Are business travelers really subject to posted worker rules?
Yes, in many cases. Posted worker rules do not automatically exempt short trips. If a traveler performs services that benefit an entity in the host country, they can be subject to these obligations—the key test is the nature and purpose of the activity, not the job title or length of stay.
For U.S. employers, not all EEA countries require posted worker registration, so whether a prior posting notification is needed depends on the specific host state. This also means that if a U.S. business traveler visits several EU/EEA countries or Switzerland on one trip, a posting notification may be required in one destination but not in another, even for the same activities.
By contrast, for workers posted within the EU/EEA and Switzerland, posting rules and related obligations generally apply across the board when qualifying services are provided.
Is posted worker registration the same as a work visa?
No. Posted worker notification is a separate, independent requirement. It typically requires documentation confirming social security coverage and is not a substitute for a visa or work permit. In many cases, a work permit—or proof that the traveler qualifies for a work permit exemption—must be in place when the posted worker notification is filed.
Is there one streamlined process across the EU?
Not yet. Each country runs its own portal (e.g., Germany's Meldeportal, France's SIPSI, Belgium's Limosa) with different languages and documents.
A common EU e-Declaration form has been proposed, but it would initially be voluntary—which is why a country-by-country Matrix approach is more reliable than a single checklist.
How does KPMG automate this?
KPMG LINK Go, our proprietary tax engine, assesses each trip across income tax, social security, the Posted Workers Directive, and permanent-establishment risk—and other areas of mobility compliance. When a filing is triggered, it collects the incremental data needed directly from the employee—then we lodge the filing and post confirmation back to the employee's record, available pre-travel.
Can KPMG help us design the whole program, not just file?
Yes. Through our Program Architecture & Governance service, we run workshops with your mobility, tax and HR teams to map the current state versus the future state, agree risk thresholds and roles, and build a repeatable, technology-enabled operating model—so compliance runs quietly in the background.
What happens if we've never registered a posting before?
Prior notification means registration should be completed before the worker starts activities in the host country. Where that has not happened, or cannot be achieved for a specific trip, the next step should be determined through an individual assessment with consulting support. Historical travel data can help identify potential past exposure and inform practical decisions for future compliance.
