

6. A delegated act adopted pursuant to Articles 5(2) and 11(3) shall enter into force

only if no objection has been expressed either by the European Parliament or by the

Council within a period of [two months] of notification of that act to the European

Parliament and the Council or if, before the expiry of that period, the European

Parliament and the Council have both informed the Commission that they will not

object.That period shall be extended by [two months] at the initiative of the

European Parliament or of the Council.

Article 17

Committee

1. The Commission shall be assisted by a committee within the meaning of Regulation

(EU) No 182/2011.

2. Where reference is made to this paragraph, Article 5 of Regulation (EU)

No 182/2011 shall apply.

Article 18

Evaluation

1. By [seven years after the date of entry into force], the Commission shall evaluate the

implementation and effectiveness of this Regulation.

2. The evaluation shall assess, in particular, whether the objectives of this Regulation

have been achieved and whether its provisions remain relevant, effective, efficient,

coherent and proportionate.

3. The Commission shall submit a report on the findings of the evaluation to the

European Parliament and the Council. The report shall be made publicly available.

EN 37 EN

Article 19

Amendments to Regulation (EC) No 883/2004

1. Regulation (EC) No883/2004 is amended as follows:

(1) in Article 72, point (d) is deleted;

(2) Article 73 is deleted.

2. Decisions of the Administrative Commission concerning digital aspects, adopted

under Article 72, point (d) of Regulation (EC) No 883/2004, shall continue to

serve as guidance until the implementing acts provided for in this Regulation enter

into force. The Technical Commission on social security coordination referred to in

Decision H15 shall continue to work until the adoption of the rules of procedure of

the Digitalisation Group pursuant to Article 13(5).

Article 20

Amendments to Regulation (EC) No 987/2009

Article 4 of Regulation (EC) No 987/2009 is amended as follows:

(1) paragraph 1 is deleted;

(2) in paragraph 3, the second sentence is deleted.

Article 21

Amendments to Regulation (EU) 2018/1724

Annex II to Regulation (EU) 2018/1724 is amended as follows:

In the table, the following row is inserted after the row 'Retiring':

Exercising social

security rights

Applications, requests and

notifications relating to the

exercise of social security rights

under Regulation [ESSPASS

Proposal].

Confirmation of applications,

requests and notifications relating to

the exercise of social security rights,

as well as all outputs pertaining to

the procedures under Regulation

[ESSPASS Proposal].

Article 22

Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in

the Official Journal of the European Union.

EN 38 EN

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Strasbourg,

For the European Parliament For the Council

The President The President

EN 1 EN

LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3

1.1. Title of the proposal/initiative ...................................................................................... 3

1.2. Policy area(s) concerned .............................................................................................. 3

1.3. Objective(s) .................................................................................................................. 3

1.3.1. General objective(s) ..................................................................................................... 3

1.3.2. Specific objective(s) ..................................................................................................... 3

1.3.3. Expected result(s) and impact ...................................................................................... 3

1.3.4. Indicators of performance ............................................................................................ 3

1.4. The proposal/initiative relates to: ................................................................................. 4

1.5. Grounds for the proposal/initiative .............................................................................. 4

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative ............................................................ 4

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section ‘added value of EU involvement’ is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone. ................................................................................. 4

1.5.3. Lessons learned from similar experiences in the past .................................................. 4

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments ....................................................................................... 5

1.5.5. Assessment of the different available financing options, including scope for

redeployment ................................................................................................................ 5

1.6. Duration of the proposal/initiative and of its financial impact .................................... 6

1.7. Method(s) of budget implementation planned ............................................................. 6

2. MANAGEMENT MEASURES................................................................................... 8

2.1. Monitoring and reporting rules .................................................................................... 8

2.2. Management and control system(s) ............................................................................. 8

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed .................. 8

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them............................................................................................................ 8

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure) ........................................... 8

2.3. Measures to prevent fraud and irregularities ................................................................ 9

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10

EN 2 EN

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)

affected ....................................................................................................................... 10

3.2. Estimated financial impact of the proposal on appropriations ................................... 12

3.2.1. Summary of estimated impact on operational appropriations.................................... 12

3.2.1.1. Appropriations from voted budget ............................................................................. 12

3.2.1.2. Appropriations from external assigned revenues ....................................................... 17

3.2.2. Estimated output funded from operational appropriations......................................... 22

3.2.3. Summary of estimated impact on administrative appropriations ............................... 24

3.2.3.1. Appropriations from voted budget .............................................................................. 24

3.2.3.2. Appropriations from external assigned revenues ....................................................... 24

3.2.3.3. Total appropriations ................................................................................................... 24

3.2.4. Estimated requirements of human resources.............................................................. 25

3.2.4.1. Financed from voted budget....................................................................................... 25

3.2.4.2. Financed from external assigned revenues ................................................................ 26

3.2.4.3. Total requirements of human resources ..................................................................... 26

3.2.5. Overview of estimated impact on digital technology-related investments ................ 28

3.2.6. Compatibility with the current multiannual financial framework.............................. 28

3.2.7. Third-party contributions ........................................................................................... 28

3.3. Estimated impact on revenue ..................................................................................... 29

4. DIGITAL DIMENSIONS .......................................................................................... 29

4.1. Requirements of digital relevance .............................................................................. 30

4.2. Data ............................................................................................................................ 30

4.3. Digital solutions ......................................................................................................... 31

4.4. Interoperability assessment ........................................................................................ 31

4.5. Measures to support digital implementation .............................................................. 32

EN 3 EN

1. FRAMEWORK OF THE PROPOSAL/INITIATIVE

1.1. Title of the proposal/initiative

Proposal for a Regulation of the European Parliament and of the Council on

digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC)

No 883/2004, (EC) No 987/2009 and (EU) No 2018/1724

1.2. Policy area(s) concerned

People, society and social model, Free movement of persons, labour mobility

Access to services

Digitalisation of public administrations

1.3. Objective(s)

1.3.1. General objective(s)

The initiative aims to promote fair mobility within the EU, facilitating access to

social security rights for all individuals - in line with the European Pillar of Social

Rights and the single market strategy. It supports the Union’s cross-cutting

objectives of simplification and reduction of administrative hurdles through

digitalised cross-border public services.

1.3.2. Specific objective(s)

The specific objectives of the initiative are:

(1) Cross-border social security cases requiring the proof and verification of

social security rights and insurance status are handled with reduced manual

intervention and streamlined administrative steps, leading to faster and more

consistent processing.

(2) Cross-border interoperability is strengthened through converged documents’

formats, data models and verification methods across the EU, enabling

seamless exchange of information and reducing fraud.

(3) Individuals experience improved accessibility, awareness, and control over

their cross-border social security rights and data.

Individuals experience improved accessibility, awareness, and control over their cross-border

social security rights and data.

1.3.3. Expected result(s) and impact

The initiative is expected to reinforce the social security coordination framework, by

improving rules’ application and making their implementation simpler, more

efficient, and resistant to fraud.

It will increase the transparency and accessibility of rights for individuals, while

helping reduce fraudulent and exploitative practices. It is also anticipated to assist

businesses, making it easier for them to carry out activities across borders, and to

EN 4 EN

support national authorities by simplifying processes and enhancing cooperation. The

initiative will drive the digitalisation of cross-border public services, ultimately

contributing to a better competitiveness of the EU economy.

1.3.4. Indicators of performance

A comprehensive draft monitoring framework has been designed to monitor the

implementation and evaluate the initiative’s impact, ensuring that it remains fit for

purpose and achieve the intended objectives. This framework will undergo further

refinement based on the ultimate legal specifications and implementation schedule.

Indicators includes:

1) Percentage of procedures fully available online

2) Percentage of documents issued electronically

3) Percentage of compliant national authorities

4) Number of complaints by businesses and individuals on cases exceeding the

deadlines

5) Proportion of documents processed automatically across Member States

6) Reduction in processing time to issue and verify documents

7) Number of rejected healthcare reimbursement invoices

8) Reduction in the cases of falsified portable documents and inappropriate use of

EHIC

9) Percentage of users satisfied with the solution and awareness rating

10) Time of completion of users’ requests (reducing average time, reducing

difference between minimum and maximum time needed between Member

States)

11) Number of cross-border verifications completed successfully (transaction

volume, increasing)

12) Cybersecurity indices of data safety.

A comprehensive draft monitoring framework has been designed to monitor the

implementation and evaluate the initiative’s impact, ensuring that it remains fit for purpose

and achieve the intended objectives. This framework will undergo further refinement based on

the ultimate legal specifications and implementation schedule.

Indicators includes:

EN 5 EN

Percentage of procedures fully available online

Percentage of documents issued electronically

Percentage of compliant national authorities

Number of complaints by businesses and individuals on cases exceeding the deadlines

Proportion of documents processed automatically across Member States

Reduction in processing time to issue and verify documents

Number of rejected healthcare reimbursement invoices

Reduction in the cases of falsified portable documents and inappropriate use of EHIC

Percentage of users satisfied with the solution and awareness rating

Time of completion of users’ requests (reducing average time, reducing difference

between minimum and maximum time needed between Member States)

Number of cross-border verifications completed successfully (transaction volume,

increasing)

Cybersecurity indices of data safety.

1.4. The proposal/initiative relates to:

a new action

a new action following a pilot project / preparatory action34

the extension of an existing action

a merger or redirection of one or more actions towards another/a new action

1.5. Grounds for the proposal/initiative

1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for

roll-out of the implementation of the initiative

The main requirement for the short-term is to reach an agreement on the legislative

proposal by co-legislators by Q3 2027.

The proposal provides for the adoption of implementing acts.

1.5.2. Added value of EU involvement (it may result from different factors, e.g.

coordination gains, legal certainty, greater effectiveness or complementarities). For

the purposes of this section ’added value of EU involvement’ is the value resulting

from EU action, that is additional to the value that would have been otherwise

created by Member States alone.

Action at the EU level delivers significant added value by supporting the free

movement of people for study, travel, residency, family or business purposes. Given

the cross-border nature of the identified issues, only EU-level intervention rather

than individual Member State efforts can effectively solve these. An action at EU

level will ensure alignments with other EU digital initiatives, such as the Single

Digital Gateway Regulation and the European Digital Identity framework, ensuring

34 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.

EN 6 EN

the necessary efficiency and. EU-level action prevents fragmentation that could arise

if Member States develop disparate digital solutions, leading to suboptimal outcomes

and potentially higher costs to remedy.

1.5.3. Lessons learned from similar experiences in the past

One of the key considerations in estimating the budgetary requirements for this

initiative has been the valuable lessons learned from past experiences, particularly

those derived from the implementation of the Electronic Exchange of Social Security

Information (EESSI) system. The financial projections take into account the

operational and technical support necessary for Member States’ national

implementation, ensuring that adequate resources are allocated. Additionally,

insights gained from the ESSPASS pilot activities have provided a clearer

understanding of the scope of effort and resource allocation.

1.5.4. Compatibility with the multiannual financial framework and possible synergies with

other appropriate instruments

The proposal is compatible with the multiannual financial framework.

It is part of the Fair labour mobility package, it supports the European pillar of social

rights and the Digital decade policy programme.

1.5.5. Assessment of the different available financing options, including scope for

redeployment

The implementation of this legislative proposal requires the organisation of meetings

with Member States in the Group on digitalisation in social security coordination and

in the Committee supporting the adoption of implementing acts as well as human

resources to support Member States’ national implementation. The necessary

expenditure for organising these meetings, i.e. travel costs of delegates, and

providing this support is covered by the general budget.

EN 7 EN

1.6. Duration of the proposal/initiative and of its financial impact

limited duration

•  in effect from [DD/MM]YYYY to [DD/MM]YYYY

•  financial impact from YYYY to YYYY for commitment appropriations and

from YYYY to YYYY for payment appropriations.

unlimited duration

(1) Implementation with a start-up period from 2026 to 2030,

(2) followed by full-scale operation.

1.7. Method(s) of budget implementation planned

Direct management by the Commission

•  by its departments, including by its staff in the Union delegations;

•  by the executive agencies

Shared management with the Member States

Indirect management by entrusting budget implementation tasks to:

•  third countries or the bodies they have designated

•  international organisations and their agencies (to be specified)

•  the European Investment Bank and the European Investment Fund

•  bodies referred to in Articles 70 and 71 of the Financial Regulation

•  public law bodies

•  bodies governed by private law with a public service mission to the extent that

they are provided with adequate financial guarantees

•  bodies governed by the private law of a Member State that are entrusted with the

implementation of a public-private partnership and that are provided with adequate

financial guarantees

•  bodies or persons entrusted with the implementation of specific actions in the

common foreign and security policy pursuant to Title V of the Treaty on European

Union, and identified in the relevant basic act

• bodies established in a Member State, governed by the private law of a Member

State or Union law and eligible to be entrusted, in accordance with sector-specific

rules, with the implementation of Union funds or budgetary guarantees, to the extent

that such bodies are controlled by public law bodies or by bodies governed by private

law with a public service mission, and are provided with adequate financial

guarantees in the form of joint and several liability by the controlling bodies or

equivalent financial guarantees and which may be, for each action, limited to the

maximum amount of the Union support.

Comments

From 2028 onwards, a modest but ongoing financial requirement will arise. This will need to

be accounted for in the preparation of the post-2027 MFF (2028-2034), ensuring adequate

allocation for continued implementation support.

EN 8 EN

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial Framework.

The source of financing and scope of Union financial commitment in the post-2027 period

remain subject to the outcome of interinstitutional negotiations on the MFF 2028-2034 and

thereafter shall be determined through the annual budgetary procedure. All appropriations and

staffing allocations as of 2028 are indicative.

EN 9 EN

2. MANAGEMENT MEASURES

2.1. Monitoring and reporting rules

The proposed Regulation establishes a reporting obligation for Member States to

ensure transparency and accountability in the implementation of provisions related to

deadlines to issue social security documents and to exchange data through the

Electronic Exchange of Social Security system.

2.2. Management and control system(s)

2.2.1. Justification of the budget implementation method(s), the funding implementation

mechanism(s), the payment modalities and the control strategy proposed

Direct management, as per Article 62.1(a) of the Financial Regulation, is the

preferred mode of implementation, as the actions will be carried out by the European

Commission, specifically Directorate-General for Employment, Social Affairs and

Inclusion (DG EMPL), which will ensure the coordination with Member States and

the various stakeholders.

2.2.2. Information concerning the risks identified and the internal control system(s) set up

to mitigate them

The controls are part of the internal control system of DG EMPL. The new activities

will be subject to the same risk identification and mitigation approach.

2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between

the control costs and the value of the related funds managed), and assessment of the

expected levels of risk of error (at payment & at closure)

The controls are integrated into the internal control system of DG EMPL. The new

activities will generate negligeable additional control costs at DG level.

2.3. Measures to prevent fraud and irregularities

The Commission shall ensure that, when actions financed are implemented, the financial

interests of the Union are protected by the application of preventive measures against fraud,

corruption and any other illegal activities, by effective checks and by the recovery of the

amounts unduly paid and, if irregularities are detected, by effective, proportional and

dissuasive penalties. The Commission is authorised to carry out checks and verifications in

situ under this Decision, in compliance Council Regulation (Euratom, EC) No 2185/96 of

11 November 1996 concerning on-the-spot checks and inspections carried out by the

Commission in order to protect the European Communities financial interests against fraud

and other irregularities. If need be, investigations shall be carried out by the European Anti-

Fraud Office and shall be governed by Regulation (EC) No 1073/1999 of the European

Parliament and of the Council of 25 May 1999 concerning investigations conducted by the

European Anti-Fraud Office.

EN 10 EN

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

3.1. Heading(s) of the multiannual financial framework and expenditure budget

line(s) affected

– Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of

multiannual

financial

framework

Budget line Type of

expenditure Contribution

Number Headings 2

Non-

diff 35

.

from

EFTA

countries 36

from

candidate

countries

and

potential

candidates 37

From

other

third

countries

other assigned

revenue

2

Prerogatives - Free movement of workers,

coordination of social security schemes

and measures for migrants, including

migrants from third countries

diff. YES/NO YES/NO YES/NO NO

35 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 36 EFTA: European Free Trade Association. 37 Candidate countries and, where applicable, potential candidates from the Western Balkans.

EN 11 EN

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

(3)  The proposal/initiative does not require the use of operational appropriations

(1)  The proposal requires the use of operational appropriations, as explained below

3.2.1.1. Appropriations from voted budget

EUR million (to three decimal places)

DG: EMPL Year Year Year Year Year Year Year

TOTAL MFF 2028-2034 2028 2029 2030 2031 2032 2033 2034

Operational appropriations

Budget line Prerogatives –

Free movement of workers,

coordination of social security schemes and measures

for migrants, including migrants from third countries

Commitments (1a) 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

Payments (2a) 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

Budget line Commitments (1b) 0

Payments (2b) 0

Appropriations of an administrative nature financed from the envelope of specific programmes38

Budget line (3) 0

TOTAL appropriations Commitments =1a+1b+3 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5.25

for DG EMPL Payments =2a+2b+3 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5.25

38 Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

EN 12 EN

Year Year Year Year Year Year Year TOTAL

MFF

2028-

2034 2028 2029 2030 2031 2032 2033 2034

TOTAL operational

appropriations

Commitments (4) 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

Payments (5) 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

TOTAL appropriations of an administrative nature financed from the envelope for

specific programmes (6) 0 0 0 0 0 0 0 0

TOTAL appropriations

under HEADING 2 Payments =4+6 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

of the multiannual

financial framework =5+6 0.750 0.750 0.750 0.750 0.250 0.250 0.250 5.25

==================================================================================================

Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

• TOTAL

operational

appropriations (all

operational

headings)

Commitments (4) 0 0 0 0 0 0 0 0

Payments (5) 0 0 0 0 0 0 0 0

• TOTAL appropriations of an

administrative nature financed from

the envelope for specific programmes

(all operational headings)

(6) 0 0 0 0 0 0 0 0

TOTAL

appropriations

Under

Heading 1 to 3

Commitments =4+6 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

EN 13 EN

of the multiannual

financial framework Payments =5+6 0.750 0.750 0.750 0.750 0.750 0.750 0.750 5,25

(Reference amount)

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

Heading of multiannual financial framework 2028

-2034 4 ‘Administrative expenditure’39

DG: EMPL Year Year Year Year Year Year Year TOTAL

MFF

2028-2034 2028 2029 2030 2031 2032 2033 2034

 Human resources 0,299 0,299 0,299 0,299 0,299 0,299 0,299 2,093

 Other administrative expenditure, Budget line 20.020602 0, 164 0, 164 0.164 0,164 0,164 0,164 0,164 1,148

TOTAL DG

EMPLAppropriations 0,463 0,463 0,463 0,463 0,463 0,463 0,463 3,241

DG: EMPL Year Year Year Year Year Year Year

TOTAL

MFF

2028-2034

 Other administrative expenditure 0 0 0 0 0 0 0 0

39 The necessary appropriations should be determined using the annual average cost figures available on the appropriate BUDGpedia webpage.

EN 14 EN

TOTAL appropriations under HEADING 4 of

the multiannual financial framework

(Total

commitments =

Total payments) 0,463 0,463 0,463 0,463 0,463 0,463 0,463 3,241

EUR million (to three decimal places)

Year Year Year Year Year Year Year TOTAL

MFF 2028-

2034 2028 2029 2030 2031 2032 2033 2034

TOTAL

appropriations under

HEADINGS 1 to 4

Commitments 1,213 1,213 1,213 1,213 1,213 1,213 1,213 8,491

of the multiannual

financial framework Payments 1,213 1,213 1,213 1,213 1,213 1,213 1,213 8,491

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative purposes only and does not pre-judge the next

Multiannual Financial Framework. The source of financing and scope of Union financial commitment in the post-2027 period remain subject to

the outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined through the annual budgetary procedure.

All appropriations and staffing allocations as of 2028 are indicative.

3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)

Indicate

objectives and

outputs

Year 2028

Year 2029

Year 2030

Year 2031

Enter as many years as necessary to show the

duration of the impact (see Section1.6) TOTAL

OUTPUTS

EN 15 EN

 Type 40

Aver

age

cost

N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost N o

Cost Total

No

Total

cost

SPECIFIC OBJECTIVE No 1,2 and

3 41

…

- Output Consult

ant

1 0.750 1 0.750 1 0.750 1 0.750 1 0.750 1 0.750 1 0.750 7 5.25

- Output

- Output

Subtotal for specific objective No 1

SPECIFIC OBJECTIVE No 2 …

- Output

Subtotal for specific objective

TOTALS 7 5.25

40 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 41 As described in Section 1.3.2. ‘Specific objective(s)’

EN 16 EN

3.2.3. Summary of estimated impact on administrative appropriations

(2)  The proposal/initiative does not require the use of appropriations of an

administrative nature

The proposal/initiative requires the use of appropriations of an administrative nature, as

explained below

3.2.3.3. Total appropriations

VOTED APPROPRIATIONS Year Year Year Year Year Year Year TOTAL

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

Human resources 0.299 0.299 0.299 0.299 0.2990.2990.299 2,093

Other administrative expenditure 0.164 0.164 0.164 0.164 0.1640.1640.164 1.148

Subtotal HEADING 4 0.463 0.463 0.463 0.463 0.463 0.463 0.463 3,241

Outside HEADING 4

Human resources 0.000 0.000 0.000 0.000 0.0000.0000.000 0,000

Other expenditure of an administrative

nature 0.000 0.000 0.000 0.000 0.0000.0000.000 0.000

Subtotal outside HEADING 4 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000

TOTAL 0. 463 0. 463 0. 463 0. 463 0. 463 0. 463 0. 463 3,241

===================================================================

The estimated impact on expenditure and staffing for 2028 and beyond is added for illustrative

purposes only and does not pre-judge the next Multiannual Financial Framework. The source of

financing and scope of Union financial commitment in the post-2027 period remain subject to the

outcome of interinstitutional negotiations on the MFF 2028-2034 and thereafter shall be determined

through the annual budgetary procedure. All appropriations and staffing allocations as of 2028 are

indicative.

3.2.4. Estimated requirements of human resources

(1)  The proposal/initiative does not require the use of human resources

(2)  The proposal/initiative requires the use of human resources, as explained

below

3.2.4.1. Financed from voted budget

VOTED APPROPRIATIONS Year Year Year Year Year Year Year

2028 2029 2030 2031 2032 2033 2034

 Establishment plan posts (officials and temporary staff)

20 01 02 01 (Headquarters and

Commission’s Representation Offices)

1 1 1 1 1 1 1

EN 17 EN

20 01 02 03 (EU Delegations) 0 0 0 0 0 0 0

(Indirect research) 0 0 0 0 0 0 0

(Direct research) 0 0 0 0 0 0 0

Other budget lines (specify) 0 0 0 0 0 0 0

• External staff (in FTEs)

20 02 01 (AC, END from the ‘global envelope’)

1 1 1 1 1 1 1

20 02 03 (AC, AL, END and JPD in the EU Delegations)

0 0 0 0 0 0 0

Admin. Support line

• at

Headquarter s

0 0 0 0 0 0 0

[XX.01.YY.YY] • in EU

Delegations 0 0 0 0 0 0 0

(AC, END - Indirect research) 0 0 0 0 0 0 0

(AC, END - Direct research) 0 0 0 0 0 0 0

Other budget lines - Heading 4 0 0 0 0 0 0 0

Other budget lines - 07.200301 - Outside Heading 4

0 0 0 0 0 0 0

TOTAL 2 2 2 2 2 2 2

The human resources required will be met by staff from the DG who are already assigned to

management of the action and/or have been redeployed within the DG, together if necessary, with

any additional allocation which may be granted to the managing DG under the annual allocation

procedure and in the light of budgetary constraints.

The staff required to implement the proposal (in FTEs):

To be covered by

current staff

available in the

Commission

services

Exceptional additional staff*

To be financed

under Heading 7

or Research

To be financed

from BA line

To be financed

from fees

Establishment

plan posts

1 N/A N/A N/A

External staff

(CA, SNEs, INT)

1 N/A N/A N/A

Description of tasks to be carried out by:

EN 18 EN

Officials and temporary staff 1 AD will support the negotiation, prepare the implementing acts, organise meeting

with Member States.

External staff 1 external staff will support the official in charge

3.2.5. Overview of estimated impact on digital technology-related investments

There are no digital and IT costs under Heading 4.

TOTAL Digital

and IT

appropriations

Year Year Year Year Year Year Year TOTAL

MFF

2028 -

2034 2028 2029 2030 2031 2032 2033 2034

HEADING 4

IT expenditure (corporate)

0 0 0 0 0 0 0 0

Subtotal

HEADING 4 0 0 0 0 0 0 0 0

Outside HEADING 4

Policy IT expenditure on operational programmes

0 0 0 0 0 0 0 0

Subtotal outside

HEADING 4 0 0 0 0 0 0 0 0

TOTAL 0 0 0 0 0 0 0 0

3.2.6. Compatibility with the current multiannual financial framework

The proposal/initiative:

(9)  can be fully financed through redeployment within the relevant heading of the

multiannual financial framework (MFF)

.

The estimated impact on expenditure and staffing for 2028 and beyond is added for

illustrative purposes only and does not pre-judge the next Multiannual Financial

Framework. The source of financing and scope of Union financial commitment in the

post-2027 period remain subject to the outcome of interinstitutional negotiations on

the MFF 2028-2034 and thereafter shall be determined through the annual budgetary

procedure. All appropriations and staffing allocations as of 2028 are indicative.

(10)  requires use of the unallocated margin under the relevant heading of the MFF

and/or use of the special instruments as defined in the MFF Regulation

(11)  requires a revision of the MFF

EN 19 EN

3.2.7. Third-party contributions

The proposal/initiative:

(12)  does not provide for co-financing by third parties

(13)  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year Year Year Year Year Year Year

Total 2028 2029 2030 2031 2032 2033 2034

Specify the co-

financing body p.m. p.m. p.m. p.m p.m. p.m. p.m. p.m

TOTAL

appropriations

co-financed

3.3. Estimated impact on revenue

(14)  The proposal/initiative has no financial impact on revenue.

(15)  The proposal/initiative has the following financial impact:

 on own resources

 on other revenue

 please indicate, if the revenue is assigned to expenditure lines

4. DIGITAL DIMENSIONS

4.1. Requirements of digital relevance

EN 1 EN

Reference to

the

requirement

Requirement description

Actors affected or

concerned by the

requirement

High-level

Processes Categories

R1

Article 6

Persons concerned and, where applicable,

employers, shall be able to submit requests for

social security documents falling within the scope

of this Regulation fully online using procedures

that comply with Regulation (EU) 2018/1724. The

online request procedure shall be user-friendly,

accessible and comply with the following

requirements:

(a) It shall enable the electronic identification

and authentication of the person

concerned and, where applicable, the

employer;

(b) It shall allow for the electronic provision

of the information, documents or

supporting evidence, referred to in Article

3(2) of Regulation (EC) No 987/2009,

necessary to process the request;

(c) It shall ensure that the final submission of

the request can be completed remotely;

(d) It shall provide the person concerned and,

where applicable, the employer with an

automatic acknowledgement of receipt

after the completed submission has been

• Issuers of social

security documents

• Holders of social

security documents

and applicants

Request social

security

documents

• Data

• Process digitalisation

and automation

• Digital public service(s)

EN 2 EN

completed, unless the document is issued

immediately;

(e) It shall notify the person concerned and,

where applicable, the employer,

electronically that the issuing procedure

has been completed.

R2

Article 7(1)

The competent institutions shall issue digital social

security documents in a format suitable for use in

the European Digital Identity wallet of the person

concerned, and where relevant, of the employer.

The digital social security documents shall comply

with the technical specifications adopted pursuant

to paragraph 11.

• Issuers of social

security documents

• Holders of social

security documents

and applicants

Issue digital

social security

documents

• Data

• Process digitalisation

and automation

• Digital solutions

• Digital public Service(s)

R3

Article 7(2)

By way of derogation from paragraph 1, the

competent institutions shall, at the request of the

person concerned or the employer, issue the social

security document in a standardised and accessible

physical format. Such a document shall include a

QR code or any other electronic features to

enhance its security, in accordance with the

technical specifications adopted pursuant to

paragraph 11.

• Issuers of social

security documents

• Holders of social

security documents

and applicants

Issue physical

documents

enhanced with

digital features

• Data

• Process digitalisation

and automation

• Digital solutions

• Digital Public Service(s)

R4

Article 7(3)

Each Member State shall communicate to the

Commission a list of issuers and shall keep that list

• Member States

Issue of social

security

• Data

• Process digitalisation

and automation

EN 3 EN

up to date. The Commission shall make those lists

available to the public through a secure channel

and in an electronically signed or sealed form

suitable for automated processing. With regard to

issuers of the portable document A1, the list shall

be communicated to the Commission by [date of

entry into force plus 12 months]. Member States

shall communicate the list of issuers of EHIC and

other social security documents falling within the

scope of this Chapter by [date of entry into force

plus 3 years].

documents • Digital solutions

• Digital Public Service(s)

R5

Article 7(4)

Before issuing a social security document, the

issuers shall verify the accuracy of the information

provided by the persons concerned and, where

applicable, by the employers in support of their

request, including by means of digital tools.

• Member States

Verify

information

before issuing

social security

documents

• Data

• Process digitalisation

and automation

• Digital solutions

R6

Article 7(5)

Where a social security document referred to in

paragraph 1 or 2 is revoked, the issuer shall

immediately notify the person concerned and,

where applicable, the employer, by electronic

means, except if other means are indicated by the

person concerned and, where applicable, the

employer.

• Issuer

• Holders of social

security documents

and applicants

Inform on

issuance and

revocation of

social security

documents

• Data

• Process digitalisation

and automation

• Digital solutions

• Digital Public Service(s)

R7

Article 7(6)

The issuers shall ensure that a person is able to

receive and store, within their own European • Member States Issue digital

social security

• Data

• Digital Public Service(s)

EN 4 EN

Digital Identity wallet, the digital social security

documents of their minor children and of a natural

person whom they legally represent.

documents of

legally

represented

persons

R8

Article 7(7)

Social security documents issued under paragraph

1 and 2 by one Member State shall be recognised

by verifiers in all other Member States.

• Member States

• Verifiers of social

security attestations

• Holders of social

security documents

Recognise social

security

documents

• Data

• Digital solutions

• Digital Public Service(s)

R9

Article 7(8)

Member States shall ensure that verifiers

established on their territory are equipped with the

necessary technical means to verify the social

security documents issued under this Article, in

order to confirm their authenticity, integrity and

validity. Verifiers shall be able to verify that:

(a) the document was issued by an authorised

institution;

(b) the data contained in the document has not

been tampered with since issuance;

(c) the document has not expired or been

revoked.

• Member States

• Verifiers

• Holders of social

security documents

Verify social

security

documents

• Data

• Process digitalisation

and automation

• Digital solutions

• Digital Public Service(s)

R10

Article 9(2)

From [date of entry into force plus 3 years],

Member States shall ensure that healthcare

providers on their territory are able to

electronically transmit the data contained in the

European Health Insurance Card of a patient from

another Member State, and all the data that need to

• Member States

• Healthcare

providers

• Insured persons

receiving treatment

Transmit data

for the

reimbursement

of costs under

the EU social

security

coordination

• Data

• Process digitalisation

and automation

• Digital solutions

• Digital Public Service(s)

EN 5 EN

be transmitted for the reimbursement process, to

the competent institutions of the Member State of

treatment.

rules

R11

Article 8

Competent institutions shall issue social security

documents to the person concerned and, where

applicable, the employer in compliance with the

deadlines established in accordance with paragraph

2.

• Issuers of social

security documents

• Holders of social

security documents

and applicants

Issue social

security

documents • Digital Public Service(s)

R12

Article 10(2)

The Commission shall establish, by means of

implementing acts, a common technical framework

to ensure interoperability between national portals

used to request the portable document A1 and the

public interfaces connected to the Internal Market

Information System for the declaration of posting

of workers and for the posting of drivers in road

transport, as provided for in Article 1(11) of

Directive (EU) 2020/1057. That technical

framework shall enable the reuse of relevant

submitted data across the procedures for the

request of the portable document A1 and the

submission of posting declarations, in compliance

with Regulations (EU) 2016/679 and (EU)

2018/1725 and the once-only principle.

• Commission

• Member States

• Portable document

A1 applicants

Requests for

portable

document A1

• Data

• Digital solutions

• Digital Public Service(s)

R14

Article 14(1)

Member States shall collect and transmit to the

Commission data on the implementation of

• Member States

• Commission Report • Data

EN 6 EN

Article 8(1) and Article 11(2).

R15 – Article

11(1)-(2)

Member States shall exchange, access and process

the data required to apply Regulations (EC) No

883/2004 and (EC) No 987/2009 via the Electronic

Exchange of Social Security Information (EESSI)

system, in accordance with its functional and

technical specifications laid down pursuant to

Article 78 of Regulation (EC) No 987/2009. When

exchanging data via the EESSI system, Member

States shall comply with the maximum time

periods laid down in Annex I of this Regulation.

Member States

Cross-border

information

exchange

Data

Process digitalisation and

automation

Digital Public Service

R16 - Article

7(10)

Interoperability of ESSPASS with EESSI and

other initiatives Interoperability Digital Public Services

4.2. Data

High-level description of the data in scope

Type of data Reference to the

requirement(s)

Standard and/or specification (if applicable)

EN 7 EN

Personal and non-personal data contained in

the digital social security documents

R2

R7

R8

R9

R10

As provided for in Article 7(11), data specifications for digital

social security documents will be defined through implementing

acts, in accordance with the examination procedure referred to in

Article 5 of Regulation (EU) No 182/2011. These specifications

will comply with the common standards, schemas, formats and

technical specifications established under the European Digital

Identity (EUDI) framework. They will also draw upon the work

undertaken during the ESSPASS pilot projects and the

recommendations of the Ad hoc group of the Administrative

Commission on ESSPASS.

Personal and non-personal data contained in

the physical social security documents

enhanced with digital features

R3

R8

R9

R10

As provided for in Article 7(11), data specifications for the

enhanced physical social security documents will be defined

through implementing acts, in accordance with the examination

procedure referred to in Article 5 of Regulation (EU)

No 182/2011. These specifications will also draw upon the work

undertaken during the ESSPASS pilot projects and the

recommendations of the Ad hoc group of the Administrative

Commission on ESSPASS.

Personal Identification Data (PID) attributes

held in the EUDI wallet

R2

R7

R8

R9

R10

The disclosure of PID attributes to the verifier will be performed

through EUDI wallet presentation protocols defined under the

EUDI framework.

Personal identification data or identifier and

other data required to request social security

R1 The identification and authentication in national portals and the

exchange of information for requesting social security documents

EN 8 EN

documents online R5 will follow the specifications and protocols used in the Member

States.

Data about issuers of social security

documents

R4 Issuers registration in the trust lists will follow the specifications

and protocols defined under the EUDI framework

Data regarding the implementation

of Article 8(1) and Article 11(2)

R13 The format and structure for the reporting obligation will be

defined through implementing acts, in accordance with the

examination procedure referred to in Article 11(2) of Regulation

(EU) No 182/2011.

Data required to apply Regulations (EC) No

883/2004 and (EC) No 987/2009, exchanged

between competent institutions – personal and

non-personal data

R15 Exchanges take place via the EESSI system in accordance with its

functional and technical specifications laid down pursuant to

Article 78 of Regulation (EC) No 987/2009.

Alignment with the European Data Strategy

The requirements are consistent with the objectives of the European data strategy. They facilitate secure access and interoperable exchange of

standardised data among relevant stakeholders across borders.

The requirements comply with the rights to privacy and data protection guaranteed in the Charter of Fundamental Rights of the European Union,

the Treaty on the Functioning of the European Union, the General Data Protection Regulation and the EU Data Protection Regulation.

No open data is processed under these requirements. The reporting obligation set out in Article 14 generates data exclusively for monitoring purposes,

without mandating the reuse of the reported information.

Alignment with the once-only principle

The requirements adhere to the once-only principle: social security documents, regardless of format, are issued once by national authorities, enabling

individuals and businesses to securely reuse them digitally without resubmitting the same data. These documents are verified cross-border after consent

is obtained.

EN 9 EN

Article 10(2) and (3) aim to implement the once-only principle to reduce administrative burdens and eliminate redundant data submissions when

requesting portable document A1.

High-level description of the data flows

Type of data Reference(s) to the

requirement(s)

Actors who

provide the data

Actors who

receive the data

Trigger for the data

exchange

Frequency (if

applicable)

Personal and non-personal data

contained in the digital social

security documents

R2

R7

Issuers Holders of

documents and

applicants

Issuance of digital

social security

documents

Personal and non-personal data

contained in the physical social

security documents enhanced

with digital features

R3 Issuers Holders of

documents and

applicants

Issuance of physical

social security

documents enhanced

with digital features

Personal Identification Data

(PID) attributes held in the

EUDI wallet

R9 Holders of

documents

Verifiers Request from the

verifiers and explicit

authorisation from the

holders

Personal and non-personal data

contained in the digital social

security documents

R9 Holders of

documents

Verifiers Request from the

verifiers and explicit

authorisation from the

holders

Personal and non-personal data

contained in the physical social

security documents enhanced

with digital features

R9 Holders of

documents

Verifiers Request from the

verifiers and holders’

presentation of the

physical documents

EN 10 EN

Personal identification data or

identifier and other data

required to request social

security documents online

R1 Applicants National portals

for requesting

social security

documents

Application for the

issuance of social

security documents

Data about issuers of social

security documents

R4 Issuers Commission Communication to

the Commission of

the trust lists of

issuers, any

subsequent update

Personal Identification Data

(PID) attributes held in the

EUDI wallet

R10 Verifiers of EHIC Authorities in

the Member

States of

treatment

Transfer of data for

reimbursement

processing

Personal and non-personal data

contained in the digital social

security documents

R10 Verifiers of EHIC Authorities in

the Member

States of

treatment

Transfer of data for

reimbursement

processing

Personal and non-personal data

contained in the physical social

security documents enhanced

with digital features

R10 Verifiers of EHIC Authorities in

the Member

States of

treatment

Transfer of data for

reimbursement

processing

Data regarding the

implementation of Article 8(1)

and Article 11(2)

R13 Member States Commission Reporting obligation

Data required to apply

Regulations (EC) No 883/2004 R15 Member States Member States

Need basis and within

the maximum time N/A

EN 11 EN

and (EC) No 987/2009 periods laid down in

Annex I

4.3. Digital solutions

High-level description of digital solutions

Digital solution

Reference(s)

to the

requirement(s)

Main mandated

functionalities

Responsible

body

How is accessibility

catered for?

How is reusability

considered?

Use of AI

technologies

(if applicable)

ESSPASS

issuing

infrastructure

R2

R3

Issuance,

management and

revocation of

digital social

security

documents and

physical social

security

documents

enhanced with

digital features

Member State

competent

authorities

For the digital social

security documents,

accessibility is addressed

through the Member

States’ implementation of

the EUDI wallets

(Article 5a(21) of

Regulation (EU)No

910/2014). For physical

documents, accessibility

requirements will be

defined in the technical

specifications to be

adopted through

implementing act, in

accordance with

For the digital social

security documents,

the solution is based

on the EUDI

framework and reuses

its core components,

such as the EUDI

trust framework, the

EUDI wallet, the PID

issuance

infrastructure, trust

registries and lists,

interoperability

specifications.

The EUDI trust

N/A

EN 12 EN

Article 7(11).

framework is also

being considered for

reuse in relation to

physical social

security documents.

ESSPASS

verifier

application/s

R8

R9

Verification of

digital social

security

documents and

physical social

security

documents

enhanced with

digital features

Member State

competent

authorities

The accessibility

requirements of the

verifiers’ application/s

interacting will be defined

through implementing

acts, in accordance with

Article 7(11).

As one of the

implementation

options, the

Commission may

provide a reference

implementation of the

application for reuse

and configuration by

Member States on a

voluntary basis. This

will be discussed with

Member States prior

to the implementation

phase. Details of the

verification

application will be

defined through

implementing acts, in

accordance with

Article 7(11).

As investments and

adaptations for

healthcare digital

systems are already

EN 13 EN

provided for under

the European health

data space, these

should be leveraged

to create synergies

that maximise their

impact and efficiency.

Online portals

for requesting

social security

documents

R1 Request of social

security

documents

Member State

competent

authorities

Responsibility for ensuring

the accessibility of

national portals rests with

the Member States.

Article 6(1) provides that

online request procedure

shall be accessible

Depending on a

Member State’s

digital landscape and

organisational

structure, existing

portals could be

updated to include

online requests for

additional social

security documents.

Alignment of the digital solution with applicable digital policies and legislative enactments

ESSPASS issuing infrastructure

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act No use of AI is foreseen in the proposed Regulation.

EU Cybersecurity framework All security aspects of the issuing infrastructure, including the security

requirements for issuers of digital social security documents, the EUDI wallet

EN 14 EN

security features and the communication protocols between issuer and wallet, are

covered by the EUDI framework Regulation. The same security requirements for

the issuance of digital social security documents will also apply to the physical

documents enhanced with digital security features. They will be further detailed in

the technical specifications.

eIDAS The solution is based on the EUDI framework and reuses its core components. The

EUDI trust framework is also being considered for reuse in relation to physical

social security documents. These documents will include eIDAS-compliant

electronic signatures, providing the same level of assurance as digital social

security documents.

Single Digital Gateway and IMI The solution is built on the foundations established by the Single Digital Gateway

Regulation (SDGR), which mandates that Member States enable fully online access

to administrative procedures, such as A1 portable document requests, EHIC

applications, and pension claims, while ensuring the electronic issuance of outputs.

The solution standardises the format of these outputs to facilitate cross-border

verification and further extends digitalisation to all social security documents

within the scope of the proposed Regulation.

Others

Verifier application

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act No use of AI is foreseen in the proposed Regulation.

EN 15 EN

EU Cybersecurity framework All security aspects of the verifier application, including the verification protocols,

will be compliant with the cybersecurity requirements defined under the EUDI

framework. They will be further detailed in the technical specifications.

eIDAS The verification of digital social security documents will comply with EUDI

protocols and standards, which are defined to support the implementation of eIDAS.

The physical documents enhanced with digital features will include eIDAS-

compliant electronic signatures, verifiable via the same verifier application.

Single Digital Gateway and IMI Interoperability with IMI.

Others

Portals to request ESSPASS attestations

Digital and/or sectorial policy (when these are

applicable)

Explanation on how it aligns

AI Act No use of AI is foreseen in the proposed Regulation.

EU Cybersecurity framework The proposed Regulation does not impose any additional cybersecurity

requirements.

eIDAS Portals should support login based on the Personal Information Data (PID)

presentation from the EUDI wallet.

Single Digital Gateway and IMI The Your Europe portal will serve as a possible single-entry point for applicants to

request the social security documents covered under the Single Digital Gateway

Regulation, redirecting them to the national portals for document requests.

Article 10 of the proposed Regulation (R13) address interoperability between

EN 16 EN

national portals for requesting the portable document A1 and the public interfaces

connected to the Internal Market Information System for the declaration of posting

of workers, currently under negotiations, and for the posting of drivers in road

transport.

Others

4.4. Interoperability assessment

High-level description of the digital public service(s) affected by the requirements

Digital public

service or category

of digital public

services

Description Reference(s) to the

requirement(s)

Interoperable

Europe Solution(s)

(NOT

APPLICABLE)

Other interoperability solution(s)

ESSPASS –

Request, issuance

and revocation of

social security

documents

This service, provided by

competent authorities in Member

States, enables applicants to

request and receive social security

documents either in a digital

format for use in the EUDI wallet

or as a physical document

enhanced by digital features.

R2

R3

R7

R13

// EUDI framework and wallet

ESSPASS -

Verification of social

This service, provided by

verifiers, enables holders of social

security documents to have their

R8

R9

EUDI framework and wallet

EN 17 EN

security documents documents instantly verified and

validated through digital means

(i.e. the verifier application).

For digital social security

documents, the service also allows

holders to confirm whether the

verifier is authorised to request

and verify the document.

Impact of the requirement(s) as per digital public service on cross-border interoperability

Request, issuance and revocation of social security documents

Assessment Measure(s) Potential remaining barriers (if applicable)

Alignment with existing digital and

sectorial policies

Please list the applicable digital and

sectorial policies identified

- Adoption of technologies and standards

set out under the EUDI Regulation

- Use of digital signatures in compliance

with the eIDAS Regulation (for physical

social security documents enhanced with

digital features)

- Compliance with GDPR

- Synergies with processes related to

EESSI (R 15)

Organisational measures for a

smooth cross-border digital public

services delivery

- Establishment of a modern and efficient

governance structure, comprising a

Committee under Regulation (EU)

No 182/2011 to support the Commission

EN 18 EN

Please list the governance measures

foreseen

in adopting implementing acts and an

Advisory Group on Digitalisation in

Social Security Coordination to provide

technical advice, operational support and

a community of practice for exchanging

experiences and knowledge.

- Registration of trusted issuers within the

trust framework and notification of the

corresponding trust lists to the

Commission.

- Mutual recognition of social security

documents

Measures taken to ensure a shared

understanding of the data

Please list such measures

- Shared specifications adopted through

implementing acts, in accordance with

the examination procedure referred to in

Article 5 of Regulation (EU)

No 182/2011.

- Advisory Group providing expertise to

the Commission in the early preparation

of implementing acts before submitting to

the Committee.

Use of commonly agreed open

technical specifications and

standards

Please list such measures

- Adoption of technical specifications for

digital social security documents as

provided for in Article 7(1)

- Adoption of technical specifications for

physical social security documents

enhanced with digital features as

provided for in Article 7(2)

Potentially high impact for authorities with lower

levels of technological maturity

Verification of social security documents

EN 19 EN

Assessment Measure(s) Potential remaining barriers (if applicable)

Alignment with existing digital and

sectorial policies

Please list the applicable digital and

sectorial policies identified

- Adoption of technologies and standards

set out under the EUDI Regulation

- Use of digital signatures in compliance

with the eIDAS Regulation (for physical

social security documents enhanced with

digital features)

- Synergies with e-Health initiatives using

the EUDI wallets

Organisational measures for a

smooth cross-border digital public

services delivery

Please list the governance measures

foreseen

- Establishment of a modern and efficient

governance structure, comprising a

Committee under Regulation (EU)

No 182/2011 to support the Commission

in adopting implementing acts and an

Advisory Group on Digitalisation in

Social Security Coordination to provide

technical advice, operational support and

a community of practice for exchanging

experiences and knowledge.

- Registration of authorised verifiers in

accordance with the EUDI trust

framework.

Measures taken to ensure a shared

understanding of the data

Please list such measures

- Shared specifications adopted through

implementing acts, in accordance with

the examination procedure referred to in

Article 5of Regulation (EU)

No 182/2011.

- Advisory Group providing expertise to

the Commission in the early preparation

of implementing acts before submitting to

EN 20 EN

the Committee.

Use of commonly agreed open

technical specifications and

standards

Please list such measures

- Adoption of technical specifications for

verification of social security documents,

regardless of format, as provided for in

Article 7(11)

4.5. Measures to support digital implementation

High-level description of measures supporting digital implementation

Description of the measure

Reference(s) to the

requirement(s)

Commission

role

(if applicable)

Actors to be

involved

(if42 applicable)

Expected timeline

(if applicable)

Adoption of implementing acts on the

functional, operational and technical

specifications, as provided for in

Article 7(1) (2) (11).

R2

R3

R7

R8

R9

Preparing and

adopting the

implementing

acts

Commission,

Committee

composed of

representatives

of Member

States

42

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 COM(2026) 980 final

ANNEX

ANNEX

to the

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC) No

883/2004, (EC) No 987/2009 and (EU) No 2018/1724

{SEC(2026) 980 final} - {SWD(2026) 981 final} - {SWD(2026) 982 final} - {SWD(2026) 983 final}

EN 1

Maximum time periods for exchanges through the Electronic Exchange of Social Security

Information (EESSI) system

Sector Category of exchange SED pairs as defined in the EESSI

Common Data Model1

(request – reply)

Response

time

(weeks)

Horizontal and

Miscellaneous

Ad-hoc Exchange of Information H001 - H002 6

Determine Residence H005 - H006 6

Exchange of Personal Identification Numbers H061 - H062 6

Exchange of Information concerning the amount of

income for special non-contributory cash benefits

M050 - M051 4

Exchange of information special non-contributory

cash benefits – information concerning periods of

employment / self-employment / residence completed

in another MS(s)

M052 - M053 4

Accidents at Work

and Occupational

Disease

Certification right benefits in Kind – Member State of

stay/residence requests confirmation of rights

DA001 - DA002 6

Establishing the reimbursement rates DA004 - DA005 6

Family Benefits Determine Competence F001 - F002

F022 - F023

F026 - F027

6

Legislation

Applicable

Determination of legislation applicable A005 - A006 4

Request for Exceptions A001 - A002/A011 6

Request for more information A005 - A006 6

Pension Old Age Pension Claim P2000 - P6000 26

Survivors Pension Claim P2100 - P6000 26

Invalidity Pension Claim P2200 - P6000 26

Recovery Offsetting of Overpayment of Benefits R001 - R002 26

Offsetting of Overpayment with arrears R005 - R006 26

Request for Additional Information R012 - R014 26

Request for Notification under Art. 77 R015 - R016 17

Request for Recovery R017 - R018 26

Sickness Entitlement - Residence outside Competent Member

State without PD

S071 - S072 6

Entitlement - Residence outside Competent Member

State without PD - Entitlement document issued by

Competent State

S072 - S073 6

Cancellation of entitlement document S016 - S017 6

Cancellation of registration S018 - S019 6

Necessary Treatment in Member State of Stay -

Request for Entitlement Document

S044 - S045 3

Necessary or Scheduled Treatment - Reimbursement

Rates

S067 - S068 6

Aggregation of Periods - Insurance Risk Type:

Sickness, Paternity and Maternity

S040 - S041 4

Unemployment

Benefits

Exchange of information to determine a claim for UB U001 - U002

U003 - U004

U005 - U006

U001CB - U017

6

1 EESSI’s Common Data Model (CDM) assures a common understanding of and standardises data

exchange and business scenarios under Regulations (EC) No 883/2004 and 987/2009, defining activities,

structured electronic documents (SEDs), and cross-border collaborations to resolve business scenarios

outlined in the Regulations.

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 981 final

COMMISSION STAFF WORKING DOCUMENT

Subsidiarity Grid

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE

COUNCIL

on digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC) No

883/2004, (EC) No 987/2009 and (EU) 2018/1724

{COM(2026) 980 final} - {SEC(2026) 980 final} - {SWD(2026) 982 final} -

{SWD(2026) 983 final}

1

Subsidiarity Grid

1. Can the Union act? What is the legal basis and competence of the Unions’ intended action?

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative?

The proposal is based on Article 48 TFEU which empowers the Union to adopt measures to coordinate Member States’ social security systems in order to facilitate the free movement of workers and ensure the protection of their social security rights across the Union. The proposal establishes a framework for the digitalisation of cross-border social security procedures and exchanges necessary for the implementation and enforcement of the EU social security coordination rules. While Article 48 TFEU applies to employed and self-employed migrant workers and their dependants, Regulation (EC) No 883/2004 (based both on what are now Articles 48 and 352 TFEU) extends social security coordination to inactive citizens moving within the Union. This Article provides a solid legal basis for adopting measures to digitalise cross-border social security procedures to facilitate the access to social security benefits, and fair mobility within the EU.

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in nature?

In the area of social security coordination, the Union's competence is shared between the Union and the Member States pursuant to Article 4 TFEU.

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in Article 3 TFEU1. It is the specific legal basis which determines whether the proposal falls under the subsidiarity control mechanism. Article 4 TFEU2 sets out the areas where competence is shared between the Union and the Member States. Article 6 TFEU3 sets out the areas for which the Unions has competence only to support the actions of the Member States.

2. Subsidiarity Principle: Why should the EU act?

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 24: - Has there been a wide consultation before proposing the act? - Is there a detailed statement with qualitative and, where possible, quantitative indicators

allowing an appraisal of whether the action can best be achieved at Union level?

The proposal was prepared following extensive consultation activities and practical testing, beginning with the ESSPASS pilot phase. The pilot tested the feasibility of digitally issuing, storing, presenting and verifying social security documents across borders, focusing on documents such as the Portable Document A1 and the European Health Insurance Card. They involved national social security authorities, technical experts and other stakeholders and therefore provided early operational evidence on user needs, cross-border verification, interoperability, data protection and the integration of ESSPASS with the European Digital Identity framework. The experience gained

1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN 2 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN 3 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML 4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN

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through this pilot helped identify both the potential benefits of ESSPASS and the legal, technical and practical conditions necessary for its effective implementation. The following targeted consultations in the context of the Fair Labour Mobility Package, a call for evidence on ESSPASS (14 January–11 February 2026) alongside a Call for Evidence on the Fair Labour Mobility Package, an open public consultation (22 January to 16 April 2026), validation workshops, surveys, stakeholder interviews and dedicated meetings with Member States, social partners and other relevant stakeholders. The consultations demonstrated broad support for further digitalisation of social security coordination and for the ESSPASS initiative as a means to simplify cross-border procedures, reduce administrative burdens and fraud, and facilitate access to social security rights. This conclusion is supported by a wide-ranging evidence-gathering exercise, including two surveys that received 87 responses from 32 countries, 97 stakeholder interviews, two validation workshops involving respectively 62 and 44 participants, and dedicated exchanges with Member States, social partners, national authorities, healthcare providers, enforcement authorities, technical experts and participants in the ESSPASS pilots. The public consultation and calls for evidence reinforced these findings: 93% of respondents to the public consultation supported a standardised solution for the digitalisation of portable documents and the European Health Insurance Card. Stakeholders (including trade unions, employers and public authorities) also emphasised the importance of effective enforcement, interoperability, real-time verification, the availability of alternative solutions for persons unable or unwilling to use digital tools, and robust data protection and security safeguards. The impact assessment contains a dedicated section on the legal basis and the principle of subsidiarity, setting out qualitative and quantitative evidence demonstrating the scale of the expected benefits of a common Union solution. Under the preferred option, verification times are expected to fall from the current 5–16 minutes for a Portable Document A1 and 2–5 minutes for an EHIC to only a few seconds for documents stored in an EUDI Wallet and approximately one minute for enhanced physical documents. Over a 12-year period, the resulting savings are estimated at EUR 24–72 million for verifiers, EUR 21–64 million for businesses in relation to Portable Document A1 procedures, and EUR 23–69 million for healthcare providers in relation to EHIC verification. Enhanced document security could also generate savings from reduced fraud of up to EUR 157 million for the Portable Document A1 and EUR 120 million for the EHIC. These benefits depend on documents being issued and verified on the basis of common rules and technical requirements across all Member States and could therefore not be achieved to the same extent through uncoordinated national action. The explanatory memorandum likewise includes a specific justification of the proposal's compliance with the principle of subsidiarity.

2.2 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the conformity with the principle of subsidiarity?

The explanatory memorandum and the impact assessment accompanying the Commission’s proposal contain a detailed justification regarding compliance with the principle of subsidiarity and address this issue in the context of the policy options analysed.

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The free movement of people and freedom to provide services are fundamental freedoms of the European Union. To fully benefit from these freedoms, individuals and businesses must rely on efficient public services, including when accessing social security benefits or sending employees to work abroad. Ensuring seamless cross-border verification of social security rights and insurance status requires coordinated action, as Member States cannot overcome these challenges alone. Digital solutions implemented by a single Member State will not ensure cross-border interoperability and recognition and verification of social security documents.

An action at the EU level will improve proof and verification of social security rights and insurance status, thus the access to benefits and healthcare, establishing a more supporting environment for workers who are relocating or considering relocation within the EU. Given the cross-border nature of the existing problems, effective solutions are best pursued at the EU level, rather than through individual or regional efforts by Member States. Action at the EU level will benefit mobile individuals by making their social security rights more transparent and accessible, reducing fraudulent and exploitative practices. It will assist businesses operating cross-border by reducing unnecessary administrative difficulties and complexities, while supporting national authorities by simplifying processes and strengthening cross-border cooperation. This will enhance legal certainty, the understanding and implementation of rules, facilitate their enforcement while fostering trust in the EU’s social security coordination framework and Europe’s single market.

The impact assessment also concludes that Union action would maximise the benefits of existing Union investments and ensure coherence with other digital initiatives, including the Single Digital Gateway Regulation, the Once-Only Technical System, the European Digital Identity framework, the Interoperable Europe Act, the Electronic Exchange of Social Security Information and the European Health Data Space. In the absence of Union action, national approaches would likely result in fragmented and incompatible solutions that would be more costly and difficult to reverse at a later stage.

2.3 Based on the answers to the questions below, can the objectives of the proposed action be achieved sufficiently by the Member States acting alone (necessity for EU action)?

The problems addressed by the proposal are cross-border in nature and affect all Member States. Their underlying causes are largely common across the Union and stem from the continued reliance on paper-based procedures, limited interoperability and insufficient standardisation of document formats and verification methods.

While Member States may digitalise their own procedures, they cannot establish on their own common standards and interoperable solutions ensuring the mutual recognition and cross-border verification of social security documents. Separate national approaches would likely lead to fragmented and incompatible systems, duplication of efforts and higher costs for individuals, businesses and public authorities.

(a) Are there significant/appreciable transnational/cross-border aspects to the problems being tackled? Have these been quantified?

The proposal addresses problems that are inherently cross-border as it aims to facilitate the application and enforcement of EU social security coordination rules for persons moving across

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borders, including workers, jobseekers, students, pensioners, posted workers and travellers requiring healthcare. The difficulties concern the request, issuance and verification of social security coordination documents used between Member States as well as the secure exchange of information between individuals, businesses and national authorities. Reliance on paper-based procedures, limited interoperability and the absence of common verification mechanisms create obstacles to the exercise of free movement, increase administrative burdens and expose cross- border situations to fraud and error. In 2024 around 5,5 million portable documents A1 certificates were issued attesting the social security position of a person in a cross-border situation and around 256 million European Health insurance cards were in circulation providing evidence of entitlement to urgent medical care during a temporary stay in another Member State. The results of the open public consultation further confirmed the scale and cross-border nature of these problems. Overall, 78% of respondents considered that the current procedures create difficulties and delays in accessing social security rights across borders, 76% identified additional administrative burdens for national authorities, healthcare providers and labour inspectorates, and 69% reported administrative burdens for businesses. Among healthcare providers, labour inspectorates and national authorities, 50% reported difficulties in verifying the social security rights and insurance status of individuals from other Member States. Furthermore, 93% of respondents supported the introduction of a standardised EU digital solution for issuing and verifying social security coordination documents, demonstrating broad recognition that common Union action is needed to address these cross-border challenges.

(b) Would national action or the absence of the EU level action conflict with core objectives of the Treaty5 or significantly damage the interests of other Member States?

The initiative supports the effective exercise of free movement which is a fundamental freedom and core objective of the single market. If Member States acted separately or if there were no EU action, individuals and businesses moving across borders would continue to face delays, burdensome paper procedures, verification difficulties and uneven enforcement. This would undermine the effective operation of EU social security coordination rules and could negatively affect persons, businesses and authorities in other Member States that depend on reliable and interoperable cross-border exchanges.

(c) To what extent do Member States have the ability or possibility to enact appropriate measures?

Member States can develop national digital tools and manage their own social security systems, but they cannot on their own create a uniform EU-wide framework guaranteeing interoperable, secure and mutually recognised cross-border exchanges for all Member States. The proposal explicitly seeks to establish common EU rules for an ESSPASS framework, support the Electronic Exchange of Social Security Information (EESSI) system and support other cross-border data exchanges between competent institutions to better prevent and combat cross-border social security fraud. This proposal is necessary to attain these objectives which cannot be sufficiently achieved individually by Member States.

(d) How does the problem and its causes (e.g. negative externalities, spill-over effects) vary across the national, regional and local levels of the EU?

5 https://europa.eu/european-union/about-eu/eu-in-brief_en

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The impact assessment demonstrated that the underlying problem is widespread and stems from fragmentation, reliance on paper-based procedures and limitations in exchanges between individuals and administrations in cross-border situations. While administrative arrangements and proof and verification tools may differ across Member States, the need for secure, standardised and interoperable cross-border exchanges of social security coordination information is common throughout the Union. The proposal is designed to address these structural cross-border problems while fully respecting the sovereignty of Member States to organise and administer their national social security systems

(e) Is the problem widespread across the EU or limited to a few Member States?

The impact assessment has shown that the problem is widespread across the EU. The proposal applies to persons falling within the scope of Regulation (EC) No 883/2004 and to all branches of social security listed in Article 3(1) of that Regulation. The impact assessment presents the issue as affecting the functioning of free movement and social security coordination across the Union as a whole and not as a problem limited to a small number of Member States.

(f) Are Member States overstretched in achieving the objectives of the planned measure?

To address the cross-border digitalisation of social security documents, the EU has already supported pilot projects on ESSPASS in Member States, focusing on the European Health Insurance Card and portable document A1. These pilots demonstrated that the core components of the European Digital Identity framework can be used for the digitalisation of procedures related to both documents, including issuance and cross-border verification, and produced concrete technical outputs such as user journeys, prototype solutions and a first draft rulebook. The initiative is designed to support a smooth transition from the ESSPASS pilot phase to full-scale implementation, while building on existing EU digital infrastructure and enhancing cross-border data exchanges between institutions. The available evidence indicates that the proposed rollout is proportionate: it is expected to generate significant savings through faster cross-border verification for authorities, businesses and healthcare actors. The impact assessment also reports positive pilot results and broader stakeholder evidence on current inefficiencies, supporting the policy relevance of the initiative.

(g) How do the views/preferred courses of action of national, regional and local authorities differ across the EU?

The consultation results indicate broad support across stakeholder groups, including national public authorities for further digitalisation of social security coordination and for the ESSPASS initiative. Public authorities generally agreed on the need to simplify cross-border procedures, strengthen interoperability, introduce secure real-time verification mechanisms and improve the implementation and enforcement of the Union social security coordination rules. There is broad support for using the European Digital Identity Wallet as the primary digital solution, while ensuring the availability of alternative solutions for persons unable or unwilling to use digital tools. Although some stakeholders expressed concerns regarding implementation costs, digital inclusion and data protection and security, these related primarily to the design and implementation of the initiative rather than to the need for action at Union level. No significant differences emerged in the preferred course of action across the public authorities that participated in the consultation.

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2.4 Based on the answer to the questions below, can the objectives of the proposed action be better achieved at Union level by reason of scale or effects of that action (EU added value)?

The objectives can be better achieved at Union level by reason of their scale and effects. The problems identified are cross-border and stem from fragmentation between national systems, and affect free movement, access to social security rights, enforcement and the functioning of the internal market. EU action offers clear added value through common standards, interoperability for the different steps going from the request, issuance and verification of social security coordination documents. It will also support better cooperation and information exchanges between national institutions while leaving Member States fully responsible for the substance of their national social security systems.

(a) Are there clear benefits from EU level action?

There are clear benefits from action at Union level as the proposal would establish common rules and procedures for the request, issuance, presentation and verification of social security documents used in cross-border situations. This would make it easier for individuals and businesses to request such documents through accessible digital procedures, irrespective of the Member State in which they are located, thereby reducing administrative burden and facilitating the exercise of free movement rights. Union action would also ensure faster access to social security documents through common digital solutions and common binding deadlines for their issuance across all Member States and set up a common legal basis for all proportionate and necessary exchanges of information between competent institutions. By enabling the secure delivery of documents in the European Digital Identity Wallet, individuals and businesses would be able to receive and use them swiftly when needed in another Member State. Furthermore, the proposal would introduce common and secure verification mechanisms across the Union, allowing competent institutions, labour inspectorates, healthcare providers and other authorised entities to verify the authenticity, integrity and validity of social security documents in a reliable and efficient manner. This would strengthen mutual trust between Member States, facilitate the recognition of documents across borders, reduce fraud, forgery and errors and make it easier for individuals to prove their social security rights when moving, travelling or working within the Union.

(b) Are there economies of scale? Can the objectives be met more efficiently at EU level (larger benefits per unit cost)? Will the functioning of the internal market be improved?

The documents indicate that a common EU framework would be more efficient than separate national solutions. Current fragmentation forces businesses and citizens to navigate different procedures and systems, creating unnecessary administrative burden and legal uncertainty. Businesses in particular face overlapping requirements and delays for example receiving the relevant social security coordination documents which can prevent workers from starting assignments on time and hinder cross-border service provision. A Union-level approach allows common procedures, functional specifications and technical standards to be developed for secure exchanges or access to data avoiding duplication and incompatibility between national systems. The proposal also explicitly foresees synergies and interoperability with other Union initiatives including the Once-only Technical System, European business wallets, IMI and e-Health initiatives. The impact assessment identifies significant efficiency gains from faster verification. Under the modelled options, verification could be reduced to around one minute or even to almost real time in many cases, generating substantial savings compared with current practices. A coordinated EU

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solution therefore supports the internal market by making free movement and cross-border service provision more predictable, faster and more secure.

(c) What are the benefits in replacing different national policies and rules with a more homogenous policy approach?

A more homogeneous Union approach would address the shortcomings arising from divergent national practices in the request, issuance and verification of social security coordination documents. The evidence shows significant differences across Member States in the digitalisation of procedures, the speed of document issuance and the availability of online services while individuals and businesses continue to encounter difficulties when presenting and verifying social security documents across borders. Replacing fragmented national approaches with a common Union framework would improve legal certainty by establishing common rules, procedures and technical standards applicable across all Member States. It would strengthen mutual trust by enabling competent institutions, healthcare providers and other authorised entities to verify the authenticity and validity of social security documents in a secure, reliable and consistent manner. It would also reinforce the implementation and enforcement of the Union social security coordination rules by reducing opportunities for fraud, forgery and error through secure, real-time verification mechanisms. Finally, a common approach would improve the user experience by providing individuals and businesses with simpler and more accessible procedures to request, receive and present social security coordination documents across the Union. The Electronic Exchange of Social Security Information (EESSI) supports exchanges between competent institutions, while ESSPASS provides a common framework enabling individuals to securely access, present and share their social security credentials directly with authorised third parties, thereby addressing a gap that fragmented national solutions cannot resolve consistently across the Union.

(d) Do the benefits of EU-level action outweigh the loss of competence of the Member States and the local and regional authorities (beyond the costs and benefits of acting at national, regional and local levels)?

The benefits of action at Union level outweigh the limited impact on Member States' competences. The proposal does not harmonise national social security systems or affect Member States' competence to determine the organisation, financing or substance of their social security schemes. It is limited to establishing a common framework for the digitalisation of cross-border procedures and data exchanges necessary for the effective implementation and enforcement of the Union social security coordination rules. By contrast, the proposal is expected to deliver significant benefits for individuals, businesses and national authorities. These include simpler and more accessible procedures for requesting social security coordination documents, faster issuance through binding deadlines, more secure and reliable cross-border verification, reduced administrative burdens, improved enforcement, enhanced fraud prevention and easier access to social security rights and healthcare across the Union. By building on existing Union digital infrastructures and initiatives, the proposal also maximises previous investments and avoids unnecessary duplication of effort. The impact assessment identifies both the costs and benefits of the proposal. While implementation and maintenance costs will arise, particularly for national administrations, these are expected to be outweighed by the long-term benefits, including increased efficiency, reduced fraud, lower administrative burdens and improved legal certainty. Overall, the proposal strikes an appropriate balance between respecting Member States' competences and achieving the objectives that cannot be sufficiently attained through national action alone.

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(e) Will there be improved legal clarity for those having to implement the legislation?

The proposal would improve legal clarity by establishing a common legal framework governing the digital aspects of social security coordination including common procedures, technical specifications and governance arrangements for the request, issuance, exchange and verification of social security coordination documents. It would also introduce binding deadlines for the exchanges within the EESSI system and the issuance of social security documents, thereby providing greater predictability for individuals, businesses and competent authorities.

The proposal would further facilitate consistent implementation across the Union through common implementing acts and a dedicated governance framework supporting cooperation between Member States, the development of technical specifications and the exchange of best practices. This would reduce the legal and operational uncertainties currently resulting from divergent national approaches, limited interoperability and fragmented verification procedures, thereby ensuring a more uniform and effective application of the Union social security coordination rules.

3. Proportionality: How the EU should act

3.1 Does the explanatory memorandum (and any impact assessment) accompanying the Commission’s proposal contain an adequate justification regarding the proportionality of the proposal and a statement allowing appraisal of the compliance of the proposal with the principle of proportionality?

The explanatory memorandum and the impact assessment provide a justification demonstrating that the proposal complies with the principle of proportionality. The proposal is limited to those aspects necessary to facilitate the digital implementation and enforcement of the Union social security coordination rules in cross-border situations. It does not harmonise national social security systems or affect Member States' competence to determine the organisation, financing or substance of their social security schemes.

The proposal establishes a common framework for the digital request, issuance, exchange and cross- border verification of social security coordination documents, ensuring interoperability and mutual recognition while leaving the substantive rules on social security coordination unchanged. It also builds, to the greatest extent possible, on existing Union digital infrastructures and initiatives, notably the European Digital Identity framework, thereby avoiding unnecessary duplication of systems and reducing implementation costs. As recognised in the impact assessment, the deployment of the European Digital Identity Wallet forms part of the baseline scenario, as Member States are already required to make EUDI Wallets available under existing Union legislation. Consequently, the proposal relies on existing investments and follows a cost-effective approach that minimises additional administrative and financial burdens while achieving its objectives.

3.2 Based on the answers to the questions below and information available from any impact assessment, the explanatory memorandum or other sources, is the proposed action an appropriate way to achieve the intended objectives?

The proposal aims to strengthen digitalisation of cross-border social security coordination, focusing exclusively on areas where EU action delivers clear added value over national efforts without altering Member States’ competence over their social security systems or harmonising national rules. It establishes interoperable digital procedures, common technical standards, and governance frameworks, enabling secure cross-border exchange, verification, and issuance of social security

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documents. While the initiative entails one-off implementation and recurring maintenance costs for national administrations, these are justified by long-term gains: reduced administrative burdens, stronger fraud prevention, faster procedures, and improved access to rights for mobile citizens and businesses.

(a) Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on their own, and where the Union can do better?

The initiative is limited to those aspects that Member States cannot achieve satisfactorily acting alone and where action at Union level provides clear added value. It addresses only the digital aspects necessary for the effective implementation and enforcement of the Union social security coordination rules in cross-border situations, without harmonising national social security systems or affecting Member States' competence to determine the organisation, financing or substance of their social security schemes.

Member States cannot individually ensure interoperable digital procedures, common verification mechanisms or the mutual recognition of social security coordination documents across the Union. Independent national digitalisation initiatives would risk further fragmentation, divergent technical standards and uneven recognition of digital credentials, thereby undermining legal certainty and the effective application of the Union social security coordination rules. The proposal therefore confines Union intervention to those elements requiring common action, namely the establishment of interoperable digital procedures, common technical standards and governance arrangements necessary to ensure the secure request, issuance, exchange and cross- border verification of social security coordination documents.

(b) Is the form of Union action (choice of instrument) justified, as simple as possible, and coherent with the satisfactory achievement of, and ensuring compliance with the objectives pursued (e.g. choice between regulation, (framework) directive, recommendation, or alternative regulatory methods such as co-legislation, etc.)?

A Regulation is the most appropriate and proportionate legal instrument to achieve the objectives of the proposal. Given the cross-border nature of social security coordination and the need to establish common digital procedures, technical specifications and governance arrangements, the proposal requires uniform application across all Member States. A directly applicable Regulation ensures legal certainty, avoids regulatory fragmentation and provides a consistent framework for the request, issuance, exchange and cross-border verification of social security coordination documents.

The choice of instrument is also consistent with the existing legal framework on social security coordination, as the proposal complements the Union Regulations on social security coordination by establishing a dedicated legal framework governing their digital implementation and enforcement. A directive would leave Member States discretion in transposition, potentially resulting in divergent approaches to digital procedures, interoperability, verification mechanisms and governance, thereby undermining the objectives of the proposal. It would also be inconsistent with the existing regulatory framework governing social security coordination at EU level. A non- binding instrument would not provide the legal certainty or uniform implementation necessary to ensure the effective functioning of the common digital framework.

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The proposal is limited to those measures necessary to ensure the effective and uniform digital implementation of the Union social security coordination rules while leaving Member States fully responsible for the organisation, financing and substance of their national social security systems.

(c) Does the Union action leave as much scope for national decision as possible while achieving satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum standards or use a less stringent policy instrument or approach?)

The proposal leaves as much scope for national decision-making as possible while ensuring the effective implementation and enforcement of the Union social security coordination rules in cross- border situations. It does not harmonise the organisation, financing or substantive design of national social security systems, nor does it affect Member States' responsibility for determining entitlements or administering social security benefits under the existing coordination framework. The proposal limits Union action to establishing the common digital framework necessary to ensure interoperability, mutual recognition and secure cross-border exchanges of social security coordination documents. Within that framework, Member States retain flexibility in the practical organisation and implementation of their national digital systems. The impact assessment also recognises that implementation choices at national level, including governance arrangements and verification models, remain important determinants of implementation costs. The proposal therefore strikes an appropriate balance between establishing common rules where necessary to achieve the objectives of the initiative and preserving Member States' discretion over the organisation and operation of their national systems.

(d) Does the initiative create financial or administrative cost for the Union, national governments, regional or local authorities, economic operators or citizens? Are these costs commensurate with the objective to be achieved?

The proposal entails one-off implementation and recurrent maintenance costs, primarily for national public administrations, social security institutions, labour inspectorates and healthcare providers. However, the impact assessment concludes that these costs are proportionate to the objectives pursued and are expected to be outweighed by the long-term benefits resulting from the initiative.

The proposal is expected to reduce administrative burdens and recurring costs associated with paper-based procedures, manual verification, delays in issuing and verifying social security coordination documents and fraud. It is also expected to improve the efficiency of cross-border procedures, facilitate access to social security rights and healthcare, strengthen enforcement and provide greater legal certainty for individuals, businesses and competent authorities.

The impact assessment further notes that costs will vary depending on Member States’ existing digital infrastructure and their choices concerning technical architecture, integration with national systems and the sequencing of deployment. This flexibility allows Member States to build on existing solutions and phase implementation in a cost-efficient manner. It also clarifies that major investments related to the European Digital Identity Wallet are part of the baseline scenario and therefore do not constitute additional costs attributable to the proposal. Overall, the expected costs are considered commensurate with the objectives pursued and are balanced by significant long- term economic, administrative and societal benefits.

(e) While respecting the Union law, have special circumstances applying in individual Member States been taken into account?

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The proposal takes into account the different administrative structures, levels of digital maturity and implementation capacities across Member States. It does not prescribe the organisation of national administrations or require the harmonisation of national implementation models. Instead, it establishes only those common rules, technical specifications and common governance arrangements that are necessary to ensure the effective and interoperable application of the Union social security coordination rules in cross-border situations. The impact assessment recognises that implementation costs and practical arrangements may vary depending on national governance choices, including the organisation of verification systems and the existing level of digitalisation. The proposal therefore provides sufficient flexibility for Member States to organise implementation in a manner best suited to their national circumstances, while ensuring that the essential elements required for secure cross-border exchanges, mutual recognition and interoperability are applied uniformly throughout the Union. In addition, the governance, monitoring and reporting arrangements support the progressive implementation, ensures that the framework remains flexible and can adapt quickly and efficiently to practical experience, technological developments and evolving needs, thereby ensuring that it remains fit for the future.

EUROPEAN COMMISSION

04.05.2026

SEC(2026) 980

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 980}

{SWD(2026) 981-983}

Impact assessment / European Social Security Pass (ESSPASS)

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111

[email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / European Social Security Pass (ESSPASS)

Overall opinion: POSITIVE WITH RESERVATIONS

(A) Policy context

The Social Security Coordination (SSC) Regulation No 883/2004 on the coordination of

social security systems and its Implementing Regulation (EC) No 987/2009, support free

movement of persons within the single market. While the Electronic Exchange of Social

Security Information (EESSI) enables faster, secure, cross-border exchanges of

information among social security institutions, the exchange of data between individuals

and administrations in cross-border scenarios remains cumbersome, mostly relying on

paper-based procedures. The ESSPASS initiative builds on the existing digital systems

like EESSI, aiming to make interactions between individuals and administrations more

effective and efficient and forms part of broader efforts to digitalise services, reduce

administrative burdens and improve labour mobility across Europe. It also supports wider

EU goals on competitiveness, innovation, and full digital access to key public services by

2030.

(B) Key issues

The Board notes the additional information provided and commitments to make

changes to the report.

However, the report still contains significant shortcomings. The Board gives a

positive opinion with reservations because it expects the lead Service to rectify the

following aspects:

(1) The analysis of problems and their drivers is not sufficiently underpinned by

observational evidence and does not differentiate between stakeholders’ groups.

(2) The specific objectives are not sufficiently SMART. The logic behind the design

and structuring of the policy options is not clear.

(3) The report does not sufficiently justify all key assumptions, in particular those

driving the cost and benefit analysis. The sensitivity analysis is not sufficiently

developed.

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(C) What to improve

(1) The report should clarify the scope of the initiative regarding the portable documents

to be covered in the short and longer run. Beyond the initial focus on portable

documents A1 and EHIC, the report should explain the phased roll-out of other

portable documents.

(2) The report should improve the problem definition, building on available evidence, in

particular observational data. The problems and their drivers should be analysed with

more granularity, allowing to understand the magnitude of problems faced by the

specific stakeholder groups, e.g. (a) workers, differentiated where relevant by self-

employed and posted workers, (b) businesses, with a possible focus on SMEs and (c)

administrations. The report should also better differentiate the problems stemming

from the legal base and those linked to implementation. The report should better

analyse the simplification and digitalisation potential.

(3) The report should frame the overarching objective more strategically and link it better

to the Commission priorities. The specific objectives should be drafted in a SMARTer

way, considering in this context how success will be measured.

(4) The report should improve its intervention logic by better explaining the approach for

constructing the policy options and providing a more detailed description of the

policy measures, especially as regards their implementation. The voluntary options

should be used for sensitivity analysis only or discarded early on.

(5) The report should improve the analysis of costs and benefits based on a strengthened

assessment of economic, social and environmental impacts. The key assumptions,

particularly those driving the outcome of the analysis, should be transparently

disclosed and justified (e.g. data sources, evidence base, related uncertainties) and

where relevant be a subject of sensitivity analysis. A summary of all costs and

benefits, accompanied by sufficient explanations on the cost structure, their nature

(one-off vs recurrent) and distribution (who bears them) should be provided. Based

on the improved analysis, the report should provide a more robust comparison of

options.

(6) The coherence with existing or proposed policy initiatives (e.g. EUDI or e-declaration

proposal) should be further developed.

(7) The monitoring and evaluation framework should be accompanied by well-defined

indicators, data sources, baseline/benchmarks and, where relevant, quantified targets.

The framework would benefit from specifying indicators that are stakeholder-specific

(e.g. SMEs, verifiers, citizens, etc.). Indicators covering cybersecurity should also be

included.

Some more technical comments have been sent directly to the author Service.

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(D) Conclusion

The lead Service may proceed with the initiative.

The lead Service must revise the report and its executive summary in accordance

with the Board’s findings before launching the interservice consultation.

Full title European Social Security Pass (ESSPASS)

Reference number PLAN/2025/2391

Submitted to RSB on 31 March 2026

Date of RSB meeting “Written procedure”

Electronically signed on 04/05/2026 16:13 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

EN EN

EUROPEAN COMMISSION

Strasbourg, 15.9.2026 SWD(2026) 982 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on digitalising the coordination of social security systems, laying down a framework for

the European Social Security Pass (ESSPASS) and amending Regulations (EC) No

883/2004, (EC) No 987/2009 and (EU) No 2018/1724

{COM(2026) 980 final} - {SEC(2026) 980 final} - {SWD(2026) 981 final} - {SWD(2026) 983 final}

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Table of contents

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ......................................................................... 1 PROBLEM DEFINITION .............................................................................................................................. 2

Background (context and scope) ................................................................................. 2 What is the problem?................................................................................................... 3 What are the problem drivers? .................................................................................... 9 How likely is the problem to persist? ........................................................................ 13

WHY SHOULD THE EU ACT? .................................................................................................................. 14

Legal basis ................................................................................................................. 14 Subsidiarity: Necessity and added value of EU action ............................................. 14

OBJECTIVES: WHAT IS TO BE ACHIEVED? ......................................................................................... 15

General objective....................................................................................................... 15 Specific objectives..................................................................................................... 16

WHAT ARE THE AVAILABLE POLICY OPTIONS? .............................................................................. 16

What is the baseline from which options are assessed? ............................................ 16 Description of the policy options .............................................................................. 19 Options discarded at an early stage ........................................................................... 24

WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ..................................................................... 26

Economic impacts ..................................................................................................... 28 Social impacts ........................................................................................................... 39 Environmental impacts .............................................................................................. 41

HOW DO THE OPTIONS COMPARE? ...................................................................................................... 41 PREFERRED OPTION ................................................................................................................................ 46

A solution built on the EUDI framework and enhanced social security coordination

documents ........................................................................................................ 46 Application of the ‘one in, one out’ approach ........................................................... 48

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ........................................... 48 ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 48 ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 53 ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................... 81 ANNEX 4: ANALYTICAL METHODS ...................................................................................................... 88 ANNEX 5: COMPETITIVENESS CHECK ............................................................................................... 120 ANNEX 6: SME CHECK ........................................................................................................................... 125 ANNEX 7: THE PORTABLE DOCUMENTS AND THE EUROPEAN HEALTH INSURANCE CARD

........................................................................................................................................................... 131 ANNEX 8: EXAMPLES OF STAKEHOLDERS’ CHALLENGES .......................................................... 144

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ANNEX 9: THE SIZE OF THE PROBLEM AND ITS CONSEQUENCES ............................................. 150 ANNEX 10 ESSPASS PILOTING ACTIVITIES IN 2021 - 2025 ............................................................. 175 ANNEX 11: DIFFERENCES IN PURPOSE, SCOPE AND ACTORS BETWEEN ESSPASS AND

EESSI ................................................................................................................................................ 178 ANNEX 12: INTERVENTION LOGIC AND MONITORING INDICATORS FOR THE PREFERRED

POLICY OPTION ............................................................................................................................. 182

iii

Glossary

Term or acronym Meaning or definition

AC Administrative Commission for the coordination of social

security systems

AHG Ad Hoc Group of the Administrative Commission

DC4EU Digital credentials for Europe

EAA Electronic Attestations of Attributes

EESSI Electronic Exchange of Social Security Information

eIDAS Electronic Identification, Authentication and Trust Services

EHIC European Health Insurance Card

ESSPASS European Social Security Pass

EUDI European Digital Identity

EUDIW European Digital Identity wallets

ELA European Labour Authority

GDPR General Data Protection Regulation

OOTS Once Only Technical System

SDGR Single Digital Gateway Regulation

SDG Sustainable Development Goals

SSC Social Security Coordination

1

Introduction: Political and legal context Free movement is one of the most valuable achievements of the single market and delivers

significant benefits to Europe1. Over 55% of respondents to the Eurobarometer survey on

intra-EU labour mobility perceive it as significantly benefitting European integration, labour

markets and individuals’ lives, while an even larger majority, 84% of respondents to the survey

on European Union citizens and democracy, views its impact on their country’s economy as

favourable2.

The social security coordination (SSC) regulations3 provide a crucial contribution to this

freedom. They ensure individuals retain access to social security benefits - such as pension,

unemployment or family benefits - and healthcare when moving across borders, whether they

are individuals living in one Member State and working in another, young people studying

abroad, jobseekers in a new country, workers on temporary assignments, pensioners relocating,

travellers in need of urgent medical care. These regulations do not harmonise national social

security systems but determine which country’s system a mobile person falls under, assuring

that no person is left without coverage or subject to double coverage4.

EU SSC rules encourage Member States to use digital technologies for the exchange, access

and processing of data and to offer user-friendly services for individuals exercising their right

to move freely across Europe5. While the Electronic Exchange of Social Security

Information (EESSI)6 enables faster, secure, cross-border exchanges of information among

social security institutions, the exchange of data between individuals and administrations in

cross-border scenarios remains cumbersome, often relying on paper-based procedures. To

address this issue, the European Pillar of Social Rights Action Plan launched the European

Social Security Pass (ESSPASS) pilot project to explore a solution facilitating individuals’

exercise of social security rights across borders. Following the pilot phase, a legislative proposal

for an ESSPASS has been announced in the Single Market Strategy and in the 2026

Commission Work programme, as part of the Fair labour mobility package.

The initiative responds to the European Parliament calls for an ESSPASS proposal (notably in

its 2021 Resolution), follows up on the 2023 Commission’s Communication on digitalisation

in social security coordination, the November 2023 Council Conclusions, the Letta report on

the future of the single market, which urges to advance on ESSPASS, and requests from the EU

social partners7. It is part of the efforts to further modernise, simplify and digitalise cross-border

social security, as outlined in Executive Vice-President Mînzatu’s mission letter. These efforts

1 European Parliamentary Research Service 2019, Mapping the Cost of Non-Europe, 2019-24 and Ritzen, J.,

Kahanec, M. & Haas, J. (2017). EU mobility. IZA Policy Paper, No. 125, Bonn: IZA Institute of Labor Economics. 2 Eurobarometer surveys: ‘Intra-EU labour mobility after the pandemic’ - December 2022, and ‘European Union

Citizens and Democracy’ – July 2020. 3 Regulation (EC) No 883/2004 on the coordination of social security systems and Regulation (EC) No 987/2009

laying down the procedure for implementing Regulation (EC) No 883/2004. These Regulations also apply to

Norway, Iceland, Liechtenstein and Switzerland. Specific rules are in place in the agreements with the United

Kingdom. 4 Current negotiations aim to revise certain aspects of these Regulations to achieve greater fairness, clarity, and

ease of enforcement, COM (2016) 815 final. 5 Articles 72 (d), 73 and 78 of Regulation (EC) No 883/2004 and 4 (3) of the Regulation (EC) No 987/2009. 6 Articles 78 and 79 of Regulation (EC) No 883/2004 and Articles 2, 4 and 95 of Regulation (EC) No 987/2009. 7 Several position papers, hearing of EU social partners of 6 November 2025 (see Annex 2).

2

support the Commission’s goals for 2024-2029 to simplify processes and reduce burdens on

businesses, individuals and national authorities. Moreover, they aim to ensure better

enforcement and help relaunch Europe’s competitiveness, in line with the Draghi report, the

EU competitiveness compass and the 28th regime to help companies - notably start-ups and

scale-ups - overcome barriers to operating across Europe, supporting growth, innovation and

global competition. The initiative also contributes to the aim of fostering inclusive digital

participation for all individuals in Europe8 and facilitating seamless digital cross-border

services, in line with the Digital Decade Programme and the target of 100% of key strategic

services online by 20309.

Problem definition Background (context and scope) Free movement within the EU has become a fundamental aspect of life for many people,

offering opportunities to live, work, or travel across countries. This freedom plays a significant

role in the functioning of the single market, with approximately 14 million EU citizens living

and/or working long-term in another Member State. In 2024, there were 1.9 million cross-

border workers and 3.64 million posted workers.10 Intra-EU tourism also flourished, with 250

million overnight trips recorded the same year11. Furthermore, numerous students and

researchers are participating in programmes like Erasmus+12.

For individuals moving within the EU confirming their rights to social security benefits

and healthcare services is essential. Official forms exist to serve this purpose, covering

several areas:

- nine portable documents, relevant for cross-border healthcare, unemployment

benefits, accidents at work, occupational diseases, or attesting which country’s social

security legislation applies to individuals working across-borders13.

- the European Health Insurance Card (EHIC) enabling access to medically necessary,

state-provided healthcare during temporary stays in other EU countries.

In 2024, more than 8 million portable documents and almost 40 million EHICs were issued14,

whereas the total number of EHICs in circulation was 256 million15.

While the initiative aims to potentially cover all portable documents and the EHIC, the analysis

and findings in this impact assessment primarily focus on portable document A1 and the EHIC

8 European Declaration on Digital Rights and Principles. 9 Europe's Digital Decade | Shaping Europe’s digital future. 10 Intra-EU Labour Mobility Report 2025. 11 Tourism statistics - Statistics Explained - Eurostat. 12 Erasmus+ annual report 2024 - Publications Office of the EU. Almost 1.5 million people went on an Erasmus+

mobility in 2024. 13 The content of these forms has been defined by the Administrative Commission (AC) for the coordination of

SSC. For more details on portable documents and their use, see Annex 7. 14 This does not account countries, like Germany and Italy, where the EHIC is automatically issued to all insured

individuals. 15 Facts and figures on intra-EU labour mobility and EU social security coordination. The public consultation

found that 86% of respondents were familiar with these documents to some or a high extent, with the EHIC having

the highest level of familiarity (81%). See Annex 2.

3

due to their successful piloting, which has already confirmed the feasibility, relevance and

added value of digitalising their procedures16, making them the starting point for a phased

rollout of the initiative (see section 5.2).

What is the problem? There are barriers for individuals (including the self-employed and those active in two or

more countries) to swiftly and reliably prove their social security rights and insurance

status across Europe, for businesses to easily comply with requirements when posting

workers, and for social security institutions, labour inspectorates17 and healthcare

providers to efficiently and securely verify the authenticity (originating from an authorised

institution), integrity (unaltered) and validity (neither expired nor revoked) of relevant

documents. See an illustrative case below18.

Extensive data collection has been conducted to estimate the size of the problem, also as part

of a study on digitalisation in SSC.This involved gathering information from various sources,

such as the annual statistical reports on SSC19 and several databases and resources from the

Commission, like SOLVIT and Your Europe Advice. Additionally, relevant literature was

reviewed, and consultations were conducted with experts, national authorities and other

stakeholders, including through the Implementation dialogue on fair labour mobility, the yearly

high-level meeting on digitalisation in SSC and a hearing with EU social partners (Annex 2).

Insights were further enriched through surveys focusing on the problems and impacts of

ESSPASS, a public consultation, findings from the ESSPASS pilot activities20. Collectively,

these efforts have provided evidence confirming both the existence and magnitude of the

problem and helped estimate the consequences. However, estimates are subject to several

limitations21. For instance, the extent of individuals experiencing problems is likely

underestimated, as official data only reflect the experiences of those who were willing and able

16 See Annex 10 on ESSPASS pilot activities in 2021-2025. National authorities support this roll-out approach, as

expressed during regular meetings of the AC and Technical Commission and reiterated in the responses to the call

for evidence. See section 0. 17 For ease of reading, the term ‘labour inspectors’ is used throughout the report to encompass all actors responsible

for the verification of portable document A1. 18 See Annex 8 for examples of stakeholders’ challenges. 19 Facts and figures on intra-EU labour mobility and EU social security coordination - Employment, Social Affairs

and Inclusion. 20 For a description of the main challenges identified by one of the pilot projects: Grech, A. and Farkas, K.G.

(2026). Beyond DC4EU. Advancing European Digital Identity through Trust Frameworks, Education and Social

Security Pilots. www.dc4eu.eu/reports. 21 See Annexes 4 and 9 for a detailed presentation of methodological aspects.

Gabriela, an EU citizen from Slovenia, is going on vacation to Spain. Before her trip, she has to request the

EHIC card from her Slovene health insurance institution well in advance so that it arrives by post on time. If the

card is delayed, she can require a Provisional Replacement Certificate.

During her holiday Gabriela has an accident and needs urgent medical treatment. She presents her plastic EHIC

at the hospital. Gabriela gets the treatment, but the EHIC is not accepted because the hospital has doubts on her

insurance status. She has to pay up-front and once back at home asks her Slovenian insurance for reimbursement.

This results in additional time spent, potential delays and hurdles in recovering the sums due.

4

to report them. Additionally, the reporting of problems in certain areas, notably fraud, involves

only a limited number of Member States providing estimates22.

The problem tree (Figure 1) illustrates the relationship between the problem drivers, problem

and the resulting consequences for different groups and society.

Figure 1. Problem tree

The identified problem results in various negative consequences, the most significant of

which are presented in this section, with more details, including on methods, in Annex 9.

Individuals and businesses

Current obstacles in requesting and obtaining portable documents and the EHIC23lead to

inconvenience and delays due to processing or postal delivery, and in some cases requests or

renewals must even be made in person24.

Businesses with employees, or self-employed, on temporary assignments abroad must allocate

time, personnel and finances to manage paperwork and procedures related to portable

document A1 with different information requirements across EU countries25. This necessitates

22 Fraud and error in the field of social security coordination and the European Labour Authority’s study on Fraud

and error and selected issues in the field of social security coordination. 23 Delays and difficulties in obtaining the documents emerged as the most reported issue in the public consultation

among respondents who had encountered difficulties (see Annex 2). 24 See section 0, first problem driver. EU individuals from ten different Member States reported in the public

consultation that they had to visit national authorities in person to renew documents, highlighting persistent

inefficiencies in renewal procedures. 25 See Annex 7. The A1 form needs to be requested by companies sending employees to work temporarily abroad

(i.e. posted workers) or self-employed. Business Europe reported that various procedures and different information

requirements create unnecessary red tape for businesses operating across borders: 2025-01-

22_businesseurope_mapping_of_regulatory_burden-d55-1.pdf.

5

expertise and effort from internal human resources or global mobility teams. Smaller

businesses, lacking dedicated international departments, find these demands particularly

burdensome26. Specifically, businesses report that obtaining the A1 form, while

simultaneously meeting posting declaration requirements27 is costly. They suggest

exploring technical synergies between these procedures to reduce redundancy and enhance

legal certainty, while facilitating enforcement28.

Obstacles and delays in receiving portable documents can prevent timely access to

benefits and essential services and restrict business operations across borders. Specific

challenges were for instance reported in obtaining:

- the portable document U1, impeding timely calculation of unemployment benefits for

mobile workers.

- the portable document A1, which may leave businesses and workers vulnerable to fines

for failure to present the document during inspections29, disrupt operations30 and create

uncertainty for those needing to relocate, secure housing, and arrange travel31, as well

barriers to accessing national healthcare systems in the host countries during long-term

postings32.

26 During the hearing of the EU social partners (see Annex 2), SME Europe highlighted the administrative burdens,

especially for SMEs, due to the different social security systems across the Union. Among the 31 respondents to

the public consultation representing companies and business associations, 45% considered that SMEs, start-ups

and scale-ups are more affected by the administrative burden than larger businesses. This was highlighted by

respondents including Pearle, Confindustria (Italy), International Road Transport Union, International Transport

Danmark and Handwerkskammer Koblenz (Germany). 27 Businesses need to submit a declaration to the host country, when required by national legislation (Article 9 (1)

(a) of Directive 2014/67/EU). A proposal for a public interface, COM (2024) 531, is under negotiation.

Administrative requirements for posting operations have been identified as a major barrier to the single market:

Single Market Enforcement Taskforce, Report 2023-2024 and Single market strategy, COM (2025) 500. 28 Feedback from the hearing with EU social partners and several position papers. 29 Emphasised by Pearle, the European federation of music and live performance organisations, as well as by other

associations in the transport sector (International Road transport Union and Transport en Logistiek Nederland). Some EU countries, like France and Austria introduced administrative fines. However, people shall not be fined

if they can prove that an A1 form request has been submitted before the inspection. 30 In response to the call for evidence, Ceemet noted that in certain countries it is nearly impossible to obtain an

A1 form or can take several months before a decision is made by the issuing institution. Some respondents to the

public consultation for instance reported that urgent short-term assignments (e.g. emergency repairs or production

line breakdowns) are particularly disrupted when the document cannot be issued in time. Similarly, stakeholders

from the logistics sector reported that freight forwarders and logistics companies operate in fast paced, short notice

environments, where they need rapid digital delivery and verification of portable documents to deploy staff

efficiently. When A1 forms are not available quickly, consignments may be delayed at borders or during roadside

checks, disrupting supply chains and generating additional costs for both operators and their clients. For live

performing artists, speed to obtain portable documents are crucial to avoid losing business opportunities. 31 See Beyond-DC4EU-Final-Report-January-2026.pdf. 32 Many workers may be requiredto have an A1 form when requesting an S1 form, which certifies the entitlement

to healthcare when living in a country different from the one of insurance. In the construction sector, posted

workers are disproportionately affected by workplace accidents and thus need the swift and digital issuance of

their portable documents to be able to easily access urgent healthcare.

6

These issues have been recognised as major barriers to a seamless EU single market33.

Difficulties tend to be acute for individuals daily crossing borders for work, as even minor

delays can significantly disrupt their access to benefits compared to other workers34.

Workers on temporary assignment abroad (posted workers)are oftennot informed about

their employers’ request of a portable document A1, leaving them without crucial knowledge

of their social security affiliation35. This lack of transparency has been a major source of

critique of the current status quo36. Moreover, this gap in information creates vulnerabilities

to fraudulent practices, as workers are unable to verify the arrangements made regarding their

social security status 37.

For verification processes in other Member States, annual lost time for individuals is

estimated between 65,000 and 217,000 hours due to checks related to portable document A138,

68700 to 171 600 hours for the EHIC, and 51,600 hours for the other portable documents39.

Challenges and associated lost time are exacerbated when there are doubts regarding

documents’ authenticity, integrity and validity, requiring additional exchanges between host

authorities and institutions in the issuing country, or leading to non-acceptance of documents40.

The individuals whose EHICs are refused must pay for their treatment immediately and later

request reimbursement in their countries of insurance41. In 2024, 14 countries42 reported

33 In 2024, SOLVIT handled 242 cases in France, 62 in Cyprus, 58 in Germany related to U1 form issuance delays,

as well as cases on delays in A1 form issuance (e.g. in Romania). Cases were also reported via the Your Europe

Advice reports. Respondents to the ESSPASS public consultation considered delays as a major issue. 34 Report EU Border Regions: Living labs of European integration. 35 Insufficient information or awareness among mobile persons about their rights and the legislation that applies

to them in cross-border situations was ranked by public consultation’s respondents as second among the four

situations contributing to difficulties to proving social security rights across borders (see Annex 2). The European

Transport Workers’ Federation reported challenges for transport workers to know whether they are insured, under

which jurisdictions, for which exact periods, and to which Member State they can turn in order to claim their social

security rights and benefits. 36 Garben, S., 2023, The European Social Security Pass (ESSPASS), publication for the Committee on

Employment and Social Affairs, Policy Department for Economic, Scientific and Quality of Life Policies,

European Parliament, Luxembourg; Houwerzijl, M., 2015, A Hunters Game: How Policy Can Change to Spot and

Sink Letterbox-Type Practices; Houwerzijl, M. (2018): 'Improving cross-border social security', in: Buelen, W.

(ed), Putting an end to cross-border social security fraud and abuse, European Federation of Building and

Woodworkers. 37 2023 ELA study on construction issues: Dutch labour inspectors noted recurrent instances where posted workers

were unaware of A1 form. This suggests that their employers were likely withholding this information

fraudulently. During the hearing with social partners, ETUC emphasised that more transparency is needed to help

workers be better aware of their status. 38 See Annex 9, table 4 on the number of portable document A1 checked annually and table 9 on the time spent.

81 % of respondents (131 out of 162) to the public consultation reported that current challenges result in lost time

and administrative hurdles for individuals. 39 See Annex 9. 40 In response to the public consultation, the European Cabin Crew Association (EurECCA) highlighted that the

verification of security position remains largely dependent on ex post administrative exchanges between

institutions. 41 This was one of the main challenges reported in the public consultation by those who encountered problems

with the EHIC. 42 Directorate-General for Employment, Social Affairs and Inclusion, Publications Office of the European Union,

2026, Cross-border health care - reference year 2024. CZ, DK, DE, EE, FR, HR, IT, LU, HU, AT, PL, SK, SE,

and CH.

7

domestic EHIC refusals by healthcare providers and 18 countries43 identified similar issues

abroad. Causes included doubts about EHIC validity, lack of knowledge of procedures,

unreadable cards and format issues, language barriers, and missing information. It is estimated

that around 42,000 EHICs were either not accepted or missing at the point of care in 2023,

resulting in individuals having to pay upfront healthcare costs totalling EUR 3.4 million44.

While costs are eventually reimbursed, the funds recovery process creates difficulties and

expenses, due to the necessary administrative interactions, time-consuming procedures45and

hidden fees, like courier services. Delays in receiving reimbursements may cause cash flow

problems and financial distress for individuals, especially for expensive treatments46.

Businesses also face indirect financial pressures when issues with the portable document A1

arise during inspections47. Feedback from the Digital Credentials for EU (DC4EU) project48

indicates that during verification of the A1 form, posted workers are often not allowed to

continue performing their duties. While the cessation of activities may not occur for every

instance, if work would have to be stopped, the resulting labour costs are estimated to total

between EUR 1.2 and 4.2 million annually49. Additionally, businesses may need to provide

extra documents and information50.

National authorities and healthcare providers

It is estimated that the visual inspection of portable document A1 alone accounts for 65 000

to 217 000 hours annually (total EU), costing labour inspectorates between EUR 1.4 to 4.7

million51. For other portable documents, this is estimated at EUR 1.36 million52. Meanwhile,

checks on EHIC require 68 000 to 172 000 hours resulting in costs of around EUR 2.2 to 5.6

million for healthcare providers each year53. These estimates do not include the time required

for additional exchanges with issuing countries in case of doubts on documents’ validity, with

waiting time for receiving information ranging from hours to months54.

43 Ibid. CZ, DK, EE, EL, ES, FR, HR, IT, LU, HU, MT, NL, AT, PL, SI, FI, SE, and CH. 44 See Annex 9, table 17. Data from the statistical report on Cross-border healthcare in the EU under social security

coordination, reference year 2023. 45 The problem was raised by the Ad Hoc Group (AHG) of the AC on the digitalisation of the EHIC. 46 The Your Europe Advice reported a case of an individual unable to pay the amount upfront, but the insurance

institution would only reimburse after payment. 47 Almost half (46%) of the respondents to the public consultation representing business associations and

companies (14 out of 31) reported that doubts regarding the validity of the portable document A1 during

inspections created moderate to major problems, including delays, lengthy waiting times and operational

disruptions. 48 See Grech, A. and Farkas, K.G. (2026) Beyond-DC4EU-Final-Report-January-2026.pdf. This was confirmed

by national experts during interviews as part of the Study on digitalisation in SSC. 49 See Annex 9. 50 69% of respondents to the public consultation reported that overall current problems in proving and verifying

social security rights across borders create administrative burdens for companies. 51 Ibid, table 10. Ranges reflect the minimum and maximum time needed for checks across Member States (which

vary from 5 to 16 minutes), and the assumed number of portable document A1 checked per control. 52 Ibid, table 7. 53 Ibid., table 14. Ranges reflect the minimum and maximum time needed for checks across Member States (which

vary from 2 to 5 minutes). 54 Stakeholders interviewed as part of the study on digitalisation, notably social security institutions from five

Member States. Healthcare providers, labour inspectors and national authorities respondents were asked whether

they had experienced any difficulties over the previous three years. Overall, 50% (22 out of 44) reported that they

8

Beyond direct financial impacts, inefficiency damages reputation of national authorities and

healthcare providers. Slow service delivery erodes trust that individuals and businesses place

in cross-border public services55.

Additionally,difficulties in proving and verifying social security rights and insurance status

increase the risk of errors, fraud56 and misuses. Based on Member States and experts’

feedback57, critical issues were identified:

- Manual entry of information from portable documents or the EHIC into IT systems

resulting in data discrepancies and errors, which can lead for instance to failure to

identify individuals, with adverse effects on the EHIC reimbursement procedures58.

- Presentation of counterfeit or altered physical documents to fraudulently claim

benefits59, with estimates of 0.1% to 1% of portable documents60 – equivalent to 3 500 to

35 000 cases – and about 2 000 to 20 000 EHICs which may be falsified annually. This

could lead to annual costs of about EUR 7.5 million specifically for portable document A1

and from EUR 1 to 10 million for EHIC61.

- The misuse of EHICs no longer valid as the holder's insurance coverage has ended (fraud

and errors)62, resulting in further procedural steps for the EHIC issuing countries, which

must cover costs and then ask for refunds63.

In 2024, rejections of reimbursement claims were also reported by a high number of

countries, mostly due to invalid EHICs at the time of treatment or missing information64.

had encountered such difficulties, with healthcare providers reporting challenges in verifying insurance status. 75

% of respondents to the public consultation reported that current challenges generate administrative burdens for

national authorities, healthcare providers and labour inspectorates. 55 In a survey conducted by the DC4EU pilot project, a Spanish healthcare provider indicated that introducing

instant EHIC verification would enable immediate treatment with confidence in coverage. It would eliminate

uncomfortable interactions, where patients are asked to call their home country's insurance while waiting in the

emergency room. 56 Directorate-General for Employment, Social Affairs and Inclusion, Publications Office of the European Union,

2025, Fraud and error in the field of social security coordination. Fraud is underestimated, as only a few countries

provide data, particularly quantitative data. 57 Workshop with experts in the context of the study on digitalisation in SSC. 58 In a survey conducted by DC4EU pilot project, a hospital billing department in Germany reported that manual

data entry from physical cards creates errors in 15- 20% of cases, leading to reimbursement delays that can take

months to resolve. 59 This was raised by five labour inspectorates (IT, DE, ES, RO, BE) and eight social security institutions (two

institutions in DE and BE, SK, CZ, LT, FR) interviewed as part of the study on digitalisation. In response to the

call for evidence, social partners (ACV–CSC, Confederation of German Employers' Associations, BDA, and

EFBWW) noted that withdrawn or invalid documents remain practically indistinguishable from valid ones, which

stakeholders link directly to fraud risks (Annex 2). 60 See Annex 9. These refer to portable documents A1, S1, S2, U1 and U3. The percentages are assumed based on

available data. 61 Ibid. 62 See the report on fraud and error: DK, EL, MT, RO, SI, FI, NO, and UK reported inappropriate use, with four

of them able to quantify these issues. In a survey conducted by DC4EU pilot project, an Italian emergency

department noted that there is no way to confirm EHIC validity without calling the issuing country, something

impractical during emergencies. Digital verification would mitigate fraud risk, ensuring swift treatment. This issue

was also highlighted by the AC AHG on EHIC digitalisation. 63 This create issues which are being discussed by the Audit Board of the AC dealing with cross-border healthcare

reimbursement. 64 See the report on Fraud and error. Twenty countries (CZ, DK, DE, ES, FR, HR, IT, LV, LT, HU, AT, PL, PT,

RO, SI, SK, FI, SE, LI, and CH) indicated that invoices were rejected by their institutions, while 22 countries (CZ,

9

These rejections create administrative hurdles for hospitals and both administrations

involved in recovering the sums due, causing potential financial losses for the host country

or delaying payments and subsequent problems in reimbursing individuals65.

Society

The identified problem contributes to creating barriers to intra-EU labour mobility,

reducing its attractiveness for individuals pursuing personal and professional development. This

effect tends to be more visible in cross-border labour markets where commuting decisions are

highly influenced by administrative barriers66. The Draghi report67 emphasises that fears of

losing access to social protection or facing difficulties accessing social security in other

Member States68, discourages individuals from relocating - even though EU legislation ensures

the portability of social security rights. As the Letta report69 shows, existing obstacles restrict

mobility to a small segment of population. Additionally, the impacts of some of the

requirements and complexities discourage the free movement of services within Europe70,

potentially limiting business opportunities. These barriers undermine the dynamism of the

single market and compromises Europe's ability to remain competitive, generate

employment and foster economic growth. Research indicates that intra-EU labour mobility

increases productivity, optimises resource allocation, alleviates shortages and drives

innovation71. The 2026 single market and competitiveness report also emphasises that

insufficient cross-border digital services, persistent mobility and regulatory challenges

are detrimental to SMEs and hinder European economic expansion72. They jeopardise the

digital single market's objective of achieving seamless integration and a smooth societal shift

into the digital era.

What are the problem drivers? Several drivers contribute to the identified problem, each distinct yet interrelated. They relate

to current procedures for requesting, issuing and verifying portable documents and the EHIC

and are primarily linked to legal shortcomings rather than implementation issues. In particular,

DK, DE, IE, EL, ES, FR, HR, IT, LV, LT, HU, AT, PL, PT, RO, SI, SK, FI, SE, NO and CH) by institutions in

other countries. Key reasons included: coverage period gaps, wrong personal identification numbers, incorrect

treatments dates, missing EHIC ID number, insufficient EHIC information, duplicate claims and lack of insurance

coverage. 11 countries were able to quantify: total rejection rates for claims issued and received were

approximately 4.4% and 4.3%, respectively. 65 Ibid. 66 Removing 20% of existing obstacles could boost the border regions GDP by 2% (91 billion euro), potentially

creating over a million jobs. See the study: 'Quantification of the effects of legal and administrative border

obstacles in land border regions'. 67 Draghi report: In-depth analysis and recommendations (Part B), page 265. 68 65% of respondents to the public consultation reported that current problems in proving and verifying social

security rights across borders foster fear of losing social security rights when moving or working in another

Member State. 69 Much more than a market, page 102. 70 The administrative hurdles linked to procedures for posting of workers are considered one of the most significant

obstacles preventing businesses from expanding across Member States, 2025 Single Market Strategy 2024. See

also SMET report, page 12. 71 A comprehensive review of existing literature and various technical reports substantiates this analysis of labour

mobility’s positive impact on the economy, see Communication on the fair labour mobility package.72 It is estimated that harmful barriers still result in a 20% productivity gap compared to the United States.

10

there are regulatory gaps, as the detailed procedural steps are to a large extent left to Member

States, which can result in divergent practices and inconsistencies across the Union.

1. Reliance on time-consuming and manual processes

Representatives from social security institutions and experts from the pilot projects confirm that

current procedures remain slow73. This is particularly relevant for non-digital procedures,

though even when digital systems exist, they often remain time-consuming due to reliance on

physical paperwork and manual data checking.

While the online request for A1 forms and the EHIC is widely accessible74, as required by the

Single Digital Gateway (SDGR) Regulation75, the digitalisation of the request and issuance

for other portable documents is still comparatively limited, as illustrated in Annex 7. Portable

documents U1, U2 and S1 show moderate levels of online access. The least digitally accessible

documents are S2, S3 and DA1, with only a few countries providing digital services for them76.

Significant variations in document issuance speed exist across the EU for the EHIC and the

portable document A1. EHIC delivery times vary considerably; countries like Cyprus and

Austria average 0 - 4.5 days, whereas others, such as Germany and Luxembourg, exceed 11

days77. This is also due to postal shipping of plastic cards, which can be delayed or lost in

transit78.

Whereas automated systems for portable document A1 streamline operations in certain

countries (like Austria, Belgium, Germany, France, Finland and Slovakia), others continue to

experience prolonged processing periods that extend for 2-3 weeks (Hungary, Lithuania,

Czechia, Portugal and Denmark) or longer (such as in Bulgaria, Sweden, Norway, and Poland

for complex cases). Institutions reporting high automation (28% of institution, covering 24%

of A1 forms) typically issue 50-80% of certificates automatically using deterministic, rule-

based checks. The remaining institutions report either no automation (34%), moderate (22%,

covering 57% of A1 forms) or limited automation (16%, covering 9% of A1 forms). In terms

of administrative workload faced by institutions, scores range from a low of 0.09 in

Luxembourg to a high of 0.90 in Bulgaria, averaging 0.46. For applicants, scores range from

0.11 (lowest, Spain) to 0.79 (highest, Latvia), averaging 0.34 (e.g. Italy, Denmark and

Luxembourg)79.

73 In particular, representatives of social security institutions from Belgium, Croatia, Denmark, Latvia, Greece, the

Netherlands, Czechia, Romania, Ireland and Spain were concerned about the time-consuming nature of manual

verification processes (survey conducted as part of the study on digitalisation). See also Beyond-DC4EU-Final-

Report-January-2026.pdf. 74 See ELA report on overview and analysis of Member State A1 forms. Fully online application processes are

standard in 79% of institutions (89% of A1 forms). See Digital Decade 2025: eGovernment Benchmark 2025 for

the EHIC digitalisation. 75Article 6 and Annex II of Regulation (EU) 2018/1724. 76 Annex 7, tables 4 and 5. See also ELA, National cross-border digital tools and services in the field of EU social

security coordination. 77 Cross-border healthcare - reference year 2023. 78 Beyond-DC4EU-Final-Report-January-2026.pdf. 79 See ELA report on portable document A1 tools (to be published). Higher score indicates greater administrative

workload. Scores are based on elements such as complexity of required information, portal usability, automation

or verification effort. They are normalised to a scale from 0 to 1 across all 32 national institutions observed.

11

The verification of portable documents and the EHIC is also largely reliant on manual

processes, typically involving the visual inspection of information they contain and the identity

of the holder80. In the case of EHIC, healthcare providers visually inspect the card and then

manually input patients and EHIC data into their systems for processing81 and send copies of

the EHIC and ID cards for reimbursements, with some providers still using postal mail for this

purpose.

For portable document A1, some EU countries have moved towards less manual approaches

for verifications82, developing layered systems that combine information received from the

EESSI system, online verification portals (Spain, Norway, Poland and Portugal), exchanges

with home countries via the Internal Market Information (IMI) system, secure e-mails and

administrative cooperation platforms. However, these tools do not allow for instant verification

and are consequently often time-consuming83. Moreover, significant divergences among

countries84 have resulted in a fragmented landscape, inconsistencies and disparities in how

effectively each country validates the portable document A1.

Stakeholders identified the lack of automatic verification as an obstacle of high or very high

relevance, notably regarding portable documents S1, A1 and EHIC procedures85.

2. Limited cross-border interoperability, including divergence in document formats

and in national verification methods (where available)

Another key driver that makes proving and verifying social security rights and insurance status

difficult, as highlighted by stakeholders, is the limited standardisation86 and

interoperability87 – at different levels - between the national systems managed by social

80 Healthcare providers, labour inspectors and national authorities’ respondents to the public consultation were

asked to rank three factors contributing to verification challenges. Reliance on physical documents without digital

verification features and on manual processes was ranked as the main challenge, closely followed by the lack of

an EU standard enabling real-time digital verification of social security coordination documents and insurance

status. 81 Healthcare providers responding to the ESSPASS public consultation considered this a time-consuming process

that delays patient care and also increases the risk of errors and delays in reimbursement. 82 Ibid. and Annex 9. 83 Authorities in the home countries must process a growing number of inquiries from the host countries, via IMI,

with a limited number of staff, see Between the cracks: third-country posted workers. The issue of delays in replies

from national authorities regarding the validity and authenticity of the portable document A1 was also pointed out

in the public consultation. 84 See ELA report on portable document A1 tools. 85 About 60% of respondents (45 out of 76 replies) of the digitalisation study’s survey. This was also confirmed in

interviews, including with labour inspectors and in the call for evidence. Trade Unions (European Federation of

Building and Woodworkers, EFBWW, and 3F) further reported that labour inspectorates cannot verify authenticity

or validity, undermining enforcement effectiveness. 86 The lack of common standards is one of the most frequently cited barriers to data sharing. OECD (2019).

Enhancing Access to and Sharing of Data: Reconciling Risks and Benefits for Data Reuse across Societies. This

was confirmed by 91.5% of the respondents the 2020 public consultation for the European strategy for data. 87 According to the Interoperable Europe Act, cross-border interoperability refers to the capacity of public sector

bodies to interact with each other across borders by sharing data, information through digital processes in line with

the legal, organisational, semantic and technical requirements related to such cross-border interaction.

Interoperability beyond EESSI - which cover only exchanges between social security institutions - is low, see ELA

(2025), National cross-border digital tools and services in the field of EU social security coordination.

12

security institutions, labour inspectorates, and healthcare providers88. The portable documents

and the EHIC are produced in sometimes various formats across EU countries, typically as

physical documents, such as plastic cards for EHIC, paper forms, or PDFs and are not uniformly

verified within Europe, due to poor cross-border coordination and lack of common rules. For

instance:

- Most Member States issue the portable document A1 as a PDF without verification

capabilities89, and only few have introduced non standardised verification features, such as

nationally defined QR codes (France, Croatia and Slovenia)90.

- The EHIC is primarily issued as a plastic card without electronic features. A handful of

countries, like France and Italy, have introduced the possibility of receiving electronic

versions, but these are generally not used in other countries, as the physical card remains

the only accepted format across Europe, based on the specifications outlined in AC

decisions91.

The existence of various and non-standardised verification approaches forces users to adapt to

the different requirements and capabilities of each Member State's system, leading to

inefficiencies, confusion and varying levels of security92. The eGovernment Benchmark 2025

highlights that interoperability barriers are a major obstacle to efficient e-government in

Europe. Limited cross-border interoperability hinders countries from optimising

administrative processes, efficiently allocating resources, and delivering seamless services to

individuals and businesses, ultimately affecting the overall performance and effectiveness of

public administrations93.

3. Processes insufficiently centred around the needs of individuals and businesses,

inadequate awareness and control over personal data

Current procedures are insufficiently considering users (the ‘user-centric approach’). Instead

of being intuitively designed around the needs and experiences of individuals and businesses,

these processes are often cumbersome and difficult to navigate. Most national online portals

do not sufficiently incorporate features like data pre-filling, real-time status tracking, once only

principle, bulk request options to reduce applicant workload, nor provide multilingual support

to enhance accessibility94. Barriers persist, as also evidenced by the impossibility, in some

88 75 % of respondents (57 out of 76 replies) considered this of high (40) or medium relevance (survey as part of

the study on digitalisation). Moreover, 80% of respondents to the questionnaire for the Conference on digitalisation

of social security coordination and labour cards believed that more investments were needed in cross-border

interoperability and automation. 89 In response to the call for evidence on ESSPASS, BDA and EFBWW argued that static formats prevent reliable

authenticity checks. 90 The SDG Regulation provides Member States the flexibility to choose their own output format, while still

adhering to certain requirements (Article 6). 91 Technical specifications of the EHIC are defined in Decisions S1 and S2 of the Administrative Commission. 92 Interviewed labour inspectors also stressed that the effectiveness of national solutions highly depends on the

knowledge available across EU. 93 See the Commission Staff working document Impact assessment report accompanying the document Proposal

laying down measures for a high level of public sector interoperability across the Union (Interoperable Europe

Act), SWD/2022/721 final. 94 For portable document A1, see ELA report on digital tools.

13

cases, to access social security services using foreign identification means95. End users often

need to repeatedly submit the same documents or data to different institutions in different

countries, making procedures time-consuming, inefficient and leading to unnecessary hurdles96.

Individuals are often inadequately informed or excluded from processes impacting them,

notably in instances where posted workers remain unaware of actions taken by their employers,

such as requesting the portable document A1 (see section 0).

Despite efforts to improve awareness97, stakeholders have also highlighted insufficient

understanding of the various procedures among individuals98 and businesses, particularly SMEs

and the self-employed99.

External factors influence and reinforce the problem identified, although they remain outside

the direct scope of the initiative, notably:

- Differences in the adoption and availability of digital services. Digital maturity in SSC

beyond the EESSI system is highly fragmented100, with disparities emerging not just among

countries, but deeply within and between the various branches of social security. This

imbalance is driven by varying levels of cross-border demand, the complexity of the

services involved, and specific national incentives. For instance, pension services tend to

be more digitally advanced due to their extensive usage and importance in cross-border

scenarios.

- Insufficient prioritisation of investments by Member States in cross-border services

and uneven allocation of resources. Governments naturally prioritise domestic public

services over cross-border ones, especially during periods of budget constraint.

- Uneven digital skills among administrative personnel across Member States.

- Persistent individuals’ digital skills gaps. At the EU level, the Digital Economy and

Society Index (DESI)101, shows that around 60% of individuals aged 16-74 have basic

digital skills, with rates ranging from over 80% in the Netherlands and Finland to below

30% in Romania.

How likely is the problem to persist? Without EU intervention, individuals are likely to continue facing difficulties proving their

social security rights and insurance status in cross-border situations while businesses will

persist in encountering problems with easily complying with requirements.

95 This was for instance reported by Finland where access to digital healthcare and pension services often requires

a Finnish national electronic identification, limiting digital access for non-residents. The situation may improve

thanks to the implementation of the EUDI framework. 96 This was underlined by business associations in the EU social partners hearing. See Annex 2 and section 0. 97 This includes the recent ELA campaign on social security coordination: EU4SocialSecurity. 98 About 87% of respondents (66 out of 76 replies) of the survey conducted as part of the study on digitalisation,

considered this of high (35) or medium relevance. When asked to rank four situations contributing to difficulties

in proving social security rights and insurance status across borders, respondents of the public consultation

identified insufficient clarity on the procedures to be followed as the main challenge. 99 This was also raised during interviews with two business associations, one worker representative organisation,

and a Czech national authority as part of the study on digitalisation. 100 ELA (2025) National cross-border digital tools and services in the field of EU social security coordination. 101 See European Commission (2025), DESI indicators 2025, Eurostat isoc_sk_dskl_i21 2025.

14

In the absence of an EU solution, issue like the rejection of EHIC due to unverifiable validity

will persist. Given the sustained growth in post-pandemic period - with tourism trips by EU

residents rising by 6.1% in 2023 and 4.4% in 2024102 - short-term cross-border stays within the

Union are expected to remain common, maintaining the demand for access to necessary

healthcare during temporary stays abroad.

Problems in verifying portable documents, notably the A1 form, and the EHIC by national

administrations and healthcare providers will persist. Verification practices across Member

States are expected to remain fragmented, relying on diverse formats and procedures that lack

cross-border interoperability. Even with increased digitalisation of portable document A1 at the

national level, labour inspectorates in host Member States will lack the ability to access or verify

these documents in real time. The same difficulties in checking the validity of the EHIC will

continue to exist for healthcare providers.

Challenges will be greater for other portable documents, especially since, unlike the EHIC and

the portable document A1, their online request and issuance are not covered by the SDGR,

resulting in less pressure on Member States to digitalise them. The assessment of the baseline

scenario and evolution without EU intervention are presented in section 0.

Why should the EU act? Legal basis Article 48 of the Treaty on the functioning of the European Union (TFEU) grants the EU

the competence to coordinate EU countries’ social security schemes. Member States remain

free to decide about the details of these schemes and to determine who is to be insured under

their legislation, which benefits are granted, and under what conditions. While Article 48 TFEU

applies to employed and self-employed migrant workers and ‘their dependants’, Regulation

(EC) No 883/2004, based both on what are now Articles 48 and 352 TFEU, extends SSC to

inactive citizens moving within the Union. This Article provides a solid legal basis for adopting

measures to digitalise cross-border social security processes and facilitate the exercise of social

security rights and fair labour mobility within the EU.

Subsidiarity: Necessity and added value of EU action The free movement of people and freedom to provide services are fundamental freedoms of

the European Union. To fully benefit from these rights, individuals and businesses must rely on

efficient public services, including when accessing social security benefits or sending

employees for temporary work in other countries.

The barriers to the seamless proof and cross-border verification of social security rights

and insurance status cannot be effectively dealt by Member States on their own. Digital

solutions implemented by a single Member State will not ensure cross-border interoperability

and recognition and verification of SSC documents.

102 Eurostat, Tourism statistics, Trips by duration, purpose and main destination [tour_dem_tttot] for years 2023-

2024.

15

An action at the EU level will bring significant added value by:

(i.) Facilitating the application of SSC rules, free movement and fair labour mobility in

the single market. An EU action will improve proof and verification of social security rights

and insurance status, thus the access to benefits and healthcare, establishing a more supporting

environment for workers who are relocating or considering relocation within the EU. This will

similarly benefit free movement of people who wish to study, travel, reside, or do business in

another Member State. Given the cross-border nature of the existing problems, effective

solutions are best pursued at the EU level, rather than through individual efforts by Member

States. Action at the EU level will benefit mobile individuals by making their social security

rights more transparent and accessible, reducing fraudulent and exploitative practices103. It will

assist businesses operating cross-border by reducing unnecessary administrative difficulties and

complexities, while supporting national authorities by simplifying processes and strengthening

cross-border cooperation. This will enhance the understanding and implementation of rules,

facilitate their enforcement while fostering trust in the EU’s SSC framework and Europe’s

single market.

(ii.) Creating momentum in advancing European digital policies and contributing to

transforming the EU into a modern, resource-efficient and competitive economy. An EU

action will help accelerate the digitalisation of cross-border public services104, ensure a well-

functioning, integrated digital single market, ultimately benefitting European competitiveness.

By building on and reinforcing key digital EU initiatives - such as the SDGR, the Once Only

Technical System (OOTS), the EUDI framework, the European businesses wallets, the

Interoperable Europe Act, the EESSI and the European Health Data Space – an EU action will

maximise the impact of prior EU investments, being part of a coherent and cohesive EU

digital landscape that serves the interest of the EU and its Member States. If the EU does not

act now, actions by Member States would likely lead to fragmented, uncoordinated,

incompatible solutions that fail to integrate with existing EU initiatives. This could result in

suboptimal outcomes and be more costly to reverse at a later stage. An initiative in SSC could

furthermore pave the way for the adoption of similar solutions for other documents relevant for

individuals and companies in cross-border situations105.

Objectives: What is to be achieved? General objective The overarching objective of the initiative is to promote fair mobility within the EU single

market, facilitating the application of SSC rules and the access to social security rights for all

individuals, in line with the European pillar of social rights and the single market strategy. The

initiative supports the Union’s cross-cutting objectives of simplification and reduction of

administrative hurdles.

103 Garben, S., 2023, The European Social Security Pass. 104 State of the Digital Decade 2025 - Factsheet | Shaping Europe’s digital future where the percentage of digital

services to individuals and businesses are key indicators. 105 This was stressed by several participants in the High-level meeting on digitalisation in SSC. EU social partners

in the construction sector (SIDE-CIC project) have examined the digitalisation potential of the current labour and

social identity cards. One of their findings concerns the possibility of using the EUDI wallets to contain in the

future information currently provided by social identity cards/labour cards.

16

Specific objectives This intervention is structured around three specific objectives, each addressing one of the

identified problem drivers. For each objective, a corresponding reference is proposed. The

specific objectives should be read in combination with the draft performance monitoring

framework (Annex 12). Together, they outline what the success of the initiative could look like.

The specific objectives of the initiative are as follows:

- Cross-border social security cases requiring proof and verification of social security rights

and insurance status are handled with reduced manual intervention and streamlined

administrative steps, leading to faster processing. The proposed point of reference for

achieving this objective could be reduced processing times for issuing and verifying

documents.

- Cross-border interoperability is strengthened through converged documents’ formats, data

models and verification methods across the EU, enabling seamless exchange of

information and reducing fraud. The proposed point of reference for this objective could

be the alignment and use of common standards and specifications for document formats,

data models, and verification processes across Member States and the improvements in

fraud reduction.

- Individuals experience improved access to, greater awareness of, and increased control

over their cross-border social security rights and data. The proposed point of reference for

this objective could be an observable increase in user satisfaction, the use of digital

channels for accessing and managing cross-border social security information and the

degree of control over data.

What are the available policy options? What is the baseline from which options are assessed? In the baseline scenario, the issuance of portable documents within the EU is projected to

continue its upward trend106 from 2026 to 2040 due to several factors, including EU-intra

mobility107. The cross-border service provision, remote work and non-standard employment

arrangements108 are expected to support cross-border employment, thereby increasing the need

for portable documents, such as A1 and S1 and EHIC. Additionally, the demographic shifts like

EU population ageing109 and the growing number of retirees seeking residence in other Member

States110, will drive the request for portable documents S1, EHIC. Broader trends like growing

106 See Annex 9, table 21. 107 Annual report on intra-EU labour mobility – 2024 edition. Over the past two decades, the number of working-

age movers has steadily increased, with a notable rise since 2008. At the beginning of 2023 there were around 10.1

million working-age movers, a 2 % increase compared to 2022, higher than the average annual growth rate of 1 %

seen since 2018. 108 Eurofound (2024). Available here: https://www.eurofound.europa.eu/en/resources/article/2024/flexible-work-

increases-post-pandemic-not-everyone. Eurostat, EU Labour Force Survey. 109Eurostat, https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Population_projections_in_the_EU;

code: proj_23np 110 See Cross-border old-age, survivors’, and invalidity pensions. Report on portable document P1. In 2024, 6.4

million pension payments were made to individuals living in another EU/EFTA country or the UK (2.1 million in

17

intra-EU tourism111 and students’ and researchers’ mobility will also contribute to the demand

of portable documents and EHIC. Furthermore, policy and technological advancements, linked

to national strategies and the implementation of the SDGR112, are expected to enhance

document accessibility and processing. Overall, these factors suggest a continued rise in

portable document and EHIC issuance (Table 1). This trend will subsequently necessitate a

higher volume of verifications by national authorities and healthcare providers.

Table 1. Number of portable documents A1 and EHIC issued in 2023 and estimated in 2040 (EU)

EHIC portable document A1

Issued in 2023 28.5 m 5.2 m

Issued in 2040 32.8 m (+15%) 10.8 m (+106%)

Cumulative (2026-2040) ~465 m ~128 m

Source: Study on digitalisation in social security coordination

EU digital initiatives relevant for SSC are assumed to continue to be in force and implemented.

However, these initiatives will not address the specific problems identified.

Member States are expected to complete the implementation of EESSI by mid-2026. This will

further facilitate exchanges among institutions, including linked to some of the portable

documents; however, it will not resolve the challenges currently encountered by individuals,

businesses, labour inspectors, and healthcare providers. Further details are provided in section

0. and Annex 11.

Member States will continue implementing the SDGR and the OOTS. It is expected that they

will finalise the provision of fully online procedures for portable document A1 and the EHIC,

with more countries anticipated to introduce the possibility of electronic versions of the EHIC.

However, the format of the documents is expected to remain diverse as the Regulation provides

Member States the flexibility to choose their own output format, while still adhering to certain

requirements. Additionally, the described problems related to cross-border verification will not

be addressed by national solutions or bilateral agreements, which fails to provide a unified

approach valid across Europe113. The digitalisation of portable documents not explicitly

covered by the SDGR114 will likely be even more limited and fragmented. The pace and extent

will vary significantly by Member State and document type, based on feedback received115.

2016), for a total expenditure of around 31 billion euro. Data suggests that the number of exports will increase in

the coming years (see 2023 Annual report on intra-EU labour mobility). 111 See section 0. 112 See Digital Decade 2025: eGovernment Benchmark 2025. Even though 88 % of public services are available

online to national users, cross-border users can access only 56 % of those services digitally. 113 See ELA study on portable document A1 tools for examples of cooperation, for instance among neighbouring

countries such as France and Luxembourg or Finland and Estonia (data exchange agreement). 114 All portable documents except from portable documents A1 and P1 and EHIC. 115 Feedback from members of the Administrative Commission, as part of the Study on digitalisation.

18

Member States will progressively implement standardised EUDI wallets for all EU citizens,

residents who choose to use them by December 2026116. Large-scale pilot projects tested the

technical specifications and software prototypes for the EUDI wallets across various sectors,

with a project - DC4EU - piloting the wallet's use for the portable document A1 and the EHIC.

However, since the EUDI Regulation leaves the issuance of sector-specific attestations to the

discretion of Member States and the sectors, the independent national issuance of the portable

documents and the EHIC within the EUDI wallets by individual countries is neither desirable

nor expected. This is because such unilateral actions - without uniformity in formats, standards

and rules - could pose challenges regarding the acceptance and verification of these documents

in other countries with consequences for the rights of individuals117.

The Interoperable Europe Act establishes structured EU cooperation on interoperability,

introduces mandatory assessments to evaluate the impact of changes in IT systems, promotes

the sharing and reuse of interoperable solutions through the Interoperable Europe Portal, and

provide innovation and support measures for policy experimentation. Being the Act a

horizontal framework, its implementation alone will not resolve the cross-border sector-specific

challenges identified in the report.

A targeted revision of the EU social security coordination regulations (EC) 883/2004 and

(EC) 987/2009 was agreed between the European Parliament and the Council118. The revision

will further strengthen collaboration and information exchange between institutions concerning

portable document A1, notably about the dialogue and conciliation procedure when fraud or

error is suspected. However, it will not solve the problems identified related to proving rights

and verifying the validity of documents. Similarly, the initiative to reinforce the European

Labour Authority (ELA) will strengthen this authority but will not address the specific issues

and objectives of the ESSPASS initiative.

The proposal for a public interface connected to the Internal Market Information System

(IMI) for the purpose of posting declaration (e-Declaration), which has been provisionally

agreed by the co-legislators,, aims at simplifying and streamlining the processes for companies

to post workers to participating Member States. However, challenges related to portable

document A1 procedures, including different information requirements across countries, which

fall under the scope of EU SSC rules, will persist.

Additionally, in the baseline scenario, the persistent reliance on uncoordinated national

solutions for portable A1 verification across Europe will further result in a fragmented

landscape, forcing authorities to navigate varying approaches. Similarly, EHIC verification is

set to continue consuming time and resources, leading to significant financial consequences

from 2026 to 2040. As the digitisation efforts mentioned above will not address problems

associated with cross-border verification, the projected total negative financial consequence for

116 The impact assessment for the EUDI framework estimates the total costs for public authorities to range between

EUR 850 million and 910 million. 117 Sector specific legislation was adopted or proposed which provide for the use of EUDI wallets, like the

Directive (EU) 2025/2205 on driving licences and the proposal on the EU digital travel application. 118 See footnote 4. The revision concerns the coordination rules in the area of economically inactive citizens' access

to social benefits, long-term care benefits, unemployment benefits and family benefits, recovery as well as the

conflict rules on applicable legislation. A formal approval of the Council is still pending.

19

verifying documents is expected to range from EUR 34 million to EUR 90 million119 for EHIC

(in particular for healthcare providers) and EUR 32 million to EUR 86 million for portable

document A1 during this period (in particular for labour inspectorates)120. Businesses will face

labour expenses during inspections estimated at EUR 28 – EUR 76 million121. Situations where

individuals must pay upfront for unplanned medical treatments due to unaccepted EHICs will

continue. This will temporarily strain their finances, with costs estimated to be roughly between

EUR 54 and EUR 58 million. Estimated costs for filing claims are approximately EUR 1.5 –

EUR 1.7 million euro. The risk of fraud and errors in social security systems will remain a

concern, aggravated by fragmented control measures. For portable document A1, the annual

number of fraudulent cases (false portable document A1s only) is estimated at around 3,900

across the EU, resulting in a cumulative of 60 000-96 000 cases over the period 2026–2040122.

Indicative estimates place costs related to false portable document A1s at EUR 112 million to

EUR 181 million euro for the period 2026-2040123. For the EHIC, based on an estimated 2,000-

20,000 cases of inappropriate use per year, the cumulative number for 2026–2040 is projected

at 30 000-300 000 cases, translating into fraud up to EUR 150 million for the EU. Further

details are provided in Annex 9.

Regarding data protection and privacy, the GDPR will continue to serve as the foundation

for compliance. However, the presence of various national solutions might result in

discrepancies in how safeguards are applied and lead to different levels of security and trust in

digital systems.

Description of the policy options The ESSPASS initiative aims to cover all portable documents and the EHIC124. A phased

approach will be considered, allowing implementation to start one year after the date of

application of the proposed Regulation with the portable document A1 and three years after the

adoption with the EHIC. This builds on the technical feasibility and relevance of these

documents which have already been well established through pilot testing. This prioritisation –

supported by the outcomes of the pilot projects, the European Parliament125 and the vast

majority of stakeholders who responded to the public consultation126 - ensures smoother

adoption, enabling national authorities to build practical experience and focus on documents

with the highest impact. The extension to the other portable documents would occur three years

after the adoption, except for those documents for which digitalisation under ESSPASS would

not provide added value. This will be determined by an assessment, conducted with the support

119 This accounts for the growth scenario where checks increase with cross-border activity. It results in slightly

higher cumulative baseline costs (~EUR 90 million) rather than the simple multiplication of annual costs (i.e.

15*5,6 = 84). 120 See Annex 9 for details on calculations and explanations on ranges. 121 Ibid. 122 The absence of reliable data on the financial impact per fraud case makes any estimate of cumulative costs

highly uncertain. 123 These are costs to the budget due to unduly received benefits. 124 The public consultation revealed the top priorities for digitalising social security coordination documents, with

the European Health Insurance Card (EHIC) topping the list at 143 votes (88%). This was followed by the portable

documents A1 (86 votes, 53%), the S1 (81 votes, 50%) and the S2 (56 votes, 35%) for planned medical treatment

abroad. 125 European Parliament, 2021, Resolution of 25 November 2021 on the introduction of a European social security

pass for improving the digital enforcement of social security rights and fair mobility. 126 See Annex 2.

20

of Member States, namely via the newly established Ad hoc group of the AC on ESSPASS.

The assessment will cover:

- operational relevance, scalability factors, economic viability;

- transaction volume;

- cases where digitalisation is not justified.

The selection of options for detailed assessment builds on the outcomes of the pilot activities127,

insights of the stakeholders responsible for the future implementation of ESSPASS and

considers a number of additional factors, including:

- The coherence with EU policy objectives, the EU’s simplification and digitalisation

agenda and the digital ready policymaking128.

- The reliance on EU initiatives that already provide a foundation for ESSPASS to

build upon, notably the SDGR, the OOTS, the EUDI framework, potentially the future

European Business wallets, and the Interoperable Europe Act. Building on these

initiatives ensures coherence with the broader EU framework and adheres with the

proportionality principle, employing a cost-effective strategy for minimising costs,

optimising resources efficiently.

- The EU shift towards user-centricity and privacy-by-design principles, ensuring

that individuals have complete control over their personal data129. Direct, easy access

to information and documents related to social security status in cross-border

situations empowers individuals to readily understand and exercise their rights.

- The need to address the digital divide - disparities in technology access, usage, and

benefits across regions and groups - to ensure inclusivity, along with high standards of

data privacy and accessibility130.

In all selected options a dual system – combining both digital and non-digital solutions – would

remain a permanent feature. There would not be formal phasing out of non-digital support, so

that physical documents’ formats continue to be available alongside digital ones. This approach

is intended to ensure inclusiveness and genuine freedom of choice for users, in line with the

European declaration on digital rights and principles.

The analysis assessed sub-options, distinguishing between voluntary and mandatory

implementation by Member States of the proposed solutions. However, the voluntary sub-

options were considered less effective and therefore are not presented in the main report, but

only in Annex 4.

A high-level description of the main features and requirements of the selected options are

presented in the following sections. The detailed technical design and governance arrangements

would need to be defined later during implementation.

127 More details on these activities and the results are provided in Annex 10. 128 Interoperable Europe Act and Better Regulation. 129 EU Declaration on Digital Rights and Principles. 130 This was also supported by respondents to the public consideration (see Annex 2).

21

The intervention logic is presented in Annex 12.

Policy option 1: Enhanced social security coordination documents

This option would establish a solution to enhance portable documents and the European Health

Insurance Card (EHIC), enabling their revocation and digital verification across borders. The

implications of this option are as follows:

- Social security institutions or other designated bodies across EU countries will issue the

portable documents, like portable document A1, and the EHIC in a standardised

format enhanced with verifiable digital security features (e.g. PDFs with QR codes

providing machine-readable access to the encoded information), which can be either

printed or stored electronically. Authorised issuing institutions will be registered in a

publicly available trust registry, containing also their digital certificates, to allow

verifiers to automatically confirm that the issued documents are authentic and have not

been tampered with.

- Individuals will have the autonomy to choose how they want to store and present their

documents, either in a physical format (e.g. printed on paper or even potentially on a

plastic card), or stored electronically in their smartphones/email box.

- Verifiers, including labour inspectors and healthcare providers, will adopt devices with

software and applications capable of scanning security features, like QR codes. These

applications will read the encoded information and automatically verify the integrity,

validity and authenticity. They will also visually inspect the ID cards of the individuals,

as is currently done in the baseline scenario.

This policy option does not rely on the European Digital Identity (EUDI) framework and does

not involve the use of EUDI wallets. It goes beyond the baseline scenario by introducing EU-

wide standardisation, digital security features and a trust registry for cross-border verification

of portable documents and the EHIC. Under the baseline, Member States are expected to

complete the transition to fully online procedures for requesting and issuing portable document

A1 and EHIC, without standardised formats and common verification mechanisms.

Policy option 2: A solution relying on the EUDI framework with non-enhanced

social security coordination documents for non-wallet users

This option involves: i.) a fully-fledged digital solution for the issuance and instant verification

of portable documents and the EHIC, relying on the EUDI framework, ii) non-enhanced

documents for non-wallet users131. Its key elements and implications are as follows:

- Social security institutions or other designated bodies across EU countries will issue the

portable documents - like the portable document A1 - and the EHIC in a uniform

standardised digital format. This default format must be suitable for use in the EUDI

wallets (i.e. structured as a public body electronic attestation of attributes, PUB-EAAs).

Additionally, they will continue to provide non-enhanced physical documents and EHIC

131 This option emerged during discussions with Member States within the framework of the AHG on EHIC

digitalisation and of the AC due to concerns of some countries on the costs of having both the EUDI solution and

the enhanced documents.

22

plastic cards (without verifiable digital security features) for those who opt not to use

the digital wallets or cannot use it.

- Individuals will be able to securely store the portable documents and the EHIC as PUB-

EAAs within their EUDI wallets. If they cannot or prefer not to use the EUDI wallet,

non-enhanced physical documents will remain available.

- Verifiers, such as labour inspectors and healthcare providers, will be technically

equipped with hardware (devices, e.g. smartphones, tablets, computers or interactive

kiosks) and software (verification application) to interact with the EUDI wallets, in

order to automatically confirm the integrity, validity and authenticity of the portable

documents and the EHIC at the time of verification. Verifiers will use the verification

application to authenticate themselves, check the needed data from the attestations and

the personal identification data (PID) of the individuals, including a portrait, all stored

in the EUDI wallet. In this way, they can also confirm that individuals are using their

own wallet, and the attestations genuinely belong to them. Verifier will not be able to

verify the authenticity, integrity and validity of the physical documents (same as in the

baseline).

- Member States will communicate to the European Commission lists of issuers and

verifiers (EUDI trust registries) and keep them up to date. These lists will be made

publicly available.

Policy option 3: A solution relying on the EUDI framework with enhanced social

security coordination documents for non-wallet users

This option involves: i.) a fully-fledged digital solution for the issuance and instant verification

of portable documents and the EHIC, relying on the EUDI framework, and ii) enhanced

documents for non-wallet users. The main elements and implications would be the same as

those of policy option 2, with one difference: for individuals who cannot or prefer not to use

EUDI wallets, social security institutions or other designated bodies across EU countries will

issue portable documents and the EHIC in an enhanced format, that can potentially be printed

(i.e. similar to policy option 1). This will improve also the security of the non-digital version of

the documents, making them resistant to forgery and misuse, and providing the means for

revocation and verification, not possible in the merely physical format. This policy option

would enable both formats to use the same technical components for the issuance and

verification, such as issuer infrastructure and verification application, eliminating the need to

replicate all elements.

Accompanying measures and data protection

The following measures132 will accompany the aforementioned policy options to ensure their

smooth implementation and strengthen their impact on EU competitiveness and simplification:

- Introducing in all Member States the option for individuals to request online and receive

electronically the portable documents not covered by the SDGR from three years after

the entry into application of the proposed Regulation.

132 See Annex 2 on the support from respondents to the public consultation.

23

- Establishing binding deadlines for national authorities to issue portable documents and

the EHIC, ensuring that these documents are available in time for use in cross-border

situations, without compromising the quality and accuracy of information133.

- Ensure the necessary convergence between national information requirements for the

portable document A1 request, facilitating potential future interoperability and allowing

for the possibility of making use of the multilingual public interface for the declaration

of posted workers (e-declaration)134 to the extent that there is a sufficient overlap

between the information requirements in the request for PD A1 form and e-Declaration,

once established. This would allow applicants to only provide the common data once

(once only principle) as requested by stakeholders135, including several Member States

during the negotiations on the e-Declaration, and in line with the overall EU objective

to reduce administrative hurdles for businesses operating across borders. Convergence

in information requirements would also ensure better alignment on checks conducted

before issuing the A1 form. Given that the e-Declaration proposal is not formally

adopted136, key elements – such as the technical design and operational framework of

the future portal – have yet to be decided. This uncertainty does not allow for the

definition of precise interoperability measures at this stage, and these will need to be

addressed once the e-declaration proposal has been adopted by the co-legislators. It is

also important to achieve outcomes that balance efficiency with fairness. Employer

organisations and business associations137 emphasised the need to streamline

procedures, reduce duplication and move towards integrated, EU-wide digital systems.

They called for a single or coherent process that brings together A1 forms, posting

declarations, ideally via one portal and on a ‘once-only’ basis, to minimise repeated data

submissions, errors and delays, while providing predictable interactions for companies

across Member States. Trade unions and social security institutions138, stressed that

simplification must not undermine legal clarity, workers’ rights or institutional

responsibilities. They supported digitalisation and the once-only principle where it

genuinely reduces fragmentation and error risks, but caution that the portable document

A1 and posting procedures have distinct legal bases, purposes and authorities involved,

and that any technical interoperability should avoid forced mergers that could increase

complexity or weaken safeguards.

- Creating a committee within the meaning of Regulation (EU) No 182/2011139 to assist

the European Commission in exercising its implementing powers. Such empowerment

is necessary in adopting uniform technical measures and maintaining flexibility to

133 This was supported by several stakeholders during the consultation process, for instance FIEC, European

Construction Industry Federation, stated that binding deadlines should be applied to the national competent

authorities for the issuance of standardised social security coordination documents. Currently, it is nearly

impossible to obtain a portable document A1 in some Member States or it takes many months before getting a

decision. 134 The tool proposed is expected to reduce by 73% the time spent on declarations. 135 See section 0 and stakeholders’ feedback (annex 2). 136 On 23 June 2026, the European Parliament and the Council have reached a provisional political agreement on

the proposed regulation. 137 BusinessEurope, BDA, Transport and Logistics Poland, DSLV (Bundesverband Spedition und Logistik e. V.),

Handwerkskammer Koblenz, Kreyenborg GmbH & Co. KG, DIHK , Chamber of Commerce / Germany. 138 This was raised, among others by ETUC, BNS Blocul National Sindical, the Austrian Social Insurance umbrella

organisation and DGB Deutscher Gewerkschaftsbund. 139 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down

the rules and general principles concerning mechanisms for control by Member States of the Commission’s

exercise of implementing powers. Available at: link.

24

update standards, as well as in ensuring a better efficiency of the decision process, and

the legal enforceability140 of decisions, such as the adoption of standards.

These measures are common to all policy options and underpin the initiative irrespective of the

preferred policy choice141. They are therefore included in the overall intervention logic (Annex

12) but are not repeated under each option, as they do not affect the comparison between

options.

The three policy options would involve the processing of personal data, requiring full

compliance with privacy and data protection rights (Article 7 and 8 of the Charter of

fundamental rights of the European Union) and the GDPR. To ensure high standards of data

protection, the options would follow the principles of data protection by design (i.e.

incorporated into the design specifications and technical architecture) and by default (applying

the strictest privacy settings, ensuring data is not accessible to an indefinite number of

individuals), and secured with state-of-the-art security measures142. Both functional and non-

functional data protection requirements (e.g. principles of data minimisation and purpose

limitation) would be unambiguously defined as part of the system requirements, with

appropriate security measures thoroughly documented. Processing activities would involve

only a limited amount of personal data, strictly essential for the intended purpose. Security

measures would be implemented for the protection of personal data in each processing

operation. Appropriate safeguards would ensure accessibility and prevent indirect exclusion of

individuals143. Subject to these safeguards, all three options are considered supportive of the

rights to privacy and data protection.

Options discarded at an early stage Some alternative options were considered but not selected for detailed assessment. These

options were deemed either ineffective in addressing the identified problems, or

disproportionate in their approach:

- Building a new dedicated ESSPASS wallet. Developing a standalone ESSPASS

wallet alongside the EUDI wallet and the future European Business wallet would

conflict with the EU's goals of cost-effectiveness and simplicity, incurring redundant

140 The decisions of the Administrative Commission are not legally binding. 141 Respondents to the public consultation identified the alignment of information requirements across Member

States for requesting a portable document A1 as the measure with the greatest potential to simplify procedures,

with 77% (125 respondents) considering that it would provide some or high level of simplification. This was

followed by setting binding deadlines for competent institutions to issue requested social security coordination

documents (74%, 120 respondents) and by the introduction of a one-stop shop for requesting a portable document

A1 and submitting the posting declaration (71%, 115 respondents). 142 Data protection and cybersecurity considerations were repeatedly raised by stakeholders participating in the

ESSPASS call for evidence. Trade unions, NGOs, public authorities and individuals’ submissions emphasised that

ESSPASS implementation would need to comply fully with data protection requirements, including data

minimisation. 143 In response to the call for evidence AGE Platform Europe and the European Blind Union highlighted risks that

fully digital solutions could disadvantage older persons, persons with disabilities or digitally excluded groups if

accessibility requirements were not adequately addressed. Individuals’ submissions similarly welcomed digital

convenience but stressed the need to ensure usability across different groups. This was also raised by respondents

to the public consultation.

25

costs for national authorities, unnecessary complexity for individuals and businesses,

and potential competition with the EUDI ecosystem.

- Introducing a European Social Security Number (ESSN). A draft impact assessment

on the establishment of the ESSN was submitted to the Regulatory Scrutiny Board in

2018. The aim of the initiative was to facilitate individuals’ identification across Europe

and the verification of their social security coverage. The Board issued a negative

opinion pointing out that the need to introduce an ESSN was not sufficiently justified,

and alternative technical solutions should be analysed. The Commission’s further

assessment concluded that creating a domain-specific unique identifier was neither

relevant nor cost-effective for achieving the intended objectives. This would have

implied significant financial investments, complex technical requirements, and raised

concerns regarding data privacy, proportionality and subsidiarity, including

constitutional issues in some countries. Moreover, aspects related to people’s

identification are now covered by the EUDI framework144. In this context, the

Commission proposal on the EUDI framework initially suggested introducing a unique

identifier at the EU level. However, this suggestion was rejected during negotiations,

primarily due to concerns over data protection. The European Data Protection

Supervisor (EDPS) explicitly warned that including a unique and persistent identifier in

the digital identity system constitutes a significant interference with fundamental rights

because it could enable profiling and electronic surveillance of individuals. Such an

identifier is not a trivial technical feature from a data protection standpoint: it could

allow relations of identity data across different contexts and over time, potentially

eroding privacy protections145.

- Extending the scope and functionality of the EESSI. ESSPASS intends to

complement EESSI by addressing exchanges between individuals and social security

institutions, labour inspectors and healthcare providers – a domain EESSI does not

cover. After assessing the potential expansion of EESSI's scope and functionality, it was

concluded that this option was neither ideal nor feasible146. EESSI is a ‘closed system’,

designed exclusively for institution-to-institution exchanges and is not intended to

include or engage end users, such as individuals, employers, or non-social security

actors, like healthcare providers. The trust within the system is built on this exclusivity

by design. Moreover, EESSI was designed as an asynchronous messaging system (i.e.

not instant replies) and developed without considering the individuals or non-social

security institutions in the set of system stakeholders. Trying to use it for ESSPASS

purposes would require a costly and technically complex total redesign of the system,

resulting in significant operational disruption, while not being able to efficiently solve

all the identified problems. Nevertheless, the complementarity between ESSPASS and

EESSI has been explored, as well as some interlinked functionalities (e.g. institutions

certificates for digital signatures). Further details are provided in Annex 11.

144 S. Garben. 2023, The European Social Security Pass. 145 Formal comments of the EDPS on the Proposal for a Regulation amending Regulation (EU) No 910/2014 as

regards establishing a framework for a European Digital Identity. 146 Member States, as well as experts from the pilot projects did not consider EESSI as a possible way of addressing

the current problems linked to the request, issuance and cross-border verification of portable documents and the

EHIC.

26

What are the impacts of the policy options? The retained policy options may lead to different economic, social (including fundamental

rights), environmental and competitiveness impacts when compared to the baseline scenario.

Details on the baseline impacts are included in section 0.

The impacts are assessed over a 15-year period, which includes the initial three-year setup

phase. Therefore, it is assumed that the benefits begin to materialise after three years and

continue over a 12-year period. Benefits are evaluated qualitatively and, where data permits,

quantitatively. Similarly, costs are monetised as a priority; where this is not feasible, they are

examined qualitatively. Both benefits and costs are incremental, i.e. presented in comparison

to the baseline scenario.

The assessment covered policy options distinguish between mandatory and voluntary

implementation by Member States. The report focuses on the estimated costs and benefits of

mandatory implementation. The voluntary implementation scenarios are therefore not

discussed in the core chapters but presented in Annex 4 and included in the sensitivity analysis,

assuming a 50% participation rate among countries147, and consequently overall costs and

benefits at around half of those under full participation.

The choice to keep the voluntary scenarios out of the main narrative reflects the fact that

voluntary implementation across all policy options was assessed as less effective. Voluntary

approaches depends on Member States deciding whether or not to participate, which leads to

uneven and partial adoption. Only the more motivated or advanced Member States are likely to

take up new technologies, causing gaps where others opt out. This would mean that security

features, digital formats, verification methods are implemented inconsistently, undermining the

objective of enhancing cross-border interoperability. Differying standards and fragmented

participation would hinder seamless verification and access to social security services.

Enhanced processes and digital solutions would benefit only a subset of individuals, businesses

and administrations, and the identified objectives would not be achieved effectively at EU level.

Such partial implementation would result in fragmented processes and inconsistencies in the

way social security documents are issued and verified across Europe, creating uncertainties and

potentially significant problems for individuals’ access to benefits and healthcare148. Against

this background, the report concludes that mandatory implementation is necessary to ensure

coherent standards, full interoperability and equal treatment across Member States, while the

voluntary scenario is retained only as a sensitivity test in Annex 4.

147 This assumption is based on the pilots. Annex 4. 148 A large majority of respondents to the ESSPASS public consultation (93%) agree that a standardised digital

solution should be made available in all EU countries (with 76% strongly agreeing). The risks associated with

voluntary implementation were also highlighted by stakeholders responding to the call for evidence (Annex 2).

Trade unions such as ETUC and EFBWW raised concerns that inconsistent application of the initiative across

Member States due to voluntary or limited deployment might undermine the system's effectiveness, potentially

perpetuating enforcement weaknesses and fraud risks.

27

The analysis of impacts faces a certain degree of uncertainty due to a scarcity of quantitative

data from Member States149, limited engagement of healthcare providers in the pilot activities,

and the number of assumptions employed.

Actual expenditure will vary depending on the final technical design and national-level choices

regarding technical and organisational implementation - such as the level of (de)centralisation

in the issuer infrastructure - limiting insights into specific country-level cost estimates. These

choices will be influenced by factors like existing national administrative structures, technical

capacity, strategic policy priorities and cost-benefit considerations. Specifically for options 2

and 3, the decision regarding the implementation scenarios will largely depend on how Member

States will choose to organise themselves within the overall implementation of the EUDI

framework at the Member State level, which will not depend only on decisions within the SSC

sector. Drawing on the outcome of pilot activities, various technical implementation scenarios

are explored for policy options, considering their feasibility and likelihood of adoption.

As a result, estimates are preliminary and are based on a triangulated method that

combines data from the DC4EU project, the proof of concept on the enhanced EHIC (Annex

10), desk research, survey results, and additional stakeholder inputs150. Further methodological

details are provided in Annex 4.

The report assumes a 75% uptake rate of the European digital identity wallet. This assumption

is considered reasonably reliable, as it is grounded in the converging evidence and information

available, including a 2022 survey suggesting that around two thirds of EU citizens would be

willing to adopt a European digital identity wallet as an upper bound signal of demand, and the

EU’s policy ambition, as outlined in the Commission’s digital decade policy programme and

the European digital identity framework, to achieve up to 80% uptake by 2030. Moreover, the

assumption is further supported by the expanding use cases that will rely on the European digital

identity wallet, including its planned use for mobile driving licences, disability cards and other

sectoral applications, all of which are expected to promote widespread adoption. This

assumption was tested in the sensitivity analysis (see Annex 4).

A substantial majority of the surveyed social security institutions, 61 out of 69, have

identified potential implementation costs as the main challenge, particularly focusing on

costs related to system integration and infrastructure enhancements151. These expenditures

are primarily one-off costs expected to be amortised over an extended period. Moreover,

optimising processes and capitalising on synergies with existing initiatives is anticipated to

alleviate the financial pressure, while improving operational efficiency. For instance, reusing

reference models developed during the pilot activities, and the technical building blocks of the

EUDI framework for options 2 and 3, present opportunity for cost reduction.

149 Some countries, like Denmark, stated their inability to estimate costs and benefits, as they must await a final

and binding decision on implementing the solution. Others indicated a lack of time and resources to conduct such

estimations, while some emphasised that the uncertainty surrounding technical implementation makes it

impossible to determine costs at this stage (including Member States’ involved in the pilot activities). 150 Annex 4. 151 Survey conducted as part of the study on digitalisation in SSC.

28

Economic impacts

Economic benefits

The main expected benefits are due to anticipated cost savings from faster cross-border

verification and confirmation of the integrity, authenticity and validity of portable

documents and the EHIC and from reduced fraud. The benefits are estimated relative to the

baseline (section 0 and Annex 9)152. Thus, the figures presented illustrate the extent to which

costs are expected to decrease compared to the baseline scenario under each option. Savings

are derived by comparing the annual cost level under the baseline scenario with the lower

annual cost level expected once the proposed measures are implemented. The difference

between these two annual cost levels represents the yearly savings generated by the initiative

for the 12 years following implementation. In the first three years savings are estimated to be

zero, because of the need to set-up the system (see section 6.1.2 and Annex 4). Positive savings

from year four are assumed to recur each year and therefore accumulate over the full assessment

period.

Costs savings from faster cross-border verification

Under all policy options, verifiers would be able to verify the portable document A1 and the

EHIC in a faster way compared to the baseline, where the verification time is between 5 and 16

minutes for portable document A1 and 2 to 5 minutes for the EHIC153. However, verification

time will be slightly different for the different policy options:

- Under policy option 1 (PO1), verifiers would be able to confirm the integrity, authenticity

and validity of portable document A1 and EHIC, either in paper or electronic form, but the

visual inspection of the holders’ identity card would still be required. The overall process

is estimated to take one minute.

- Policy option 2 (PO2) would reduce the need for manual ID checks and accelerate identity

verification when documents are shared via the EUDI wallets, generating almost instant

verification (i.e. completed in a matter of seconds). No changes are anticipated in situations

where wallets are not used154.

- Under policy option 3 (PO3), there would be almost instant verification for EUDI wallet

documents and a one-minute verification process for enhanced non-wallet documents.

The estimated total costs savings for verifiers and businesses155 are outlined in table 2.

Individuals are also expected to benefit from faster checks.

The savings distribution between policy option 1 (PO1) and policy option 2 (PO2) reflects

differences in their verification processes. In PO1, all documents (“enhanced” documents) can

be verified online within a consistent timeframe, estimated to take one minute. While PO2

152 Ibid. As for the cost assumptions, the analysis applies a three-year set-up phase. Therefore, benefits begin to

materialise after these 3 years and continue over a 12-year period. 153 As noted in section 0, this does not include the time required for exchanges with the issuing institutions, such

as when there are doubts regarding validity. See Annex 4 and Annex 9, tables 8 and 14. 154 A 75% wallet uptake is assumed, while the remaining 25% of checks will continue using current methods, thus

do not benefit from the efficiency gains. 155 See the baseline section in Annex 9. Ranges are linked to constant and grow scenarios, based on the assumption

that the number of checks remains stable or increases.

29

allows for faster processing in approximately 75% of cases through almost instant verification,

the remaining 25% - which cannot be verified online (“non-enhanced”) - introduces significant

uncertainty, potential delays and additional manual efforts. These cases are likely to require

more time and resources, offsetting the efficiency gains achieved in the majority of situations.

Moreover, the lack of verifiability in these cases may create operational inefficiencies and

increase the risk of errors or inconsistencies.

Table 2: Estimated total costs savings from faster cross-border verification (cumulative for 12 years

following the initial three-year setup phase with zero costs savings million EUR)

Cost savings resulting from reduced fraud

By confirming the authenticity, integrity and validity of portable document A1 and the EHIC,

the three policy options would help reduce the risk of forged or outdated documents being used

to illicitly claim social security benefits or access healthcare services in other countries157. The

estimated total savings are outlined in table 3158.

Table 3, Estimated total costs savings from reduced fraud (cumulative for 12 years following the initial

three-year setup phase, million EUR)

156 The annual verification cost is reduced from EUR 2.24 million (baseline) to EUR 1.12 million, leading to EUR

1.12 million savings per year, i.e. ~EUR 13.45 million over 12 years. 157 In response to the call for evidence and during the hearings of EU social partners, trade unions expected the

initiative to strengthen enforcement capacity. Organisations such as ETF and EFBWW argued that real-time

verification and interoperable credentials would improve the detection of invalid or fraudulent A1 documents. 158 For the different ranges between portable document A1 and EHIC and calculations, see Annexes 4 and 9. 159 See Annex 4, page 77. The analysis considers that although the Wallet reduces fraud, its aggregate impact is

limited due to the continuing use of paper documents, leading to a conservative assumption of no cumulative cost

savings.

PO1 PO2 PO3

Portable

document

A1

Cost savings for

verifiers 22 – 68 19 – 55 24 – 72

Cost savings for

businesses (reduction of

labour costs)

20 – 60 17 – 49 21 – 64

EHIC

Cost savings for

verifiers (healthcare

providers)

13156 – 58 20 – 54 23 – 69

PO1 PO2159 PO3

Portable

document A1 89-157 No reduction 89-157

EHIC 12 to 120 No reduction 12 to 120

30

Regarding the rationale for the conservative estimate of zero fraud savings for PO2, this was

based on the assumption that while 75% of users in PO2 would adopt the European digital

identity wallet, the remaining 25% would continue relying on traditional documents or plastic

cards without digital security enhancements (‘non-enhanced’ documents, as in the baseline),

whose authenticity, integrity and validity cannot be verified online.

This coexistence was considered to limit the extent to which fraud could be effectively

prevented, as individuals falsifying documents could continue using the legacy system and

circumvent the wallet’s security measures, so in the aggregate analysis – in order not to

overestimate benefits – the volume of fraud was assumed to remain largely unchanged

compared to the baseline, resulting in no cost savings for PO2.

This contrasts with PO1, where online verification remains possible in all cases, including for

printed documents, due to the use of ‘enhanced’ documents.

These assumptions have been tested under different scenarios, as set out in Annex 4, to verify

whether they are too restrictive, including the possibility that some level of fraud could be

reduced under PO2.

Savings resulting from faster EHIC issuance and reduced up-front payments

The three policy options would reduce the time to obtain the EHIC. As the digital EHIC would

be accessed electronically, individuals could receive their EHIC more quickly following

application approval, compared to waiting for a physical card to be printed and mailed. In the

baseline scenario, this process can exceed 11 days in certain countries (section 0), while a digital

solution could reduce to just two to three minutes (99% reduction)160.

The options are also expected to decrease instances where upfront payment is required due to

card rejection, stemming from validity doubts, unreadable cards or format issues (around EUR

54-58 million in baseline, see section 0). Individuals would not need to go through the

reimbursement process (except in those countries where upfront payments are needed),

resulting in time savings. Even if people are eventually reimbursed, the reductions in upfront

payments161 have been estimated (table 4)162.

Table 4, Estimated reduction of upfront payments (cumulative for 12 years following the initial three-

year setup phase, million EUR)

160 Beyond-DC4EU-Final-Report-January-2026.pdf. 161 Potential reductions depend on the increases in the EHIC use. This indicator is not considered for a cost benefit

analysis, because the amounts will be eventually reimbursed. Therefore, the indicator expresses a negative

temporary consequence, but not a long-term impact on affected stakeholders. 162 These reductions have been excluded by the sensitivity analysis to ensure that the assessment remains

proportionate.

PO1 PO2 PO3

EHIC Reduction of upfront

payments for individuals 43 – 47 32 – 35 43 – 47

31

PO2 reductions are more limited compared to PO1 and PO3, as pre-financing will remain an

issue for non-wallet users, using non-enhanced documents (same as in the baseline).

Implementation costs

The implementation costs are a combination of upfront investments during the first three years

(one-off costs) and costs associated with maintenance and updates over a following twelve-

year operational period (recurrent costs). They are expected to be primarily borne by

national public administrations, encompassing ministries, social security institutions, labour

inspectors, and healthcare providers163, who serve as issuers and verifiers of social security

coordination documents. Individuals and businesses are anticipated to incur only limited

expenses. For those utilising a digital wallet (option 2 and 3), the primary necessity is a

smartphone, which most individuals in Europe already possesses164.

Across all policy options, IT-related expenses will account for a large share of total costs.

The analysis considers three core IT components common to all options:

- The issuing infrastructure to create, manage, distribute and revoke digital documents

– hereafter ‘digital credentials’165.

- A verifier application to check the integrity, authenticity and validity of credentials

against trusted lists - providing a ‘valid’ or ‘invalid’ result – and to validate their

schemas (structure, format and content rules). The application should also generate and

receive a proof of verification for audit purposes.

- A trust framework166 encompassing the infrastructure elements necessary to ensure

trust among all involved actors (individuals, credentials issuers and verifiers). This

includes lists of trusted issuers, verifiers and revoked credentials. The EU trusted list

infrastructure established under the EUDI framework could be reused for options 2 and

3. Option 1 requires lists of trusted issuers and revoked credentials.

Compliance and legal adjustments are another cost component, due to necessary changes in

national laws or administrative procedures for implementing the policy options.

Costs for the issuing infrastructure

Issuing digital credentials involves key tasks such as designing data models, integrating with

databases where original data is stored, extracting for transformation into a standardised

163 Healthcare providers, acting under the SSC rules, are public or private body or professionals that are legally

authorised to provide healthcare services under the legislation of a Member State and that delivers healthcare

benefits in kind within that State’s statutory social security/health insurance system. Therefore, the impact

assessment considers related costs for healthcare providers under the national social security system and not as

costs for businesses. 164 https://www.statista.com/topics/3341/smartphone-market-in-europe/#topicOverview. In 2024, 70.9 % of

people aged 16-74 in the EU reported using internet-connected devices, including smartphones among other smart

devices (Eurostat). 165 In the report, ‘digital credentials’ refer to cryptographically signed and tamper-evident claims created by an

issuer regarding a subject and instantly verifiable cross-border without needing to contact the original issuer. 166 The trust framework is assumed to build on existing national and EU systems, saving time and resources

through the reuse of current tools. Thus, costs considered only account for the specific actions required to fulfil

the initiative’s requirements.

32

format167, implementing qualified electronic signatures and EUDI issuance protocols (for

policy options 2 and 3). It also includes developing and testing the issuance system and user

interface. A list of the cost elements is available in Annex 4, table 6.

The costs for the issuing infrastructure are to be borne between the issuing institutions (or

issuers, the entities responsible for creating, signing and managing digital credentials) and the

authentic source (i.e. the authoritative system or organisation that holds and maintains the

original data). These costs will widely depend on how Member States will choose to organise

themselves in terms of which and how many organisations will issue the credentials. The

following scenarios summarise the main possibilities168:

- Issuing scenario 1 - Central state-wide issuer: A single entity issues all public

sector credentials.

- Issuing scenario 2 - Social security coordination-specific issuer: A dedicated

issuer focuses on all social security coordination-related credentials169.

- Issuing scenario 3 – Authentic source as individual issuers: each authentic

source in the various social security branches issues credentials directly, providing

flexibility and autonomy.

Although existing national setups suggest a hybrid approach between scenarios 2 and 3 as the

most likely implementation170, the significantly higher costs associated with scenario 3 may

deter Member States from adopting this decentralised scenario. Consequently, scenario 2 is

used as the reference point for cost estimates across all policy options. This approach

reflects the usual organisation of social security systems, while assuming that countries will

aim to optimise implementation and governance arrangements to minimise costs. Complete

figures for all scenarios are available in Annex 4.

Besides initial development and deployment, all policy options will incur recurrent

compliance costs for maintenance and operational support to ensure sustained reliability,

security and compliance. Maintenance cost, typically expressed as a percentage of initial

development costs, are estimated at 15%, as middle-range benchmark from existing

literature.

The estimated total EU costs of issuing portable document A1 and EHIC per policy option,

under issuing scenario 2 are outlined in Table 5171.

The costs are based on the following assumptions and calculations:

167 Countries with centralised databases may face slightly lower costs for this. According to DC4EU, these include

at least Austria, Czechia, Denmark, Estonia, Finland, France, Ireland, Latvia, Netherlands, Poland, Portugal, and

Sweden. Germany does not have such a database, and the situation remains unclear for other Member States based

on available data. 168 See Annex 4. Scenarios are based on DC4EU insight. 169 The cost assessment assumes two separate issuers: one for portable documents and another for EHIC, reflecting

their distinct organisational frameworks at the national level. This assumption aligns with the prevailing

institutional practices in many Member States. 170 While scenario 2 aligns well with existing more centralised governance structures in Member States like Malta,

Estonia and Sweden, scenario 3 would suit more decentralised structures like those in Germany and Belgium. 171 See Annex 4.

33

• The cost components included in the one-off cost calculations are the ones indicated in

table 2 and table 3 of Annex 4, for the issuers and the authentic sources respectively,

under the ‘issuing infrastructure’ cost category.

• As per definition of scenario 2, only one (dedicated) issuer is considered per Member

State.

• The number of authentic sources per Member State is derived from the current portable

document A1 and EHIC issuing institutions included in the Electronic Exchange of

Social Security Information repository.

• For the authentic sources, the costs indicated as “shared investments” in table 3 of

Annex 4 are calculated only once (per Member State) regardless of the number of

entities, while the rest of the costs are multiplied by the number of entities involved per

country.

• The recurring maintenance costs (which will happen after implementation, i.e. as from

year 4), are calculated as 15% of the one-off costs.

Table 5 Total EU costs for issuing infrastructure (cumulative for fifteen years, million EUR)

Costs for verifier application

Verifier application costs consist of two main categories: application development and verifier

onboarding. Development costs cover initial software design, coding, development, testing,

training, and deployment. Onboarding includes setting up the internal access control system,

integrating with national proxies, staff training, compliance checks and implementing logging

of verification proofs. Annex 4 presents the list of costs in detail.

The one-off development costs are expected to be similar across all options173. The verifier

application needs to be created but can use existing open-source components and insights from

the DC4EU pilot projects to avoid duplicating efforts. Successful deployment requires

authorised verifiers, such as healthcare providers and labour inspectors, to have compatible

devises like smartphones or tablets for scanning and validating credentials, which it is

reasonable to assume most entities already possess174.

172 The one-off costs for PO2 are higher than those for PO1 due to the need for an additional infrastructure layer

to securely connect credential issuance to individuals verified identities through national electronic identity

systems. The costs for PO3 are anticipated to be roughly 10% higher than those estimated for PO2. 173 Feedback from DC4EU and proof of concept on the enhanced EHIC. 174 This was confirmed by Member State representatives during interviews as part of the study on digitalisation.

In specific contexts, such as smaller clinics or regional healthcare providers with limited digital capacity, only a

few purchases of smartphones or tablets may be necessary. These costs are expected to be minor and negligible

compared to broader infrastructure or software deployment expenses.

PO1 PO2 PO3

One-off cost172(initial 3 years)38.5 44 48.5

Recurring costs (starting from

year 4)69.6 78 85.2

34

Cost variations will primarily depend on implementation scope, as well as additional features

and integration levels into national systems. The roll-out of the verifier application could

follow three scenarios:

- Verifier application scenario 1 – Single common application for all Member States

in the social security coordination sector: An EU-developed application, with local

language options and minor national configurations would maximise efficiency and

interoperability, minimising duplication, but requires robust governance to manage

updates, maintenance and align with national contexts.

- Verifier application scenario 2 - Single base application adapted for each Member

State: An EU-developed application customised by each country, balancing efficiency

and flexibility, thus enabling adaptation to specific national contexts.

- Verifier application scenario 3 - Separate national application(s) developed in

parallel: Each Member State develops its own application(s) based on common

standards, allowing greater national customisation but leading to higher costs.

Scenario 1 offers the lowest cost but is unlikely to occur as it would face significant governance

hurdles175; consequently scenarios 2 and 3 are considered more feasible.

The set-up costs for the verifier application can be confidently estimated, drawing on insights

from the DC4EU pilot, the proof of concept on enhanced EHIC, other stakeholder input and

available literature. The one-off development cost for a single verifier application is estimated

at EUR 150,000 for all policy options176, with total EU application development costs

summarised in Table 6. Table 6 Total EU one-off costs for application development (initial three

years, for all policy options, million EUR)

Total EU one-off costs for application development

Verifier application scenario 2 –

single base app adapted for each

Member State177

1.6

Verifier application scenario 3 –

one app per Member State178

4

One-off onboarding costs are estimated at EUR 36.000 per verifier179. This number includes

all the elements indicated in table 5 of Annex 4 under the cost category “Verifier Application”.

Total EU one-off onboarding costs depend on the total number of verifiers in the EU. This

number is more complex to define as it will depend on the organisation of the diverse and

175 This was confirmed during a Working Party of the AC on ESSPASS. 176 Input from DC4EU, the proof of concept on enhanced EHIC and interview with Denmark as part of the study

on digitalisation in SSC. This estimate is consistent with stakeholder inputs and typical costs for applications of

similar complexity suggesting costs of EUR 185,000 to EUR 200,000 (see Annex 4). 177 This includes only the costs for adapting the EU-developed app at Member State level (thus excluding the costs

of the components developed centrally and reused as-is). 178 This considers the costs of the full development of one app per each Member States. Calculations based on data

provided by DC4EU. 179 Based on inputs from DC4EU, see Annex 4.

35

numerous verifiers. While this might be simple for portable document A1 (due to the fewer

potential verifiers), it is considered one of the most challenging aspects180 for EHIC, given the

vast number of potential verifiers across thousands of clinics, hospitals and practices.

Two illustrative extreme possibilities are considered for onboarding for both portable

document A1 and EHIC: (i) a single central verifier per country, such as a national

inspectorate or a central authority for all healthcare providers, and (ii) multiple decentralised

verifiers, like hospitals181. Figures for these two possibilities are presented in Table 7. The

figures in table 7 are calculated as follows:

• The table contains the total costs for portable document A1 and EHIC, both for the

development of the application and the onboarding of verifiers.

• For the rows related to ‘one single central verifier’, one verifier per Member State is

considered for each document (one for portable document A1, one for EHIC);

• For the rows related to ‘multiple decentralised verifiers’, it is assumed:

o For portable document A1, one verifier per region is estimated, for a total of 381

regions. These regions do not correspond to statistical regions but rather reflect

administrative organisations and how the system would likely be implemented

in practice.

o For EHIC, a total of 10000 verifiers (healthcare providers, hospitals, etc.) is

estimated.

Table 7 Total EU one-off costs for application development and verifiers onboarding (initial three years,

for all policy options, million euro)182

Total EU one-off costs for application development and verifiers onboarding

Verifier application scenario 2

One single central

verifier 5.2

Multiple

decentralised

verifiers

~ 373

Verifier application scenario 3

One single central

verifier

10

Multiple

decentralised

verifiers

~378

Given the wide variety of the costs depending on the number of verifiers, for the calculation of

a reference estimate, the analysis assumes Member States will seek to streamline

180 Inputs from Member State representatives as part of the study on digitalisation and in regular AC meetings. 181 For portable document A1, the decentralised scenario assumes regional labour inspectorate offices, for the

EHIC individual hospitals (approximately 10,000 public hospitals acting as verifiers in total). 182 Calculations based on data provided by DC4EU. See Annex 4.

36

implementation and contain costs, particularly for EHIC, which has a large and fragmented

verifier landscape. Hospitals in Europe often use shared management structures within the same

cities or regions. Accordingly, the reference estimate for EHIC does not assume one verifier

per healthcare provider, which would result in disproportionately high costs, but rather a more

aggregated verification model, with approximately one shared verification infrastructure every

four hospitals.

Based on this, the total estimated one-off EU costs for application development and verifier

onboarding are about EUR 107.7 million, consistent across the three policy options183.

Recurrent maintenance and update costs of verifier application are estimated at 15% of

development costs annually (Table 8).

Table 8 Total EU recurrent costs for verifier application (12 years as from year 4, for all options, million

EUR)

Total EU recurrent costs

Verifier application scenario 2

One verifier 9.4

Multiple verifiers 672.5

Verifier application scenario 3

One verifier: 18

Multiple verifiers 677

Costs for trust framework

Establishing the trust framework involves only one-off costs related to key components which

are assumed to apply across all policy options, as detailed in Annex 4 (elements under “Trust

framework” cost category in tables 2, 3 and 5). Overall costs are expected to be comparable

across policy options (Table 9)184.

Table 9 Total EU one-off costs for trust framework

One-off costs for trust framework (for all policy options, million EUR)

Social security institutions 1.2

Other administrations

(portable document A1

verifiers)

One verifier 14

Multiple verifiers

(assuming one verifier per

region)

15

One verifier 15

183 This assumes one verifier per region (for portable document A1) and one verifier every four hospitals (for

EHIC). See Annex 4 for an explanation of these assumptions. 184 See Annex 4 for all assumptions and calculations.

37

One-off costs for trust framework (for all policy options, million EUR)

Healthcare providers

(EHIC verifiers)

Multiple verifiers

(assuming 10000 public

hospitals)

44.5

Total 29.5 – 61

Legal and regulatory adaptation

The one-off costs such as amending national legislation or conducting data protection impact

assessments under the GDPR are not expected to be substantial. They are comparable across

policy options and estimated to range between EUR 600 000 and EUR 700 000 for the EU185.

Overall summary

The overall summary of the reference estimates costs for policy options (PO) is presented in

Table 10186.

Table 10. Summary of total EU costs (million EUR)187

185 Ibid. 186 A more comprehensive table is available in Annex 4. 187 All the costs included in the table refer to mandatory implementation of the policy options. One-off costs refer

to investment costs incurred once (upfront). Recurrent costs are annual costs, which are presented in the table on

a cumulative basis. These have been calculated by multiplying the annual costs by 12 years, reflecting the

assumption of a three-year set-up period before the recurrent costs start to apply.

Core

components

Frequency PO1 PO2 PO3

Issuing

infrastructure

One-off 38.5 44 48.5

Recurrent (cumulative) 69 78 85

Verifier

application

One-off 107.7

Recurrent (cumulative) 193

Trust

framework

One-off 29.5 - 61

Recurrent (cumulative) n/a

Compliance

and legal

adaptation

One-off 0.6 – 0.7

Recurrent (cumulative) n/a

Total one-off 176 - 208 182 - 213 186 - 218

Total recurrent (cumulative) 262 270 278

Total 438 - 470 452 - 483 464 - 496

38

Source: Based on the study on digitalisation in social security coordination

Other economic impacts

Impact on competitiveness and the single market

Impacts on competitiveness are mainly assessed qualitatively based on stakeholder consultation

and sectoral evidence188. The three policy options are expected to positively impact businesses

operating within the single market, especially those posting workers abroad. The measures

common to all policy options - specifically setting deadlines for issuing portable documents

A1, bringing convergence in information requirements across Member States, facilitating future

interoperability between national portable document A1 portals and the forthcoming EU portal

for posting declarations (e-declaration) – along with improvements in the verification processes

(see section 0)189 - are anticipated to ease businesses’ compliance with requirements and

operations. These measures should result in administrative simplification by reducing hurdles,

diminishing reliance on external consultants, shortening A1 form wait times – currently 2 - 4

weeks or longer in some countries190 - and reducing repetitive information submission191.

SMEs, which make up 99% of EU businesses192 and are prevalent in sectors where posting

activity are more common – such as construction193, services sector194 - are expected to benefit

more than large companies. They tend to face more difficulties in complying with portable

document A1 requirements due to limited administrative capacity compared to larger

companies195. Complexity and requirements for cross-border service providers when posting

their workers abroad rank prominently among the barriers identified during stakeholders’

consultations, workshops and reports on the single market. Administrative simplification helps

reduce barriers to the free movement of people and services, thereby encouraging businesses to

expand their operations across borders196.

Improved cross-border access is likely to attract investment, fostering economic growth and

contributing positively to overall market competitiveness, though the magnitude cannot be

precisely quantified (see Annex 5).

188 See Annex 2. 189 Business Europe called for ESSPASS to help reduce the administrative burden faced by employers: 2025-01-

22_businesseurope_mapping_of_regulatory_burden-d55-1.pdf. 190 See section 0. 191 During the Single Market Strategy’s consultations, stakeholders advocated for simplifying SSC procedures

through digitalisation, Single Market Strategy - Synopsis report. See sta 192 https://www.europarl.europa.eu/erpl-app-public/factsheets/pdf/en/FTU_2.3.2.pdf 193 FIEC reported that construction industry generates about 7.9% of EU GDP and provides more than 12 million

jobs – that is, 6.4% of EU total employment. Among its 3.8 million enterprises, 95% are SMEs with less than 20

workers. Whereas the construction industry is first and foremost a local-based industry, construction workers

represent a very significant share of the posted workers. 194 Posting of workers Report on portable document A1 issued in 2023, page 32. 195 In a position paper, SME United stated that effort involved for SMEs with the A1 form is generally

disproportionate to the service provided, welcoming the introduction of ESSPASS. See section 0. 196 See SMET report https://ec.europa.eu/internal_market/smet/_docs/2024/smet-report-2024_en.pdf: the impacts

of some of the administrative requirements and complexities are discouraging the free movement of services in

the Single Market and thus shrinking the positive contribution of the Single market to the competitiveness and

resilience of the European economy.

39

PO3 is anticipated to have the highest impact on competitiveness (+++), as faster documents

verification reduces costs and administrative hurdles for companies, thereby making them more

competitive.

Impact on digitalisation and innovation spillovers

The three policy options offer distinct contributions to the EU’s broader digitalisation and

innovation objectives, particularly in terms of alignment with electronic digital identity and

interoperability standards, the reuse of existing building-blocks and solutions, and the

innovation spillovers across sectors and borders.

PO3 is expected to have the most positive impact due to its comprehensive approach:

standardisation of processes across Member States for both EUDI wallet-based and enhanced

physical credentials. This promotes both innovation and inclusivity, setting a strong foundation

for building on existing EU digital solutions (see coherence analysis in Chapter 0) while

ensuring accessibility for those not yet ready to utilise digital tools. It would contribute to the

2030 digital decade goals, notably by helping accelerate the digital transformation of cross-

border public services and the use of electronic identity means,197 and to the completion of the

EU digital single market198. It would also support the Commission’s innovative agenda seeking

to boost competitiveness through initiatives like the 28th regime, thanks to streamlined digital

processes facilitating companies’ operations across borders. Although it is not possible to

estimate the exact size, even assuming the smallest reasonable impact, the option would still

make a significant positive difference relative to the baseline.

Social impacts Compared to the baseline, the three policy options are expected to have an overall positive

social impact, including on fundamental rights. They should facilitate the coordination of

social security systems by easing the access to social security benefits and healthcare across

Europe (Articles 34 and 35 of the Charter of fundamental rights of the European

Union), through improved proof and verification of social security rights and insurance status

of individuals moving across the EU199. No reduction in the baseline level of protection has

been identified.

By ensuring social security rights and entitlements are more easily verifiable and transferable

through simplified procedures and reduced administrative processing times, the options are

expected to have a positive impact on the effective exercise of free movement of persons and

workers - under Article 45 of the Treaty on the Functioning of the European Union (TFEU)

and Articles 15 and 45 of the Charter of fundamental rights of the European Union (see section

197 The eGovernment Benchmark 2025 emphasise that cross-border digital services are essential for an integrated

digital single market and for individuals and businesses mobility, but significant challenges remain. These services

remain consistently less mature than services for national users. There is roughly a 25-point gap between national

online availability and cross-border availability for key services. Cross-border users still face interoperability

issues, such as lack of harmonised electronic identification (eID) acceptance from other Member States. 198 According to a study of the European Parliamentary Research Service, completing the digital single market

could generate benefits of around 110 billion euro annually. 199 This was confirmed by stakeholders participating in the call for evidence and public consultation. See Annex

2.

40

0200 and 6.1.1) and the freedom to provide services, as enshrined in Article 56 of the TFEU

and Article 16 of the Charter. Workers would be more likely to take advantage of cross-border

job opportunities and businesses more eager to operate across-borders201. The options do not

introduce any limitations on these freedoms.

The options are anticipated to facilitate easier verification of social security entitlements

throughout Europe, by enabling authorities to instantly confirm the validity of social security

documents and by promoting the use of common standards and procedures. This, in turn, would

strengthen effective compliance with applicable rules, support more timely enforcement

actions, thereby reducing opportunities for fraud, abuse and social dumping.

Receiving directly requested portable documents A1 would enhance transparency and fairness

in working conditions, providing workers with a clearer understanding of their rights and

entitlements related to social security when posted abroad. With full knowledge of their

social security arrangements, workers become less susceptible to fraudulent practices. They

also gain easier access to benefits they might be entitled to in the host country202, helping

maintain a standard of fairness where workers receive the protections and benefits due to

them (see sections 0 and 0).

Stakeholders emphasised the importance of enhancing user-centricity and have strong data

protection requirements203. Under policy option 1, the use of QR codes for document

verification would necessitate strong safeguards to mitigate risks related unauthorised scanning

of QR codes and potential tampering with the code's data. Policy Option 2 would prioritise the

highest privacy-by-design features with EUDI wallets and full control over data as individuals

would be able to share what is strictly needed for verification, have easy access to all their data

and shared them upon consent. However, it would not improve protection where non-enhanced

documents are used. Policy Option 3 is expected to bring the highest positive impact,

enhancing data protection by giving users control, minimising data exposure, and ensuring

GDPR-compliant, secure, and transparent handling of personal data when using EUDI wallets

and benefitting from legal safeguards when relying on enhanced physical attestations.

The three options are also likely to have a positive impact on the right to good administration

under Article 41 of the Charter of fundamental rights of the European Union. By simplifying

procedures and reducing processing times, the options are anticipated to ensure that requests

and operations are handled within a reasonable time, enhancing legal certainty for individuals

and businesses.

The options would enhance trust in cross-border public services, including through

increased transparency. Survey evidence suggests that a solution for instant verification of

200 Draghi report on the future of European competitiveness. See What is the problem? 0. Respondents to the public

consultation also confirmed that (Annex 2). 201 See section 070. 202 This was highlighted by stakeholders in response to the call for evidence on ESSPASS. EurECCA and ETF

reported cases where individuals faced difficulties accessing healthcare due to verification failures and considered

ESSPASS capable of mitigating such situations. 203 Surveys and interviews as part of the study on digitalisation. Among 71 survey respondents, 38 highlighted the

importance of increased user control, while interviewees emphasised strong data protection and granular access

control as crucial for public trust.

41

portable documents and the EHIC would promote equal access to services204, reducing the

risk of indirect discrimination under Article 21 of the Charter of fundamental rights of the

European Union and ensure accessibility and fairness so that everyone, including people with

disability, can participate on an equal basis.

Policy Option 3 ensures a greater positive social impact by fostering inclusion and fairness

for all individuals, thus increasing trust. It achieves this by combining the advantages of

using standardised EUDI wallets - with offer robust cryptographical security - with (printable)

enhanced credentials that adhere to consistent verification standards, as an alternative for those

who prefer not to or are unable to use digital tools. Consequently, it is expected to result in

fewer problems and facilitate smoother access to benefits and healthcare services.

Environmental impacts The environmental impacts of the three policy options are positive because of reduction in the

use of physical documents and plastic cards due to digital requests, issuance, and verification

of documents, cutting down physical document handling, and reducing in-person office visits.

For the EHIC specifically, substantial reductions in plastic card issuance are anticipated for all

mandatory options, with quantifiable impacts calculated based on key assumptions205. Under

policy option 1 and 3 transitions from plastic EHIC cards to electronic versions, is assumed to

reduce plastic use by up to 1,482 tonnes and saving up to 161 million euros. Policy Option

2 combines plastic and wallet-based digital credentials, leading to reductions in plastic usage

of up to 1,012 tonnes, with savings of up to 124 million euros.

The report assumes the full phasing out of plastic cards under PO1 (replaced by pdf documents

enhanced with QRcode) and PO3 (replaced by wallet-based and pdf enhanced with QRcode

documents), whereas PO2 retains plastic EHICs for non-wallet users.

Although increased use of digital solutions may raise energy consumption, stakeholders

consulted did not consider such impacts significant.

How do the options compare? This section evaluates the relative performance of each policy option by assessing their

effectiveness in achieving the objectives, their efficiency regarding cost-benefits ratios, and

their coherence with broader EU policy objectives. The options are scored on a scale from '-

/+' to '---/+++' based on their impact relative to the baseline. A single '-/+' indicates a minor

effect, while ‘--/++’ and '---/+++' signal a moderate and significant impact respectively. The

measures common to all policy options are expected to increase the performance for all

considered criteria.

204 Survey and interviews as part of the study on digitalisation. Approximately 39 out of 71 of survey participants

strongly concur that implementing a real-time verification solution would significantly enhance trust levels.

Additionally, 38 respondents strongly agree that such a solution would empower individuals with greater control

over their personal data. 205 See Annex 4. The use of digital tool may increase energy consumption, but such impacts were not identified as

significant by stakeholders consulted as part of the study on digitalisation in SSC.

42

Effectiveness

While each option is expected to achieve the defined policy objectives (sections 4.1. and 4.2.),

they demonstrate varying levels of effectiveness. Options are assessed along different

dimensions (table 11).

For the specific objective 1 (S01), all policy options successfully streamline processes and

reduce manual interventions; however PO3 offers the most comprehensive improvements

and the broadest potential for simplification compared with the baseline (+++), while

recognising that the actual impact will ultimately depend on the level of wallet uptake. The

digital verification of documents, whether stored in the EUDI wallets or as enhanced physical

documents, is expected to significantly reduce the length of processing time and manual

interventions required206. The verification is estimated to take only a few second for wallet-

based credentials and around 1 minute for enhanced non-wallet documents documents whereas

under the baseline the verification time is between 5 and 16 minutes for the portable document

A1 and 2 to 5 minutes for the EHIC. The effectiveness of the PO1 is assessed as medium (++),

as time is still needed for the visual inspection of ID documents (around one minute). PO2 is

considered less effective (+) because paper-based processes continue to exist whenever the

EUDI wallet is not used, meaning that the same verification challenges as in the baseline will

persist and constrain the overall reduction in manual operations and processing time. This

despite the gains expected when the wallet is used, with an assumed 75% rate of wallet use and

25% non-use, which further underlines the compatively stronger performance of PO3 in

achieving S01. Regarding specific objective 2 (S02), which targets the strengthening of cross-

border interoperability through the convergence of documents' formats, data models, and

verification methods across the EU, both PO1 and PO3 scores positive compared to the

baseline by ensuring consistent standards across digital and physical formats, thereby

improving interoperability and reducing fragmentation in how credentials are issued and

verified. However, PO3 goes further by embedding a stonger level of security in data exchange

and fraud resistance, combining high identity assurance with robust cryptographic verification

within EUDI wallets, which directly supports high cross-border interoperability (+++). The

effectiveness of PO2 is assessed as minor (+) only because it does not sufficiently address

vulnerabilities linked to the continued used of purely physical format. By not implementing

standardised formats, data models and verification processes for scenario where EUDI wallets

are not used, PO2 leaves gaps in interoperability and trust. Moreover, from a fraud-prevention

perspective, PO2 is less effective, as individuals intending to commit fraud are likely to

circumvent wallet-based solutions and rely instead on non-standardised, purely physical

documents, which are more difficult to systematically verify.

For specific objective 3 (S03), concerning the enhancement of user-centricity, awareness,

and control over data, P03 is assessed as having the highest effectiveness (+++). This policy

option significantly empowers individuals and businesses by placing users firmly at the centre,

ensuring they can choose how to access and present their credentials, while still benefiting from

secure, privacy-preserving verification when using the wallet. It guarantees universal access to

services, accommodating the needs of all users and preventing the marginalisation of those who

are either unable or prefer not to use digital tools. This includes persons with disabilities, older

persons, or others who may face barriers to digital access. At the same time, the use of EUDI

206 95% of respondents to the public consultation believe that using the European digital identity wallets would

simplify storage and verification of social security coordination documents.

43

wallets provides stronger data control and transparency, as users can decide which data is shared

and with whom, and can rely on trusted verification mechanisms providing reassurance that the

verifier is a trusted entity. PO1 is rated at a medium level of effectiveness (++). While PO1

offers enhanced documents that can be either printed or stored electronically, and verifiable in

all cases, it does not provide advanced user-centricity features, as it does not support granular

user control over data sharing (for example selective disclosure of attributes) or real-time

consent management, nor does it systematically reassure users that the verifier is a trusted entity

within a regulated ecosystem. As a result, although PO1 improves reliability and accessibility

of documents, it falls short of fully empowering users in terms of privacy, transparency, and

control over their data. PO2 is assessed as less effective (+), primarily because its benefits are

limited to scenarios where EUDI wallets are actually used. In wallet-based interactions, PO2

can improve user-centricity by enabling secure storage and verification of documents, and by

allowing users to manage their credentials within the wallet environment. However, in

situations where users do not use a wallet, PO2 relies on non-enhanced documents that do not

offer additional features for data control, selective disclosure, or assurance regarding the

identity and trustworthiness of verifiers. This creates a clear disparity in user experience: users

with wallets benefit from improved control and transparency, while non-wallet users see no

substantive change compared with the baseline, thereby limiting the overall effectiveness of

PO2 in enhancing user-centricity. In summary, PO3 is more effective because it systematically

combines the advantages of EUDI wallets with inclusive, non-digital options, ensuring both

high levels of control and awareness for wallet users and equitable access for non-wallet users.

PO1 delivers important improvements in document reliability but lacks advanced mechanisms

for user control and trusted verification, and PO2’s benefits are constrained to wallet users,

leaving non-wallet users without meaningful enhancements in user-centricity.

Table 11. Overview of effectiveness rating of policy options against the baseline

S O

1

Options PO1M PO2M PO3

Rating ++ + +++

Criteria for

comparing

options

- reduction in processing time for requesting, issuing and verifying

documents (faster processing)

- extent to which manual interventions are minimised

S 0

2

Options PO1M PO2M PO3

Rating ++ + +++

Criteria for

comparing

options

- use of standard formats and verification,

- ease of access to social security benefits and healthcare,

- level of security in data exchange.

S O

3

Options PO1M PO2M PO3M

Rating ++ + +++

44

Efficiency

Efficiency is evaluated in terms of the benefits of each option relative to its associated costs.

Because not all benefits can be expressed in monetary terms, efficiency assesment takes into

account also non-monetised benefits, such as social benefits, including better access to social

security and healthcare services, enhanced fairness, and the safeguarding of fundamental rights,

competitiveness benefits, spillovers into digitalisation and innovation (table 12).

PO3 is considered the most efficient option, with a score of ++ due to its ability to deliver

extensive benefits relative to the costs involved, whencompared against the baseline scenario.

If only monetised costs and benefits are considered, options PO1 and PO3 perform similarly,

as both have comparable benefit-cost ratios207. However, option PO3 generates high non-

monetary benefits and therefore shows higher overall efficiency. It provides stronger security,

as digital documents are securely stored in the EUDI wallets and linked to the holder’s Person

Identification Data (PID), ensuring that both the document and the individual’s identity can be

verified at a high level of assurance, as required by the EUDI framework. PO3 also delivers

high social, digital, innovation, competitiveness, and environmental benefits (see chapter 6).

The total efficiency for option PO2 is the same as in baseline when wallet is not used. While

the benefit-cost ratio is less than one (i.e. the increase in benefits is smaller than increase in

costs), it creates some non-monetary benefits, however, they are rather low (small).

Table 12. Overview of efficiency rating of policy options against the baseline

Options  PO1M  PO2M  PO3 

Rating  +  0  ++ 

Criteria for comparing

options 

cost-savings from faster checks and more effective fraud prevention; social benefits, including better access to social security and healthcare services, enhanced fairness, and the safeguarding of fundamental rights; environmental impact, aiming for reduced plastic consumption and minimised paper usage; competitiveness benefits; spillovers into digitalisation and innovation; total costs. 

Coherence

Coherence assesses the policy options alignment with the fundamental rights of the EU and

how they integrate with existing EU policy frameworks, and fits into the broader legal, digital,

and policy landscape without undermining or duplicating other initiatives. It also encompasses

207 See section 6.1, tables 2,3, section 0, table 10 and section 6.3 and the sensitivity analysis in Annex 4.

Criteria for

comparing

options

- the degree of control, awareness and autonomy of individuals over their

data

- how user-friendly and flexible the options are in accommodating

different preferences, such as digital versus physical format.

45

core European priorities such as facilitating free movement within the single market, enhancing

access to social security and advancing the digital and green transitions.

The three policy options are assessed as coherent, with PO3 being the most coherent (+++).

PO3 aligns very well with broader social and labour mobility goals by effectively supporting

the application of social security coordination rules and aligning with the European Pillar of

Social Rights. It seamlessly integrates with ongoing EU digitalisation efforts, building on

existing initiatives and frameworks like the SDG Regulation, the EUDI framework, and the

Interoperable Europe Act, rather than introducing a separate system. By leveraging these

existing frameworks, PO3 minimises risks of duplication and inconsistencies, and helps reduce

fragmentation between heterogeneous national solutions. It is also very coherent with the core

e-government principles (see chapter 0) and the GDPR and it provides a balanced approach to

digital and non-digital solutions by supporting secure digital processes while maintaining the

possibility to request physical documents where necessary. PO2 achieves moderate coherence

by relying on existing EU solutions, but it does not introduce differences compared to the

baseline in dealing with non-digital formats. PO1 embraces standardisation, but it does not fully

integrate digital and non-digital solutions within the broader EU digitalisation landscape. As a

result, its coherence is positive but limited, as it does not leverage existing digital frameworks

and may leave room for duplication of efforts.

Table 13. Overview of coherence rating of policy options against the baseline

Options PO1 PO2 PO3

Rating

+ ++ +++

Criteria for comparing options

Integration with existing EU policy

frameworks, without undermining or

duplicating other digital initiatives

Subsidiarity and proportionality

Each policy option respect the principles of subsidiarity and proportionality as they do not

go beyond what is necessary and appropriate for the EU action. They create an EU solution for

the request, issuance and cross-border verification of social security coordination documents,

ensuring interoperability, digital exchange and mutual recognition of existing credentials,

without interfering with national social security schemes, for instance they do not harmonise

benefits rules. Option 2 and 3, achieve greater proportionality, relying on existing EU

framework, notably the EUDI framework and its component, instead of building a completely

new solution.

Table 14: Overview of overall option rating against the baseline

Category Impact PO1 P02 P03

Economic impact

Implementation

costs (total)

438 – 470 452 - 483 464 - 496

46

Economic and

environmental

Economic

Benefits: (faster

verification, reduced

fraud, reduced

consumption of

plastic)

317-324

180-282330-643

Net monetised

benefits

(-121)-154

(-272) - (-201)

(-134)-147

Benefits: reduced

up-front payments

needs

++++++++

Benefits:

competitiveness and

the single market

++ +++++

Benefits:

digitalisation and

innovation spillovers

+++++++

Social impact,

including on

fundamental rights

+++++++

Preferred option A solution built on the EUDI framework and enhanced social security coordination documents Option 3 is the preferred choice as it is the most effective in achieving the objectives, the most

efficient in terms of costs and benefits, and ensures the highest level of coherence with other

EU policies. It adheres strictly to the principles of subsidiarity and proportionality, ensuring

that the proposed intervention does not go beyond what is necessary to address the identified

problem. This option would effectively address the existing challenges faced by individuals,

businesses, national authorities and healthcare providers by reducing reliance on paper-based

processes through standardised, simplified procedures for requesting, issuing and verifying

portable documents and the EHIC across-borders. This approach facilitates extensive

interoperability and recognition of documents throughout the EU, granting individuals and

businesses extensive choice and control over their data storage and presentation by enabling

them to utilise the EUDI wallet or opt for enhanced documents. In terms of security and

trustworthiness, digital credentials are cryptographically signed and issued by trusted

authorities, ensuring authenticity, integrity, and non-repudiation, allowing them to be instantly

checked without the need to contact issuing authorities. This advancement not only streamline

processes, mitigating delays caused by manual checks, but also reduces the risks of forgery and

errors, ensuring more secure and reliable interactions. From a cost-benefit perspective, option

3 would represent the most efficient use of resources, offering the best social and economic

returns. Although it requires substantial resource investment, it brings important benefits

from cost savings due faster checks, improved fraud prevention, environmental benefits,

enhanced trust and fairness as well as other social benefits. This option also contributes

47

significantly to advancements in simplification, digitalisation and innovation, without

widening the digital divide. The use of EUDI wallets to store and share documents like the

EHIC (with its broad circulation) would significantly accelerate the adoption of these wallets

fostering a broader digital economy ecosystem. Moreover, mandating the issuance of social

security coordination documents in the EUDI wallets lays the foundation for integrating at a

later stage, through sector-specific legislation, other documents relevant for labour mobility208,

such as the information currently included in labour and social identity cards utilised in the

construction sector in some EU countries209. This approach would ensure that an individual can

conveniently present, and authorities can reliably verify, all required documents via a single

trusted digital wallet.

Option 3 is coherent with other EU digital initiatives and policy frameworks, including the

GDPR, and with efforts to build a fairer Europe and strengthen its social dimension in

line with the principles of the European pillar of social rights. It supports the European goals

of promoting free movement and fair labour mobility, enhancing cross-border access to social

security and healthcare while advancing digital transformation. The option fully adheres to the

core e-government principles210: i.) digital by default, promoting digital procedures as

preferred choice, while still offering alternative options, ii.) once-only principle, reducing

redundant data submission, iii.) interoperability by design, facilitating cross-border recognition

of documents and reducing fragmentation, iv.) user-centricity, putting people at the centre211

and ensuring predictable processing times, v.) inclusiveness and accessibility, guaranteeing

equal access to all, notably people with disability, elderly people and individuals with limited

digital skills by offering the option to request a printable enhanced document, v.)

trustworthiness and security, promoting the protection of personal data and high security

standards vi) cross-border by default, establishing services available across-borders and

reducing unnecessary barriers to mobility. The option is also coherent with several Sustainable

Development Goals. More details are provided in Annex 3.

Stakeholders212 revealed broad support for this option across the various consultations.

Given the cross-border nature of the problem and the need to prevent regulatory fragmentation,

a Regulation is considered as the most effective and proportionate legal instrument to achieve

the defined policy objectives, ensuring uniform application across Member States. This Act

would lay down the legal requirements governing the digital solution, establish a clear

governance for digitalisation in social security coordination, uphold rigorous data protection

standards, with clearly delineate roles and responsibilities of the various actors involved in data

processing, as well as accessibility requirements. The technical architecture and specifications

of the solution would be defined through implementing acts. A user journey is presented in

Annex 3.

208 This is already foreseen in the proposal on the e-Declaration for posting. 209 This was stressed by several participants in the High-level meeting on digitalisation in SSC. 210 2030 Digital Compass and Tallin Declaration on e-government. 211 European Digital Rights and Principles. 212 See Annex 2. This was also confirmed in the ESSPASS public consultation. The most preferred format was a

standardised digital format combined with a physical format with enhanced security features for those not using

digital tools, selected by 109 respondents (67%). Moreover, 95% of respondents reported that integrating

documents into EUDI wallets would simplify storage and verification.

48

Application of the ‘one in, one out’ approach The are no expected administrative costs. The option would improve processes related to the

request, issuance and verification of portable documents and EHIC. By simplifying existing

procedures and reducing unnecessary delays, it would bring a positive impact on businesses

and their operations across borders (see Annexes 5 and 6).

How will actual impacts be monitored and evaluated? A comprehensive draft monitoring framework has been designed to monitor the implementation

and evaluate the initiative’s impact, ensuring that it remains fit for purpose and achieve the

intended objectives. The Commission will also contribute to ensuring correct and timely

implementation of the preferred option. Progress will be tracked through a set of operational,

result, and impact indicators linked to the specific objectives (see Annex 12). The Commission,

in close cooperation with Member States, will regularly collect and analyse data - leveraging

existing reporting mechanisms - to identify implementation gaps, assess the efficiency of the

measure, and provide the necessary evidence base for a future evaluation. The monitoring

framework will undergo further refinement based on the ultimate legal specifications and

implementation schedule. The initiative could be evaluated no sooner than seven years

following its entering into force to assess the actual impacts against the baseline scenario

established in this report. This would account for a 36-month transposition period by Member

States, and ensuring adequate time to get meaningful data on the application of the

legislation213.

ANNEX 1: PROCEDURAL INFORMATION

Lead DG, Decide Planning/CWP references

DG EMPL, Unit E2, has a lead for the Impact Assessment on the European Social Security

Pass. An impact assessment was validated in the Decide Planning under reference

PLAN/2025/2391.

Work Programme reference: Commission work programme 2026 (Annex 1, initiative no. 25)

The Call for evidence run from 14 January to 11 February 2026. The Public Consultation was

published on 22 January 2026 and finished on 16 April 2026.

Organisation and timing

213 In accordance with the Better Regulation, an ex post evaluation requires data over a period of at least three to

four years.

49

The impact assessment was coordinated by an Inter-Service Coordination Group (ISCG)

managed by the Secretariat General. Representatives from Secretariat-General, Directorate-

General for Employment, Social Affairs and Inclusion, Legal Service, Directorate-General for

Mobility and Transport, Directorate-General for Communications Networks, Content and

Technology, Directorate-General for conomic and Financial Affairs, Directorate-General for

Maritime Affairs and Fisheries, Directorate-General for Budget , Directorate-General for

Internal Market, Industry, Entrepreneurship and SMEs, Directorate-General for Trade,

Directorate-General for for Justice and Consumers, Directorate-General for Health & Food

Safety, Directorate-General for Regional and Urban Policy, Directorate-General for Human

Resources and Security, SG REFORM were appointed to the Group.

In total, three meetings of the ISCG were organised to discuss this impact assessment (on 18

December 2025, 12 February and 5 March 2026). Comments were provided by the ISCG on

the first part of the Impact Assessment after the meeting of 12 February and on the entire text

after the meeting of 5 March.

Consultation of the RSB

An upstream meeting with the RSB took place on 21 January 2026.

The draft Impact Assessment was assessed by the Regulatory Scrutiny Board (RSB). The RSB

delivered a positive opinion with reservations on 4 May2026. The revisions introduced in

response to the RSB opinion are summarised in the table below.

RSB’s requests for improvement Changes made to the report

(1) The analysis of problems and their drivers is not

sufficiently underpinned by observational evidence

and does not differentiate between stakeholders’

groups. The report should clarify the scope of the

initiative regarding the portable documents to be

covered in the short and longer run. Beyond the initial

focus on portable documents A1 and EHIC, the report

should explain the phased roll-out of other portable

documents.

The report should improve the problem definition,

building on available evidence, in particular

observational data. The problems and their drivers

should be analysed with more granularity, allowing to

understand the magnitude of problems faced by the

specific stakeholder groups, e.g. (a) workers,

differentiated where relevant by self-employed and

posted workers, (b) businesses, with a possible focus

on SMEs and (c) administrations. The report should

also better differentiate the problems stemming from

the legal base and those linked to implementation. The

report should better analyse the simplification and

digitalisation potential.

The report provides in section 5.2 further details on the

scope of the initiative and on the phased approach for

digitalisation.

The assessment has been substantially enhanced by

systematically integrating and expanding on the

relevant material from Annexes 2, 5, 6, 7 and 9, as well

as additional inputs and evidence gathered through

stakeholder consultation activities, notably the public

consultation results.

These changes helped enhance the robustness of the

analysis of the problem, ensuring that the different

dimensions are clearly articulated and underpinned by

the available data.

Further details by stakeholder group have been

provided, illustrating the specific challenges faced by

different categories of stakeholders and, in particular,

by businesses and SMEs (section 0 and Annex 8).

By disaggregating the evidence and feedback in this

way, the revised problem analysis better captures the

diversity of impacts, clarifies how these groups are

affected, and strengthens the overall justification for

the proposed intervention.

50

Stakeholder perspectives have been systematically

integrated throughout the main sections of the report,

namely the identified problems, the considered

options, and their associated impacts.

Clarifications were also provided indicating that the

identified problems are primarily linked to legal

shortcomings rather than to implementation issues

(section 0).

(2) The specific objectives are not sufficiently

SMART. The logic behind the design and structuring

of the policy options is not clear.

The report should frame the overarching objective

more strategically and link it better to the Commission

priorities. The specific objectives should be drafted in

a SMARTer way, considering in this context how

success will be measured.

The report should improve its intervention logic by

better explaining the approach for constructing the

policy options and providing a more detailed

description of the policy measures, especially as

regards their implementation. The voluntary options

should be used for sensitivity analysis only or

discarded early on.

The intervention logic has been made more

transparent and robust, and the description of the

objectives has been refined to ensure consistency

between the objectives and operational measures.

The overarching objective of the initiative has been

reframed in section 4.1 to ensure closer strategic

alignment with the priorities of the European

Commission.

The specific objectives in section 4.2 were formulated

in a more measurable way, providing a clearer basis

for assessing progress and results and should be read

in conjunction with the revised monitoring framework

in Annex 12.

The intervention logic has been further refined,

including by explaining more clearly the inclusion of

policy option 1 among the policy alternatives. The

report now provides more detailed information on the

envisaged measures under the selected policy options,

while clearly stating that the technical design will need

to be defined at the implementation stage (section 0).

Additional clarifications have been introduced for

instance confirming that the dual system (digital and

non-digital) will remain permanent for all options,

with no formal phasing out of non-digital support, and

explaining that the inclusion or exclusion of verifiable

digital security features determine the difference

between ‘non-enhanced’ and ‘enhanced’ documents.

The revised report also explains (section 6) that the

voluntary sub-options were assessed and discarded,

and that they are only presented in Annex 4 and

reflected in the sensitivity analysis.

Furthermore, the report provides additional

clarifications on the measures addressing perceived

duplication of administrative processes in the posting

of workers (section 0) and present the various

stakeholders’ perspectives (e.g. businesses ask for

reduction in duplication, trade unions underline the

need for transparency and workers’ rights),

highlighting the importance of achieving outcomes

that balance efficiency with fairness.

51

To ensure full transparency, the measures common to

all policy options have been explicitly integrated into

the intervention logic set out in Annex 12,

underscoring their role in supporting the broader

policy objectives.

(3) The report does not sufficiently justify all key

assumptions, in particular those driving the cost and

benefit analysis. The sensitivity analysis is not

sufficiently developed.

The report should improve the analysis of costs and

benefits based on a strengthened assessment of

economic, social and environmental impacts. The key

assumptions, particularly those driving the outcome of

the analysis, should be transparently disclosed and

justified (e.g. data sources, evidence base, related

uncertainties) and where relevant be a subject of

sensitivity analysis. A summary of all costs and

benefits, accompanied by sufficient explanations on

the cost structure, their nature (one-off vs recurrent)

and distribution (who bears them) should be provided.

Based on the improved analysis, the report should

provide a more robust comparison of options.

The coherence with existing or proposed policy

initiatives (e.g. EUDI or e-declaration proposal)

should be further developed.

The cost and benefit analysis was strengthened and

presented more clearly, with greater transparency and

justification of the key assumptions underpinning the

assessment. The sources, methodologies and rationale

for the main analytical choices were documented in a

more detailed manner. This included, for instance, the

assumption of a 75% adoption rate of the European

Digital Identity wallet (section 0 and Annex 4). That

uptake assumption was also tested through sensitivity

analysis in Annex 4, which examined how lower and

higher adoption rates would affect the projected

impacts.

The methodology underpinning the cost-saving

estimates was further clarified and made more

consistent and transparent. The key assumptions,

calculations and projections were explained in greater

detail. In particular, the rationale for the conservative

assumption of zero fraud savings under PO2 was set

out more explicitly (section 0). This assumption was

also tested in the sensitivity analysis, in order to reflect

the possibility that some degree of fraud reduction

could also arise under PO2.

The report was further improved through clearer

cross-referencing between the main text and the

supporting annexes.

For implementation costs, the assumptions, data

sources and evidence base were further refined and

presented more clearly in the main report, with

supporting methodological details cross-referenced

more systematically to Annex 4.

In section 0 on environmental impacts, the key

assumptions were clarified, notably those relating to

the full phase-out of plastic cards under PO1, where

they would be replaced by PDF documents enhanced

with QR codes, and under PO3, where they would be

replaced by wallet-based and PDF-enhanced

documents. By contrast, PO2 would retain plastic

EHICs for non-wallet users. The report also provided

additional explanation of the calculation logic and

results in order to improve transparency as to how the

environmental impacts were derived. Relevant

aspects, including energy use, were acknowledged

directly in the main report rather than only being

referenced in Annex 4.

52

Section 0, on the comparison of policy options, was

also strengthened. In particular, a comparative

summary table presenting the costs and benefits of all

policy options was introduced to support the

efficiency analysis.

(4) The monitoring and evaluation framework should

be accompanied by well-defined indicators, data

sources, baseline/benchmarks and, where relevant,

quantified targets. The framework would benefit from

specifying indicators that are stakeholder-specific (e.g.

SMEs, verifiers, citizens, etc.). Indicators covering

cybersecurity should also be included.

The monitoring and evaluation framework in Annex

12 has been strengthened by refining the indicators to

ensure that they capture both outcome-related effects

and process-efficiency aspects.

References to stakeholders have also been added,

where relevant, so as to better reflect the impacts on

different groups.

Quantified targets have been introduced where

proportionate and operationally meaningful, together

with explicit references to the underlying data sources,

in order to improve transparency and consistency in

measurement.

In addition, cybersecurity-related indicators have been

incorporated to address risks associated with digital

verification, including incident frequency and severity

(for example, the number of cybersecurity breaches)

and compliance with security standards.

These revisions are intended to ensure that the

framework provides a structured, evidence-based and

stakeholder-inclusive basis for monitoring

implementation and evaluating results.

Evidence, sources and quality

The Impact assessment draws upon a combination of quantitative and qualitative data sources,

including:

- Study by external consultants on Facilitating free movement through further

digitalisation in social security coordination (forthcoming).

- Official EU statistics, notably Eurostat, statistical reports on intra-EU mobility and

social security coordination.

- Relevant academic literature, EU and national policy documents and studies, EU

legislation and acts, as referred in footnotes.

- Insights from stakeholder consultations and ESSPASS pilot projects, including through

validation workshops, surveys, interviews, and dedicated meetings (see Annex 2).

53

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)

This annex summarises the outcomes of consultation activities on ESSPASS, including in the

context of the external study on digitalisation in SSC. It notes the stakeholders consulted,

describes the main consultation activities, and provides a succinct analysis of their views and

the main issues raised.

CONSULTATION STRATEGY

Objectives and methods

In line with the Better Regulation principles, the Commission carried out consultations to ensure

that the perspectives and interests of all relevant stakeholders were considered and integrated

into the ESSPASS proposal. The consultation aimed to: (1) gather insights to optimise the

ESSPASS initiative design (2) identify and address stakeholder concerns like privacy and data

protection issues (3) foster dialogue to build consensus on the objectives, benefits and costs of

the ESSPASS initiative (4) ensure stakeholder engagement throughout the entire policy-making

process.

Given the technical and operational nature of the initiative and the limited availability of

quantitative evidence on costs and impacts, the Commission adopted a mixed approach,

combining pilot projects insight, analytical work, targeted consultations and open stakeholder

engagement.

Pilot approach and early stakeholder involvement

The Commission chose to initiate ESSPASS as a pilot project, reflecting the importance of

testing digital solutions in practice and involving key stakeholders at an early stage of policy

development (see Annex 10). The ESSPASS proposal builds on the outcomes of this pilot phase

which provided early insights into feasibility, operational constraints and governance

requirements.

Consultation as part of the study on digitalisation in SSC

An external Study on Facilitating free movement through further digitalisation in social security

coordination assessed, inter alia, the potential impacts and prerequisites for implementing a

digital solution such as ESSPASS at the EU level. The following consultation activities were

carried out:

• Two surveys:

o One broad survey on problem definition, policy options and costs, including

outreach to healthcare providers and national health contact points.

o One targeted survey focusing on costs and benefits, to address the limited

availability of evidence in this area.

• 97 stakeholder interviews including additional interviews specifically addressing costs

and benefits.

54

• Two stakeholder workshops focusing on problem definition, policy options and

validation of cost estimates.

Targeted consultations and expert exchanges

In addition to the study, the Commission conducted targeted consultation activities to

complement the evidence base:

• Meetings with experts involved in ESSPASS pilot projects, focusing on operational and

technical aspects;

• Seminars and exchanges under the framework of social security coordination, including

dedicated meetings on ESSPASS and impact estimates;

• an Implementation Dialogue on fair labour mobility, addressing ESSPASS,

enforcement and verification challenges;

• a High-level meeting on digitalisation, focusing on interoperability and considerations

on the conditions for a smooth transition from pilot to ESSPASS large-scale

deployment;

• a hearing of EU social partners, gathering the views of workers’ and employers’

organisations;

• a call for evidence on ESSPASS and another one on the Fair labour mobility package;

• a public consultation.

Other activities include a request for input from the Audit Board on EHIC reimbursement

issues. Further outreach to national authorities on fraud focusing on risks and prevention.

Finally, analytical support and additional data gathering was carried out by the European

Labour Authority, notably on portable document A1 and impacts on labour inspectors.

Table 1: Overview of consultation activities

Consultation activity Stakeholders involved Main focus Type of evidence

ESSPASS pilot

projects (2023–2025)

Member State institutions Feasibility;

digitalisation of EHIC

and portable document

A1

Operational,

qualitative/quantitative

Broad stakeholder

survey - as part of the

study

National authorities,

healthcare providers, labour

inspectors, national health

contact points, social

partners

Problems, options,

costs

Qualitative, limited

quantification

55

Targeted cost–benefit

survey

National authorities

(through the representatives

of the AC)

Costs and benefits Qualitative, limited

quantification

Stakeholder

interviews (97) - as

part of the study

Administrations, inspectors,

social partners, experts

Problem definition,

objectives, options,

feasibility, impacts

Qualitative and limited

quantitative

Stakeholder

workshops - as part of

the study

Public authorities, social

partners

Problem definition,

options, impacts

Qualitative

Meetings with pilot

project experts

Technical experts Operational and

technical feasibility,

costs

Operational,

qualitative and

quantitative

Social security

coordination seminars

Member State

representatives

ESSPASS design,

impact estimates

Qualitative

Implementation

Dialogue on labour

mobility

Member States, social

partners, social security

institutions, healthcare

providers, businesses

ESSPASS,

verification,

enforcement and

simplification

Qualitative

High-level meeting on

digitalisation

High-level representatives

of national authorities

Requirements for

ESSPASS large-scale

deployment and

interoperability, pilot

projects

Strategic

EU Social partners’

hearing

Workers’ and employers’

organisations

Fair Labour mobility

package,

simplification,

workers’ rights and

enforcement

Qualitative

ELA analytical

support

Enforcement stakeholders Portable document

A1; inspection impacts

Qualitative, analytical

Call for Evidence

(online)

All stakeholders Problem definition;

policy options

Mixed

Public Consultation

(PC)

All stakeholders Problem definition;

options, impacts

Tbc - Ongoing

RESULTS OF CONSULTATION ACTIVITIES

Consultation activities have taken place over 2023-2026, from the collection of initial feedback

as part of the ESSPASS pilot project to the launch of the external study in 2025, to the Call for

evidence launched in January 2026 to the Public Consultation that closed in April 2026.

56

Consultation as part of the study

(i) Targeted survey

A targeted survey was conducted via the EU Survey platform in all EU languages from 28

March to 25 April 2025. The survey was addressed to social security institutions, national

ministries, healthcare providers, and social security inspectorates across the EU and EFTA

countries. Its purpose was to gain a better understanding of the current situation, the needs and

costs associated with a potential ESSPASS solution, and its potential impacts. Respondents

provided information on the use of all Portable Documents and the EHIC, the level of

digitalisation in verification processes, and the main obstacles encountered in cross-border

situations. The feedback informed the analysis of problem drivers and supported the assessment

of policy options, providing useful inputs across the Chapters of the report. A total of 87

responses were received, representing a diverse range of stakeholders. The majority

of responses came from social security institutions (72), followed by national ministries (8),

inspection authorities (5), and healthcare providers (2), as depicted in Figure 19.718

Figure 19. Stakeholder organisation distribution

N=87, Targeted survey

Geographically, the survey achieved wide coverage, with responses from 32 countries or levels

(EU level responses), including most Member States and several EFTA countries (Norway,

Switzerland, Iceland, Liechtenstein). The most represented countries were Luxembourg (8),

Finland (7), France (6), and Greece (5), with additional input from a wide range of other

Member States. A full breakdown is available in the Figure below.

Figure. Geographical distribution of targeted survey respondents

57

N=87, Targeted survey

Regarding the documents covered within the scope of activities of respondents,

the frequency of portable documents and EHIC that respondents operate with were portable

document A1 and EHIC, followed by document in the sickness sector (portable documents S1,

S2, S3), portable document DA1 (work-related accidents), and unemployment-related forms

(Portable document U1, U2, U3). For example, portable document A1 was mentioned by

44 respondents, EHIC by 42, and portable document S1 by 35. (see Figure 21). This reflects

the centrality of these documents in cross-border social security coordination.

The survey data also highlighted some limitations, including uneven representation across

stakeholder groups and countries, especially with regard to the low response rate of healthcare

providers and variable completeness of responses, especially with regards to costs and impacts.

As such, the findings were interpreted as indicative patterns rather than statistically

representative measures. Nevertheless, the survey provided valuable insights, which were used

to inform both the problem definition and the assessment of policy options.

Figure. The number of survey respondents who operate with portable documents and EHIC

58

N=87, Targeted survey

Following the Working Party meeting on 1 October 2025, the study team, in collaboration with

the Directorate-General for Employment and social affairs (DG EMPL), prepared a second

survey which closely mirrored the structure and content of the survey used during the meeting

which was distributed by DG EMPL to national authorities, including both Administrative and

Technical Commission members (all Member States, EAA/EFTA and UK) and received 17

responses. The aim was to collect additional, structured feedback and fill information

gaps regarding costs and benefits. Respondents were encouraged to provide factual, justified

answers, drawing on institutional data and practical experience.

(ii) Stakeholder interviews

In total, 97 interviews were conducted with the following stakeholder groups: academia, pilot

project members, European Labour Authority, European Commission, healthcare

providers, labour and social security inspectorates, national authorities / social security

institutions, national ministries, social partners and technical experts.

As part of the supporting study, 16 scoping interviews were conducted during the early phase.

Their aim was to deepen understanding of the key issues covered by the study, confirm and

refine the design of the methodological approach and have an initial mapping of the information

available to key stakeholders, as well as informing key stakeholders that the study is being

conducted. The scoping interviews targeted EU institutions, agencies and bodies officials,

national public authorities, as well as EU umbrella organisations representing social parties and

affected stakeholders.

This was followed by 67 in-depth interviews with representatives from competent authorities,

social security institutions, relevant EU bodies and social partners to gather detailed insights on

current practices, challenges, to test hypotheses and collect available data for the analysis.

59

Finally, a third round of 15 follow-up interviews were organised with select stakeholders

interviewed to validate preliminary findings, explore certain aspects further, clarify

outstanding questions, and to explore the potential impacts and cost implications of the

different policy options in greater detail. All interviews were semi-structured, allowing for

consistency across sessions while enabling flexibility to capture context-specific perspectives.

In total, 97 interviews were performed. Interviews were conducted with the following

stakeholder groups: academia, pilot project members, European Labour Authority, European

Commission, healthcare providers, labour and social security inspectorates, national

authorities / social security institutions, national ministries, social partners and technical

experts.

(iii) Workshops

Two stakeholder workshops were held in June 2025. The first one on 12 June 2025 focused on

problem definition, options and costs. The second one on 24 June 2025 verified and built upon

the study’s preliminary results.

The first stakeholder workshop brought together a broad spectrum of stakeholders, including

representatives from the European Commission (DG EMPL), national ministries, social

security institutions, social security inspectorates, healthcare providers, social partners, trade

unions, employer organisations, and technical experts. In total, 62 participants attended the

workshop. The purpose of the workshop was to corroborate the problems identified, and to

discuss the potential deployment of ESSPASS. It was held online, to ensure broad participation

of stakeholders.

Participants confirmed that current systems for issuing and verifying portable document A1

create significant administrative burdens, legal uncertainty and enforcement gaps, especially in

the context of posting of workers. These challenges are compounded by delays, fragmented

national practices and limited possibilities for real-time verification. Importantly, discussions

underlined the need to clearly distinguish fraudulent behaviour from procedural or

administrative errors, to avoid disproportionate consequences for workers and businesses.

A strong consensus emerged around the added value of real-time verification and digital

solutions. Digitalisation was widely seen as a key enabler to simplify procedures, reduce

administrative costs, improve compliance, and strengthen trust between authorities, businesses

and workers. Participants highlighted the potential of interoperable digital tools, notably a

European-level solution building on the EUDI Wallet, to support secure and user-friendly

verification across borders.

At the same time, the workshop identified practical implementation conditions as critical to

success. These include manageable integration costs, shared technical solutions to avoid

duplication, structured roll-out strategies, and early investment in training and awareness-

raising for all users. Participants stressed that digital solutions must be user-centric,

interoperable and inclusive, and embedded in existing administrative workflows.

As a result, there was broad support for a mixed and pragmatic solution, that combines (1) a

secure, interoperable digital wallet-based solution as the core system and (2) a robust analogue

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fallback (e.g. paper or plastic documents with QR codes) to ensure accessibility, continuity and

inclusiveness during transition phases or in cases of limited digital readiness.

Overall, the workshop concluded that digitalisation alone is not sufficient. Its success depends

on being part of a broader, coordinated approach addressing legal clarity, procedural

harmonisation and technical interoperability. Participants agreed that the effectiveness of

ESSPASS will ultimately rely on sustained cooperation between Member States, flexible and

proportionate cost models, and continuous investment in capacity-building and awareness-

raising.

The second stakeholder workshop convened a diverse group of stakeholders that

included representatives from the European Commission (DG EMPL, DG MOVE, DG GROW,

DG DIGIT, DG CNECT, DG JUST, DG SANTE), the European Labour Authority, national

ministries, social security institutions, employer and employee organisations, technical experts,

and social partners. In total, 44 participants attended the event.

It was used to validate and further develop the study’s preliminary findings, with a particular

focus on remaining structural challenges in social security coordination that could be addressed

through digitalisation, as well as on longer-term developments and cross-sectoral synergies

with other EU digital initiatives.

Discussions confirmed that persistent barriers continue to affect effective social security

coordination. These include limited interoperability between national data systems, divergences

in data protection and data security legal frameworks, and constraints in the prevention and

detection of cross-border fraud. Participants identified legal and technical obstacles to data

exchange as a key limiting factor and underlined the need for clearer guidance, improved data

governance and real-time access to relevant information for enforcement authorities, while

preserving citizen control over personal data. The evolving role of the GDPR and the EUDI

framework was highlighted as a central element in shaping future digital solutions.

Participants identified opportunities to align social security coordination more closely with

related policy areas, notably labour law and healthcare. In particular, discussions highlighted

the potential to explore synergies between the Portable documents A1 process with the

proposed common electronic form for posting declarations, notably the feasibility of one-stop-

shop solutions for employers. Further digitalisation was seen as a means to better support

freedom of movement, including through possible integration of social security and healthcare

data within the EUDI Wallet and of labour cards. Across these discussions, participants stressed

the importance of coherent user journeys, common interoperability standards and a digital-first

approach, supported by early and continuous stakeholder engagement.

Overall, the workshop confirmed that digitalisation offers substantial potential to simplify

procedures, improve data sharing and facilitate cross-border mobility. At the same time,

participants emphasised the complexity of ensuring alignment between legal frameworks,

technical infrastructures and stakeholder expectations across sectors and Member States.

Results of other consultation activities

EU Implementation Dialogue on Fair Labour Mobility of 16 September 2025

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The Implementation Dialogue on Fair Labour Mobility brought together 29 external

stakeholders including Member State public authorities, social partners, civil society

representatives, and expert groups and discussed ESSPASS as part of the Fair Labour Mobility

Package. The meeting was chaired by Executive Vice-President Roxana Mînzatu and Director-

General for Employment and social affairs Mario Nava.

All participants welcomed the Commission's intention to propose ESSPASS, recognising its

potential to help individuals prove their social security rights in cross-border situations and

enable authorities to instantly verify portable documents. Stakeholders noted this would reduce

errors and fraud, support labour inspectorates, and ease administrative burdens.

Some participants from trade unions called for a more ambitious tool, suggesting the inclusion

of a labour cards with employment information and interoperability with other digital platforms.

They also stressed the need to modernise social security coordination in parallel, particularly to

ensure fair distribution of cross-border costs and strengthen fraud prevention.

Overall, stakeholders strongly supported ESSPASS as a key digital tool for cross-border social

security, while emphasising the importance of ambition, interoperability, and coherence with

broader coordination reforms.

High-level meeting on digitalisation in social security coordination of 30 September 2025

The annual High-level meeting on digitalisation in social security coordination focused on the

implementation of ESSPASS andgathered 78 participants (56 Member State including social

security representatives and 22 EU Commission officials) to discuss ESSPASS

implementation, drawing on pilot results and examining deployment challenges, financial

implications and cross-sectoral synergies between labour and healthcare. Participants

unanimously recognised the potential of ESSPASS to enhance accessibility, transparency, and

efficiency in verifying social security entitlements, marking a pivotal step toward a more

citizen-centred and integrated system. The key conclusions were as follows:

• ESSPASS was seen as a transformative tool for citizen-centred social security.

Stakeholders agreed that ESSPASS represents a fundamental shift toward a more

accessible and efficient system for real-time verification of social security entitlements,

capable of simplifying administrative procedures and reducing bureaucratic burdens for

individualsand employers navigating their rights across Member States.

• Collaboration and resources were judged as critical for a successful rollout. A

successful transition from pilot to full-scale implementation was seen as requiring

substantial financial and technical investment, as well as active engagement from

national social security institutions, healthcare providers, and IT developers.

Participants highlighted interoperability with the EUDI Wallet as particularly important

to streamline access and reinforce trust in digital verification. Some participants (such

as representatives from Denmark and Austria) suggested that ESSPASS's underlying

infrastructure could serve as a model for other areas relevant to free movement and fair

labour mobility, such as cross-border healthcare access and digital labour

documentation, contributing to a unified digital ecosystem in support of EU objectives.

• Stakeholders acknowledged that challenges remain, particularly in ensuring user-

friendly design, data security, and inclusivity. The need to address potential barriers

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- such as digital literacy gaps or varying levels of technological readiness across

Member States - was underscored as vital to preventing exclusion and ensuring

equitable access. Additionally, the discussion touched on the importance of clear

communication strategies to raise awareness among individuals and businesses about

the benefits and functionalities of ESSPASS.

ESSPASS was seen by all as a catalyst for deeper integration in social security coordination,

with its success depending on sustained political commitment, cross-border cooperation, and a

phased approach balancing innovation with practicality.

Working party meeting of the Administrative Commission (AC) on ESSPASS of 1

October 2025

Representatives from the AC, Technical Commission and the Commission discussed the status

and progress of the ESSPASS initiative. The discussion focused on lessons-learnt during pilot

activities and the essential legal, organizational, financial, and technical conditions required for

successful ESSPASS implementation. Another key topic was the potential costs and benefits

of large-scale deployment. This focus stemmed from the need to further collect quantitative

data on ESSPASS impacts and validate estimates.

In the second part of the meeting, findings from the digitalisation study, highlighting missing

elements and gaps in the evaluation of potential costs and benefits for large-scale deployment.

Delegations were invited to engage in an interactive feedback session using Slido to provide

input related to the costs and benefits of ESSPASS. A survey was launched after the meeting

to collect more comprehensive input on these issues.

EU hearing of European Social Partners on the Fair Labour Mobility Package of 6

November 2025

The European Social Partners Hearing held on 6 November 2025 was organised by the

European Commission to gather feedback from European social partners (employers’

organisations and trade unions), including on ESSPASS, as part of the Fair Labour Mobility

Package. The consultation focused on practical implications for workers and businesses,

inclusivity, and operational challenges in implementing ESSPASS.

All stakeholder categories expressed overall support for the development of ESSPASS.

Employer organisations primarily viewed ESSPASS as a simplification and compliance tool,

aimed at reducing administrative burden and ensuring legal certainty. Trade unions emphasised

its potential as an enforcement instrument to combat fraud, bogus arrangements and social

dumping, and to strengthen workers’ protection.

Administrative burden, simplification and interoperability

Several employer organisations stressed the need for ESSPASS to reduce administrative

complexity, particularly in highly mobile or SME-dominated sectors. Pearle-Live

Performance Europe highlighted the disproportionate burden associated with repeated A1

applications for very short-term postings in the live performance sector and called for a system

based on simplification, proportionality and interoperability. ESSPASS should integrate with

existing systems (including EESSI) and avoid parallel paper and digital processes. It should

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support real-time verification and a ‘once-only’ data approach. HOTREC underlined

fragmentation of contribution records and lack of interoperability between national systems,

particularly affecting SMEs and seasonal workers. It supported a common EU digital

framework enabling automatic data exchange, real-time verification and the use of standardised

EUDI wallet, reducing administrative costs and improving transparency.

The cross-industry Employers’ input called for ESSPASS to move beyond a pilot phase and

become a fully-fledged instrument and called for an interoperable ‘single process’ merging A1

request and posting declarations, based on the once-only principle.

CEI-Bois supported a more reliable and secure system that is harder to counterfeit and

contributes to legal certainty, while reducing unnecessary bureaucracy.

Fraud prevention, enforcement and real-time verification

Worker representatives placed stronger emphasis on ESSPASS as a tool to combat fraud and

improve enforcement. ETUC supported ESSPASS as part of a modernised social security

coordination framework but stressed that digitalisation must not weaken reporting obligations.

It called for real-time verification of employment and insurance status, interoperability with

EESSI, IMI, ERRU and posting systems, and enhanced capacity for inspectorates to carry out

cross-checks and risk assessments. ESSPASS data should be strictly limited to labour and social

security purposes and not used for migration control. EFFAT supported ESSPASS but argued

that it should go beyond digitalisation of the portable document A1 and include a European

Social Security Number (ESSN). It emphasised interoperability, cross-checking capacities and

workers’ ability to verify their own data remotely. Use of data should remain confined to labour

and social security enforcement. In the aviation sector, Europeans for Fair Competition

(E4FC) supported ESSPASS to address alleged fraudulent use of A1 certificates and to

facilitate checks on aircrew employment status. It stressed that issuing authority must be a

public social security authority, not companies, to ensure authenticity and prevent abuse.

Similarly, the European Network Airlines Association (ENAA) supported strengthened

verification mechanisms to ensure fair competition and prevent alleged cases of manipulation

of social security affiliation.

Workers’ access to information and portability of rights

Several stakeholders underlined the importance of ESSPASS for workers’ transparency and

portability of rights. HOTREC considered that ESSPASS could provide mobile and seasonal

workers with clearer access to their contribution records and entitlements across Member

States. Pearle stressed that workers should have direct access to authoritative information on

their social security coverage and cross-border history. Eurocadres viewed digital enforcement

of social security rights as beneficial for highly skilled mobile professionals, provided it is

implemented coherently with the revision of social security coordination rules and involves

social partners throughout the process

Integration with the EUDI Wallet

Pearle supported expanding the EUDI Wallet to include qualifications, social security

credentials and posting confirmations, provided this reduces the number of physical documents

required. HOTREC supported inclusion of additional labour mobility documents in the EUDI

Wallet to simplify cross-border employment. ETUC stressed that interoperability with other

EU systems (EESSI, IMI, ERRU and posting declarations) is essential for enforcement

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purposes. Employers’ representatives underlined the need for synergies between ESSPASS,

digital credentials and the eDeclaration system, while avoiding overcomplication or excessive

data requirements.

(v.) Results from calls for evidence

Two calls for evidence were published by the Commission in relation to ESSPASS. The first

formed part of the preparation of the Fair Labour Mobility Package and gathered feedback on

broader labour mobility challenges, including digitalisation measures. The second was

specifically dedicated to ESSPASS and focused on issues related to social security coordination

and portable documents. Together, the two consultations collected both general and targeted

stakeholder input to support the preparation of the initiative.

(i) Call for evidence on the Fair Labour Mobility Package

The call for evidence on the Fair Labour Mobility Package run from 5 January 2026 to 2

February 2026, seeking stakeholder views on the Commission’s understanding of challenges

related to fair labour mobility and possible policy responses, including the ESSPASS proposal.

Stakeholders were invited to provide evidence on administrative burdens, enforcement

challenges and opportunities linked to the digitalisation of social security coordination and

labour mobility procedures.

Of the 71 submissions received, including contributions from business associations,

companies, trade unions, public authorities, NGOs and individual citizens, 37 explicitly

referenced ESSPASS. Most submissions originate from Belgium (reflecting the presence of

EU-level organisations headquartered there), followed by Germany, France and Denmark.

In relation to stakeholders’ categories, the majority of contributions came from business

associations and companies (15) closely followed by trade unions (13). Five from NGOs and

other organisations, and two contributions were received from individuals and two also from

public authorities.

Integration with existing systems and implementation feasibility

Stakeholders across all categories underline that the feasibility and effectiveness of ESSPASS

depend primarily on its integration within existing digital and administrative

infrastructures. The European Transport Workers’ Federation (ETF), the European Trade

Union Confederation (ETUC) and the European Construction Industry Federation (FIEC)

highlighted that ESSPASS had a role to play a broader digital ecosystem. They notably referred

to ongoing developments such as eDeclaration systems, the digitalisation of the portable

document A1 and enhanced labour inspection cooperation tools. These stakeholders consider

ESSPASS as one component of a wider digital toolchain supporting fair labour mobility.

Public authorities emphasised operational efficiency gains linked to digitalisation. The

Austrian Federation of Social Insurances (DVSV) and Deutsche Sozialversicherung

Europavertretung (DSV) highlight the expected reduction of manual procedures, while the

Dutch Ministry of Social Affairs and Employment (SZW) and the German Ministry for

Economic Affairs, Labour and Tourism (MWAT) stress the potential for digitalising existing

verification workflows and improving interoperability between national systems. Similar views

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are expressed by business stakeholders, notably the Confederation of Finnish Industries (EK)

and BusinessEurope, which underlined the importance of aligning ESSPASS with existing

national infrastructures and broader EU digital initiatives, including the EUDI framework.

At the same time, stakeholders identify significant implementation risks. Public authorities

such as SZW, MWAT and DVSV point to the complexity of integrating heterogeneous national

systems and warn against creating additional digital layers rather than building on existing

infrastructures. Transport and business organisations, including Transport and Logistics

Netherlands (TLN) raised concerns that insufficient interoperability could lead to fragmented

implementation and inconsistent recognition across Member States. The Swedish Association

of Local Authorities and Regions (SALAR) flagged potential disparities in Member States’

implementation capacities.

Administrative simplification and legal certainty for businesses

Business associations and companies consistently framed ESSPASS as a tool to reduce

administrative burden. Several organisations such as BDA, EK, the Confederation of Swedish

Enterprise (CSE) and TLN highlighted the expected reduction of duplication between posting

declarations and A1 procedures. BusinessEurope and Gesamtmetall emphasised that ESSPASS

could streamline documentation processes and avoid overlapping reporting obligations while

the Confederation of Danish Employers (DA) stressed the potential for simplification for

companies operating across borders.

Stakeholders also associate ESSPASS with increased legal certainty. BusinessEurope and the

International Road Transport Union (IRU) underlined that reliable and immediate verification

of documents would provide greater predictability for companies engaged in cross-border

activities. IRU and TLN further noted that faster verification could reduce disputes concerning

document authenticity and help companies avoid penalties resulting from the inability to

present valid documentation during inspections.

However, business stakeholders repeatedly stressed that these benefits depend on avoiding

additional compliance obligations. BusinessEurope and BDA cautioned against the creation

of parallel systems or new reporting layers, while CSE and TLN underline the importance of

limiting administrative impacts on SMEs. Gesamtmetall similarly emphasised that ESSPASS

should not duplicate existing posting or A1 procedures.

Strengthening enforcement and combating fraud

Trade unions shared feedback on ESSPASS highlighting the need for enforcement

effectiveness. The ETUC, the European Federation of Building and Woodworkers (EFBWW),

IG BAU, CGT and CFDT considered that digital verification of social security documents could

significantly improve the detection of fraudulent or invalid A1 documents. ETF and ETUC

explicitly linked ESSPASS to the fight against social dumping and unfair competition while

Danish unions 3F and DCU stressed the expected improvement in labour inspection capacity.

A recurring theme in trade union contributions concerned the need for real-time verification.

ETF, ETUC and EFBWW argue that inspectors currently lack the ability to verify authenticity

and validity at the moment of inspection while IG BAU and DGB underline the necessity of

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verifying revocation or status changes. These stakeholders therefore consider real-time

functionality a prerequisite for achieving meaningful enforcement improvements.

Trade unions also warned that a voluntary or limited deployment would reduce

effectiveness. ETUC, EFBWW, IG BAU and CGT expressed concerns that inconsistent

application across Member States could perpetuate enforcement gaps. EFBWW further argued

that static verification solutions would not adequately address fraudulent A1 practices.

Protection of workers and fairness in cross-border mobility

Trade unions, NGOs and citizen submissions highlighted the potential contribution of

ESSPASS to strengthening workers’ protection. ETUC and CGT underlined that clearer

proof of social security coverage could reinforce workers’ legal certainty while EFBWW

stressed that improved verification could reduce situations in which workers lack recognised

protection. CFDT emphasised increased transparency in cross-border employment situations.

EFFAT considered that ESSPASS could strengthen safeguards against labour abuse while the

International Organization for Migration (IOM) highlighted the importance of transparent proof

of rights.

Citizen contributions similarly expressed support for improved verification mechanisms and

expect clearer confirmation of social security coverage. NGOs also warned that digital

solutions must remain accessible. EFFAT and IOM raised concerns that complex digital tools

could create barriers for certain categories of workers if accessibility considerations are not

adequately addressed.

Governance, scope and transition from pilot phase

Stakeholders across categories called for clearer governance arrangements and legal

certainty regarding ESSPASS deployment. BusinessEurope emphasised the need for a clearly

defined legal framework and governance structure, while SZW highlighted the importance of

defining system architecture and responsibilities. FIEC, ETUC and ETF called for a transition

from pilot to a fully operational framework with a clear legislative basis and implementation

timeline. BusinessEurope and IRU stressed that the scope of ESSPASS should remain limited

to labour and social security verification functions.

Data protection and proportionality

Data protection considerations emerged as a cross-cutting issue. BusinessEurope and IRU

emphasised that ESSPASS must fully comply with EU data protection rules, including

principles of data minimisation and limitation to strictly necessary information. NGO

stakeholders, notably IOM and EFFAT, similarly called for strong safeguards and

proportional use of data to ensure trust and protect workers’ rights.

(ii) Call for evidence on the European Social Security Pass (ESSPASS)

The call for evidence on ESSPASS was open for feedback for four weeks from 14 January

2026 to 11 February 2026, with the aim of collecting stakeholders’ views on the Commission’s

understanding of the problems affecting social security coordination and on possible solutions

through digitalisation. Stakeholders were invited to share evidence on the functioning of

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portable documents procedures, administrative burdens, verification mechanisms and expected

impacts of ESSPASS.

This call of evidence received a total of 42 contributions. Out of these 42, 15 submissions

included an extended position paper provided as an attachment. Both the contribution and the

attached documents were analysed and treated as part of a single dataset.

In terms of stakeholders, the majority of contributions came from business associations and

companies (10) as well as individuals (10) closely followed by trade unions (9), public

authorities (8) and then NGOs and others.

Out of these 42 submissions, they came from 14 EU countries, two from third countries.

Most of the submissions from Belgium, as some of EU-level organisations are based in

Belgium, Germany, France and Denmark.

Table: Distribution of submissions per country and stakeholder category

Problems

Stakeholders across all categories broadly converge in identifying structural shortcomings in

the current framework governing verification of portable documents, in particular the portable

document A1 and the EHIC. The problems described are primarily operational and

implementation-related rather than legal in nature.

The absence of real-time and interoperable verification wasthe most frequently reported

problem. It related in particular to the inability to verify social security documents in real time

across borders. Several stakeholders explained that portable document A1 certificates are

typically issued as static PDF documents without interoperable verification functionality. This

limitation was explicitly highlighted by BDA and the European Federation of Building and

Woodworkers (EFBWW) which argued that static formats prevent reliable authenticity checks.

Trade unions including ACV–CSC and the European Transport Workers’ Federation (ETF)

emphasised that authorities cannot verify whether documents remain valid or have been

revoked, creating uncertainty during inspections. EFBWW and 3F further reported that labour

inspectorates cannot verify authenticity or validity at the moment of control, undermining

enforcement effectiveness. The absence of visible revocation status was repeatedly described

as a critical gap. ACV–CSC, BDA and EFBWW note that withdrawn or invalid documents

remain practically indistinguishable from valid ones, which stakeholders link directly to fraud

risks.

Administrative burden and fragmented procedures were identified by business stakeholders

as a major structural problem. CEI-Bois, DA and BDA explained that employers must often

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comply simultaneously with A1 procedures and national posting declaration systems, creating

unnecessary administrative burden and legal uncertainty. Pearle and several business

associations underlined that delays in issuing A1 certificates may lead to penalties or prevent

workers from starting assignments on time. Stakeholders associated these problems with

fragmented national systems and the absence of interoperable digital solutions applying a once-

only principle.

Enforcement weaknesses and fraud risks were highlighted by trade unions and sectoral

organisations. EFBWW, ACV–CSC and BDA stated that static documentation creates

opportunities for abuse and unfair competition. 3F highlighted enforcement vulnerabilities in

sectors with high labour mobility, particularly construction where complex employment

arrangements increase verification difficulties. Several submissions argued that enforcement

authorities currently operate largely ex post rather than in real time, limiting preventive

enforcement capacity.

Difficulties in exercising social security rights were also reported. EurECCA and ETF

described cases of transport workers being denied healthcare abroad or exposed to retroactive

claims because entitlement could not be verified promptly. Citizen submissions similarly

referred to difficulties linked to S1 forms, renewal procedures and lack of digital access. These

contributions framed ESSPASS not only as an administrative reform but also as a tool to ensure

effective access to social security rights.