- The EU coordination of social security (Regulations 883/2004 and 987/2009) covers the EU, Iceland, Liechtenstein, Norway, and Switzerland, and to a lesser extent, the United Kingdom.
- Four principles: you are subject to one system at a time, you have the same rights as locals, periods from different countries are aggregated, and cash benefits can be collected abroad.
- You start your pension from multiple countries with one application, and each country pays its share.
- EHIC is for temporary stays, S1 is for treatment in the country of residence, and S2 is for planned treatment abroad.
- The revision of the regulations was adopted by the European Parliament on July 7, 2026, and by the EU Council on September 28, 2026. Until publication and implementation, the current rules apply.
Have you worked in three EU countries? These are not three separate issues, but one system. EU coordination of social security does not create a common pension or common ZUS. Instead, it determines which country is responsible for your insurance and how countries settle accounts with each other. This guide serves as a map of the whole system: from the A1 certificate through pensions and healthcare to family benefits and unemployment benefits, with links to our detailed national guides. Status as of October 23, 2026.
Which Country Insures You
| Situation | Responsible Country |
|---|---|
| You work in one country | The country of employment. Your place of residence and employer's location do not matter. |
| Posting | For up to 24 months, you remain in the system of the country from which you were sent, with an A1 certificate. During this time, you do not acquire rights in the host country. |
| Working in several countries | If you perform a significant part of your work (approximately at least 25% of time or salary) in your country of residence, its system applies. Otherwise, usually, the country of the employer's location. |
| Cross-border telework | The framework agreement has been in effect for Poland since July 1, 2023. If you work remotely from your country of residence for less than 50% of the time, you can apply to remain in the employer's country system (A1 as an exception). This only works between countries that have signed it. |
| Activities in several countries | The country where your center of activity is located. When combining employment with self-employment, usually the country of employment prevails. |
Pensions: One Application, Payments from Each Country
You apply once, in your country of residence
The application is accepted by the institution in the country where you live (in Poland, ZUS), if you worked there. It forwards the case to the other countries, and institutions exchange data electronically in the EESSI system. Multinational cases take longer, so submit your application several months in advance. In ZUS, cases are handled by branches assigned to countries, including Opole (Germany), Gdańsk (United Kingdom), Szczecin (Norway, Sweden, Finland, Estonia, Latvia, Lithuania), Toruń (Denmark), the First Branch in Warsaw (France), Kraków (Netherlands), Lublin (Ireland). A complete list is available on gov.pl.
Each country calculates twice and pays the more favorable amount
Each state calculates the pension according to its own regulations and proportionally: first the theoretical amount for the entire career, and then its part corresponding to the periods in that country. It pays the higher of the two amounts. Periods shorter than a year usually do not expire, as they are taken into account by the country where you worked longer. In the end, you receive document P1 with a summary of decisions from all countries.
Payment in any EU and EEA country
Pensions can be collected in any EU and EEA country without a reduction for living abroad. National details can be found in the guides: Germany, Norway, United Kingdom. After Brexit, coordination with the United Kingdom operates based on a protocol to the trade and cooperation agreement, with limitations (e.g., no family benefits). Non-EU countries operate under a world of bilateral agreements, described in the guide on pensions from multiple countries.
EHIC, S1 or S2: Which Tool to Choose
These three documents are often confused, and each serves a different purpose. The diagram will help you choose the right one.
Which document do you need for treatment in another EU country?
What is your situation?
Is treatment necessary during your stay and cannot wait until your return?
EHIC
You receive treatment in the public healthcare system under the same conditions as locals, with local co-payments. The Polish card is issued free of charge by NFZ. The card usually does not cover emergency actions (e.g., in the mountains) or return to Poland after falling ill. See the section "Health: three different documents".
Form S1
Obtain S1 from the institution that insures you and register it with the health insurance fund in your country of residence. Then you receive treatment there as a locally insured person. This applies to cross-border workers, posted persons, and retirees with pensions from another country.
S2 or reimbursement based on the directive
For S2, you need the consent of the insuring institution before treatment. Then you receive treatment in the public system, and costs are settled between institutions. The second route is the cross-border directive: you organize and pay for treatment yourself, and then apply for reimbursement. Ask the National Contact Point in the country where you are insured.
Health: Three Different Documents
- EHIC (European Health Insurance Card): only for temporary stays. Covers necessary medical treatment during the stay, in the public healthcare system, on local terms. The Polish card is free. Validity depends on status, e.g., 3 years for workers, 20 years for retirees of retirement age, 18 months for students. You can apply in person or by mail at the NFZ branch or through the Internet Patient Account (IKP) or the mojeIKP app. From January 1, 2026, applications can no longer be submitted via ePUAP.
- S1: when you live in a different country than the one where you are insured. The form is issued by the insuring institution, and you register it in your country of residence.
- Planned treatment: the S2 route requires consent before departure. You receive treatment in the public system, and institutions can settle costs between themselves, so you often do not pay upfront. Consent cannot be refused when treatment is due in your country, and cannot be provided there in a medically justified time (Article 20 of Regulation 883/2004). The second route is the directive on cross-border healthcare. You organize treatment yourself, even in a private facility, pay, and then receive reimbursement according to the lower of the rates: the country of insurance or the country of treatment. Details are provided by the National Contact Point in the country of insurance.
Family Benefits and Unemployment Benefits
- Family benefits: rights arising from employment take precedence over rights from pensions, and those over rights from residence. When parents work in two countries, the country of residence of the children pays first (if one of the parents works there), and the other country supplements the difference if its benefit is higher. This is how the German Kindergeld works for children in Poland (see our Kindergeld guide) and the Norwegian barnetrygd.
- Unemployment benefits: periods of work from other countries are aggregated with document U1. You can take the benefit with you to look for work in another country, with document U2. Conditions: at least 4 weeks of registration as unemployed before departure and registration at the employment office of the new country within 7 days. The benefit is granted for at least 3 months; the paying country may extend this period to 6 months if you apply before the end of the first 3 months. For cross-border workers, the benefit is paid by the country of residence.
- Sick and maternity benefits: periods are aggregated, and the cash benefit is paid by the country where you are insured, even abroad. Treatment is provided by the country of residence.
The European Commission proposed changes to Regulations 883/2004 and 987/2009 at the end of 2016. After nearly ten years of negotiations, the European Parliament adopted a compromise text on July 7, 2026, and the EU Council voted on it on September 28, 2026. Changes concern, among other things, unemployment benefits, long-term care benefits, and family benefits. Some new rules, e.g., regarding unemployment, will be implemented in transitional periods. The amending regulation still needs to be published in the EU Official Journal; only then will the dates of entry into force and application be known. Until then, the rules described in this guide apply.
Where to Find Free Assistance
- SOLVIT: a free network of the European Commission that helps when an authority in another EU country incorrectly applies EU law, including in matters of social security, pensions, and family benefits. Applications are submitted online.
- Your Europe Advice: free legal advice from experts on EU citizens' rights, also available in Polish.
- Europe Direct: hotline 00 800 6 7 8 9 10 11, available in Polish.
- National Institutions: in Poland, ZUS (pensions, A1, benefits), NFZ (EHIC, S1, S2), and employment offices (U1, U2) issue documents and answer questions about specific cases.
A1: in which country you pay contributions. S1: treatment in the country of residence. S2: consent for planned treatment. U1: periods for unemployment benefits. U2: benefit for job searching in another country. P1: summary of pension decisions. Collect work certificates and insurance documents from each country. Institutions exchange data electronically, but having your own file greatly speeds up the process.
Frequently Asked Questions
Do I need to apply for a pension in each country separately?
No. You submit one application in your country of residence if you worked there, and the institution forwards it to the other countries. Each country issues its own decision, and you receive a collective summary on document P1.
Is EHIC sufficient if I move to another EU country?
No. EHIC is only for temporary stays. When you start working there, the country of employment will insure you. If you live abroad and are insured in Poland (e.g., as a retiree), you need form S1.
Are the 2026 regulatory revisions already in effect?
No. As of October 23, 2026, the text has been adopted by the Parliament and Council but is awaiting publication in the EU Official Journal. The application dates will be known after publication.
Do I pay contributions in Poland when working remotely from Poland for a company in another country?
Usually yes, if you perform a significant part of the work in Poland. If remote work from Poland takes less than 50% of the time, and the employer's country has signed the framework agreement, you can apply to remain in its system.
Sources
Status as of October 23, 2026. This guide is for informational purposes only and does not constitute legal advice. For specific matters, contact ZUS, NFZ, the employment office, or the institution in the country where you worked, or use the free advice from Your Europe Advice.
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