You are posted to Germany, you work alternately in two states, or you provide services to a client in the Netherlands. Someone asks you for the “A1”. The document has a single function, often misunderstood: it establishes which state the social contributions are paid to. It says nothing about where the income is taxed.
The A1 portable document certifies the social security legislation applicable to a person who works in more than one member state of the European Union, the European Economic Area, or Switzerland. In Romania, it is issued by the National House of Public Pensions (Casa Națională de Pensii Publice, CNPP), exclusively online, free of charge.
The general rule is that a person carrying on employed or self-employed activity in a member state is subject to that state's social security legislation. The A1 document is obtained to apply one of the exceptions to this rule: posting, activity carried on in two or more states, or an exception agreement between the competent institutions.
The document concerns the contributions. It does not concern income tax, which is determined separately, under the Tax Code and the applicable double taxation treaty.
The document is issued in application of Regulation (EC) No 883/2004 on the coordination of social security systems and Regulation (EC) No 987/2009, which lays down the procedure for implementing it.
The regulations apply between the member states of the European Union, the states of the European Economic Area, and Switzerland. The basic principle is the single applicable legislation: a person is subject, at any given time, to the social security legislation of a single state, which prevents both double contributions and the absence of any cover.
The general rule, set out in Article 11(3)(a) of Regulation (EC) No 883/2004, is that of the state of activity. The exceptions, set out in Articles 12 to 16, are the ones for which the A1 document is issued. The competent institution in Romania is the CNPP, through its International Relations Directorate.
This is the most common, and the most costly, confusion. The A1 document answers a single question: which state the social contributions are paid to. The question of where the income is taxed has its own answer, based on different rules.
Contributions follow the European coordination regulations and, outside their scope, the bilateral social security agreements. Income tax follows the Tax Code, the tax residence criteria, and the double taxation treaty concluded by Romania with the state concerned.
The two assessments can point to different states, entirely lawfully. A posted employee can remain insured in the Romanian system, under the A1 document, and can owe income tax in the state of employment, if the length of their presence and the treaty rules require it. Conversely, a worker can pay contributions in another state and remain taxable in Romania on that income, with the obligation to declare it here.
For this reason, the A1 document cannot be relied on as proof of the place of taxation, either before the Romanian tax authority or before the foreign one. The two documents that matter for tax purposes are the certificate of tax residence and a correctly prepared return.
The employee is sent temporarily by their Romanian employer to work in another member state, while remaining in an employment relationship with the Romanian employer. The maximum period provided for by the regulations is 24 months. Self-employed workers can be “posted” under similar conditions, if they have previously carried on substantial activity in Romania.
The person habitually works in more than one member state, alternately or simultaneously, as an employee, as self-employed, or in both capacities. The applicable legislation is determined under rules concerning the state of residence and the substantial part of the activity. This is the typical situation of road hauliers and of consultants with clients in several states.
Under Article 16 of Regulation (EC) No 883/2004, the competent institutions of two states can agree, in the interest of the person, a solution different from the one resulting from the usual rules. This is the route used when a posting extends beyond 24 months. It is requested through a separate application and is not granted automatically.
People who habitually work on board a seagoing vessel have their own rules, which start from the flag of the vessel, and a dedicated form at the CNPP. Their situation is covered in a separate analysis.
You establish which of the three situations applies to you: posting, activity in more than one state, or an exception agreement. Misclassification leads to the wrong form and to the application being rejected.
The CNPP publishes separate applications for companies, for self-employed workers, for civil servants, for road hauliers in multiple activity, for seafarers, and for exception agreements under Article 16. Each application lists the documents to be attached.
For employers, the turnover generated in Romania must represent at least 25% of the turnover generated in Romania and in the state of employment. For self-employed workers, substantial activity in Romania for at least two consecutive calendar months before posting. Below these thresholds, the application has no chance.
A tax clearance certificate showing no arrears, trial balances for the preceding months, Form D112, the commercial contracts performed in Romania and those to be performed during the period requested, and the contract with the client in the state of employment, with a certified translation. The exact list results from the form chosen.
Applications are uploaded exclusively online, in the CNPP's RODPA1 application, launched at the start of 2024. Filing is not charged for. An incomplete file is the main cause of the delays reported by the institution.
The applicable legislation can first be established on a provisional basis. The determination becomes final within two months of the other states' institutions being informed, if none of them contests it. Until then, the position remains open.
Once A1 has been obtained, it remains to be established where the income is taxed, based on tax residence and the applicable treaty. The two answers do not follow from one another.
The turnover generated in Romania must represent at least 25% of the turnover generated in both Romania and the state of employment. Mere administrative presence is not enough. The CNPP expressly flags the checking of letterbox premises, with particular attention to road transport companies.
The posted person must have been insured in the Romanian system before the posting. The continuity of the contribution record is checked against the CNPP's records, and gaps can hold up the file.
At least two consecutive calendar months of substantial activity in Romania before the posting, proved by the tax assessment decision (decizie de impunere), the receipts and payments ledger, and ongoing contracts with clients in Romania.
Commercial contracts performed in Romania before the period requested, and contracts to be performed during the period requested, as well as the contract or preliminary contract with the client in the state of employment, with a certified translation.
The document is presented to the supervisory body of the state where the activity is carried on. Without it, the authorities of that state can treat the person as subject to their own social security legislation.
The practical consequence is double exposure: contributions owed in the state of employment, on top of those paid in Romania, with accesorii (late-payment charges: interest and penalties) and, in some states, with separate penalties for the employer. In sectors such as construction and transport, on-site inspections are frequent, and the absence of the document can lead to the activity being stopped.
Subsequent regularisation is possible, but more difficult than obtaining the document beforehand. The A1 document can also be issued retroactively, but the procedure involves correspondence between the institutions of the two states and, sometimes, the refund of contributions paid but not owed, which takes time.
The A1 document remains relevant, but not under the European regulations. For situations begun after 1 January 2021, the Protocol on Social Security Coordination applies, annexed to the Trade and Cooperation Agreement between the European Union and the United Kingdom; for those already under way on 31 December 2020, the Withdrawal Agreement applies. The application is still addressed to the CNPP.
Romania has bilateral social security agreements with states such as the United States, Canada, Israel, the Republic of Korea, Turkey, Serbia, the Republic of Moldova, Albania, North Macedonia, Chile and Uruguay. Each agreement has its own rules and its own certificate.
Without any coordination instrument, each state applies its own legislation, and double contributions become possible. The contractual structure needs to be thought through beforehand, not regularised afterwards.
Regardless of whether a social security agreement exists, income tax follows the double taxation treaty, where one exists, or the Tax Code, where it does not.
No. The A1 document concerns only the social security legislation, that is, the state to which the contributions are paid. Income tax is determined separately, under the Tax Code and the applicable double taxation treaty. The two regimes can point to different states.
The CNPP, through its International Relations Directorate. Applications are filed exclusively online, in the RODPA1 application, and the CNPP does not charge fees for issuing it.
The CNPP has publicly stated that the average processing time is under 30 days, with cases in which the document is issued in one or two days. The condition the institution repeats is that the file must be complete; incomplete files are the main cause of delays.
The substantive condition the CNPP requires of employers is that the turnover generated in Romania represent at least 25% of the turnover generated in both Romania and the state of employment. Below this threshold, the application is usually rejected, and letterbox structures are expressly checked.
The maximum posting period provided for by the European regulations is 24 months. Beyond this term, keeping Romanian legislation applicable is possible only through an exception agreement between the competent institutions of the two states, under Article 16 of Regulation (EC) No 883/2004, which is requested through a separate application.
Yes, the A1 portable document remains relevant in relation to the United Kingdom, but the legal basis is different. For situations begun after 1 January 2021, the Protocol on Social Security Coordination applies, annexed to the Trade and Cooperation Agreement between the European Union and the United Kingdom, rather than Regulations (EC) No 883/2004 and (EC) No 987/2009. For situations already under way on 31 December 2020, the Withdrawal Agreement remains applicable. The form is still requested from the CNPP.
Informative material, updated on 18 September 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
If the situation involves income, accounts or residence in another country, the related analyses are grouped under the international tax analyses. For assistance on such matters, see international taxation.
An initial discussion separates the two questions that get confused: where the contributions are paid and where the income is taxed. For each, the legal basis, the document needed, and the risk of double exposure.