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November 12, 2025

The Denmark Wake-Up Call: Why RUT Changes Signal an Urgent Need for Global Mobility Innovation

The Immediate Challenge

On January 1, 2026, Denmark will implement stringent new requirements for the Register of Foreign Service Providers (RUT) that will fundamentally change how companies manage third-country nationals posted to Danish worksites. Foreign employers must upload copies of service contracts, employment contracts, and residence and work permits when registering third-country nationals in the RUT system.

This represents a significant operational and administrative burden. Companies must now manage not just registration data but entire document portfolios for each posted worker, with potential fines up to DKK 20,000 for non-compliance, plus daily fines until registration is finalized.

Why This Matters Beyond Denmark?

The Denmark RUT changes exemplify a broader trend sweeping across the Nordics and Europe. The new legislation implements a political agreement from May 2024 aimed at strengthening efforts against social dumping and illegal labor, reflecting government priorities that are being echoed across multiple jurisdictions.

For multinational corporations managing thousands of cross-border assignments annually, Denmark is the canary in the coal mine. Each country introduces its own unique compliance framework, its own registration system, and its own documentation requirements. The result? A patchwork of obligations that traditional mobility management approaches simply cannot handle at scale.

The Market Gap

This is precisely why organizations are actively searching for innovative solutions. The requirements are clear, the deadlines are imminent, and yet no comprehensive solution exists in the market today that can efficiently manage:

  • Multi-jurisdiction compliance tracking across dozens of countries
  • Automated document collection, validation, and submission
  • Real-time monitoring of regulatory changes
  • Centralised visibility across all posted workers and assignments
  • Integration with existing HR and mobility systems

Traditional approaches—whether manual tracking, basic HR systems, or even specialised mobility vendors—were built for a different era. They cannot adapt quickly enough to the pace of regulatory change, nor can they scale to meet the complexity of today's global workforce.

The Urgency of Now

Denmark's January 2026 deadline is just months away, but it's hardly the only pressing compliance challenge. Similar requirements are emerging across Europe, each with different timelines, different documentation standards, and different penalties for non-compliance.

Companies that wait for perfect solutions will find themselves scrambling to achieve compliance, facing potential fines, work stoppages, and reputational damage. The organizations that will thrive are those that recognize this moment as an inflection point—an opportunity to fundamentally reimagine how they approach global mobility compliance.

What's Required

The solution to this challenge must be:

Proactive, not reactive: Anticipating regulatory changes rather than responding to them

Automated and scalable: Capable of managing compliance across multiple jurisdictions without linear increases in administrative burden

Integrated: Connecting seamlessly with existing systems while providing centralised oversight

Flexible: Adapting quickly as new requirements emerge in different countries

The Path Forward

The Denmark RUT changes should serve as a catalyst for action. For HR and mobility leaders, the question is no longer whether your current systems are adequate—the answer is clearly no. The question is: what are you doing about it?

Organisations that move quickly to address these challenges won't just achieve compliance. They'll gain competitive advantage through more efficient operations, reduced risk, and the ability to deploy talent globally with confidence.

The market opportunity is clear. The urgency is real. And for companies willing to innovate, the time to act is now.

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Simplifying Cross-Border Work: The EU's e-Declaration Portal for Posted Workers

November 12, 2025
Compliance

The European Union is taking a significant step toward reducing administrative complexity for businesses operating across borders. In November 2024, the European Commission proposed new legislation to establish a digital portal that promises to transform how companies declare posted workers—a process that currently involves navigating 27 different national systems with varying requirements. Understanding Posted Workers A posted worker is an employee temporarily sent by their employer to provide services in another EU member state. This practice is fundamental to the EU's freedom to provide services, enabling businesses to fulfill contracts across borders while temporarily deploying their workforce. In 2022, approximately 5 million workers were posted across the EU, a figure that has shown consistent growth in recent years. Currently, employers face a patchwork of national regulations and declaration requirements when posting workers. Each of the 27 EU countries maintains its own system with distinct information requirements, formats, and procedures. This fragmentation creates substantial administrative burdens and compliance challenges for businesses, particularly small and medium enterprises that may lack dedicated resources to manage these complexities. The e-Declaration Proposal The proposed regulation establishes a multilingual electronic public interface connected to the Internal Market Information System (IMI). This voluntary digital portal would allow companies to submit posting declarations through a single, standardized platform rather than dealing with multiple national systems. The initiative was first announced in the 2020 New Industrial Strategy update and gained momentum through the March 2024 Communication on labour and skills shortages in the EU. The proposal represents the culmination of extensive consultations with member states and stakeholders, including work by a dedicated expert group that concluded in December 2023. How the System Works The e-Declaration portal provides a secure web environment where companies can create accounts, manage declarations, and submit information electronically. The standard declaration form captures essential data across approximately 30 data points, including: Information about the service provider (employer) Details of the posted worker or workers Specifics about the posting activity and duration Contact information for the liaison person in the host country Information about the recipient of services Once submitted, declarations are automatically transferred to the IMI system, making the information accessible to competent national authorities for monitoring and enforcement purposes. Member states can also configure the system to send declarations directly to their national back-end systems, ensuring seamless integration with existing infrastructure. Voluntary Participation Framework A critical feature of the proposed regulation is its voluntary nature. EU member states are not obligated to participate in the e-Declaration system. Countries wishing to use the platform must notify the European Commission six months before their intended start date, allowing adequate preparation time. Member states that choose to participate commit to not imposing additional declaration or information requirements beyond those specified in the standard form. This provision aims to prevent the system from becoming another layer of bureaucracy rather than a genuine simplification tool. Countries retain flexibility to discontinue use of the system if it proves unsuitable for their needs. They can also propose modifications to the standard form to accommodate specific national requirements, subject to Commission approval. Legislative Progress and Timeline The proposal has moved through the EU legislative process with notable momentum. The Council adopted its general approach on May 22, 2025, introducing several enhancements to the original proposal. These include functionality for service providers to upload relevant supporting documents and clarifications regarding personal data processing and retention. The European Parliament's Employment and Social Affairs Committee and Internal Market Committee jointly reviewed the proposal, with rapporteurs presenting their draft report in April 2025. The committees voted on amendments in September 2025, adopting the report with strong support—84 votes in favor against 11 opposed. Parliament's position strengthens several aspects of the system. It requires that the public interface be free of charge and available in all official EU languages, with translation capabilities to help national authorities understand uploaded documents. The interface should also allow companies to save relevant data for future declarations, reducing repetitive data entry. Additionally, Parliament specified that information from the e-Declaration portal should be accessible to the European Labour Authority (ELA) and that the system must be compatible with existing national back-end infrastructure. Data retention limits for posting declarations and uploaded documents are also defined more precisely. With both Council and Parliament having adopted their positions, interinstitutional negotiations can proceed to finalize the regulation. Expected Benefits The European Commission estimates significant administrative savings from widespread adoption of the e-Declaration system. Time spent on posting declarations could decrease by approximately 73 percent when companies use the standardized digital form instead of navigating 27 different national systems. If all member states participate, overall administrative costs for businesses could be reduced by up to 81 percent. These savings contribute directly to the Commission's objective of reducing companies' reporting burden by 25 percent, as outlined in its Communication on long-term competitiveness. Beyond cost savings, the system promises improved enforcement capabilities. By centralizing declaration data within the IMI framework, national authorities can more effectively monitor compliance with posting rules and coordinate cross-border inspections. This enhanced oversight helps protect posted workers' rights while maintaining fair competition among service providers. The system also increases transparency. Member states have the option to automatically send copies of declarations to posted workers themselves, ensuring they are informed about the terms and conditions registered for their posting. Data Protection and Privacy The proposal establishes appropriate legal grounds for processing personal data in accordance with the General Data Protection Regulation (GDPR) and related EU privacy frameworks. Personal information collected through the e-Declaration portal is used exclusively for authorized purposes related to posting of workers enforcement. The Council's general approach clarified that personal data of relevant representatives can be processed and retained within the service provider category for longer than the standard 36-month period when permitted by certain national laws. This accommodation addresses practical enforcement needs while maintaining strong data protection principles. Posted workers have rights to access information about how their data is processed, flag inaccuracies, and request corrections. The system is designed to balance enforcement requirements with fundamental rights to privacy and data protection. Integration with Broader Initiatives The e-Declaration portal represents one component of the EU's broader efforts to modernize labor mobility and social security coordination. The Commission has also been developing the European Electronic Social Security Pass (ESSPASS), envisioned as a mobile application providing electronic access to social insurance information. ESSPASS would digitize the A1 certificate—a crucial document establishing which country's social security system applies to a worker operating in multiple member states. Combined with e-Declaration, these initiatives could substantially streamline the entire posting process, from initial declaration through ongoing compliance verification. The Council's general approach explicitly calls for the Commission to evaluate the implementation after five years and explore integration possibilities between the posting declaration process and the portable document A1 system. Industry Perspectives Business organizations have generally welcomed the proposal as a meaningful step toward reducing administrative complexity. Industry groups like the VDMA (German Engineering Federation) have long advocated for simplified posting procedures, noting the paradox that posting workers to the United States can sometimes be administratively easier than posting within the EU. However, some stakeholders have raised concerns about the voluntary nature of the system. If only some member states participate, companies may still need to navigate a mix of the e-Declaration portal and traditional national systems, limiting the efficiency gains. Labor organizations, represented by groups like the European Trade Union Confederation (ETUC), emphasize that simplification must not come at the expense of worker protection. They advocate for robust data collection requirements, adequate retention periods to support criminal investigations, and strong enforcement mechanisms to combat fraud and abuse affecting posted workers. Challenges and Considerations The success of the e-Declaration initiative depends heavily on achieving broad participation among member states. With voluntary adoption, there is risk of fragmented implementation where only certain countries use the system, limiting its effectiveness and cost-saving potential. Technical integration poses another challenge. Member states have invested significantly in their existing national posting declaration systems. Ensuring the e-Declaration portal can interface smoothly with diverse legacy systems requires substantial technical coordination and potentially costly adaptations. Different member states have varying information requirements based on their specific enforcement needs and legal frameworks. While the standard form includes approximately 30 data points considered essential, some countries may view this as insufficient for effective monitoring. Balancing standardization with legitimate national variations requires careful negotiation. There are also questions about the system's ability to detect and prevent abuses such as fraudulent postings or schemes designed to circumvent labor protections. The effectiveness of enforcement depends not just on having a digital system, but on adequate resources for inspections and cross-border cooperation among national authorities. Looking Forward The e-Declaration portal represents a pragmatic approach to a longstanding administrative challenge in the EU single market. By providing a voluntary common platform while respecting member state sovereignty over enforcement, the proposal seeks to achieve meaningful simplification without forcing a one-size-fits-all solution. The estimated €3 million cost over the first five years is relatively modest compared to the potential administrative savings for businesses and the enhanced enforcement capabilities for member states. If the system proves successful, it could serve as a model for similar initiatives in other areas requiring cross-border administrative cooperation. For businesses regularly posting workers across the EU, the e-Declaration portal offers the promise of a more streamlined, predictable process. Rather than maintaining expertise on 27 different national systems, companies could manage their posting obligations through a single, multilingual interface. For posted workers themselves, the system should contribute to better protection of their rights through improved transparency and more effective enforcement. Clear, standardized declarations make it easier for workers to understand the terms of their posting and for authorities to verify compliance with applicable rules. As the legislation moves toward final adoption, attention will focus on which member states choose to participate and how quickly the system can be implemented. The Commission's commitment to providing technical support and training will be crucial for ensuring smooth rollout and encouraging broad adoption. The e-Declaration portal may not solve all challenges related to posting of workers, but it represents meaningful progress toward making cross-border service provision more efficient while maintaining high standards for worker protection. In an increasingly integrated European economy, such pragmatic innovations are essential for balancing competitiveness with social protections. Practical Implications for Businesses Companies that regularly post workers should begin preparing for this transition now. This includes: Reviewing current posting procedures and identifying opportunities for standardization Ensuring HR and compliance teams understand the upcoming changes Evaluating whether the e-Declaration system, once implemented, would be beneficial for their specific posting patterns Maintaining awareness of which member states join the system and when Preparing to update internal policies and training materials as the regulation enters into force While the voluntary nature of the system means companies may still need to manage some national variations, the e-Declaration portal represents a significant step toward simplifying one of the more administratively complex aspects of operating in the EU single market.

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Europe's Digital Border Revolution: Understanding the Entry-Exit System

November 12, 2025
Compliance

The European Union is implementing one of the most significant transformations in border management in decades. The Entry-Exit System (EES), which began its progressive rollout on October 12, 2025, represents a fundamental shift from traditional passport stamping to sophisticated digital tracking of non-EU travelers crossing Schengen borders. What Is the EES? The Entry-Exit System is an automated digital platform designed to register third-country nationals traveling to 29 European countries for short stays. The system captures biometric data including fingerprints and facial images, along with travel document information and entry/exit dates. This digital infrastructure replaces the manual passport stamping process that has been the standard for decades. The system applies to the 29 countries that participate in the Schengen Area, including 25 EU member states (excluding Cyprus and Ireland) plus Iceland, Norway, Switzerland, and Liechtenstein. This unified approach ensures consistent border management across much of Europe. Progressive Implementation Timeline Rather than launching simultaneously across all borders, the EU has adopted a phased approach to minimize disruption. Beginning on October 12, 2025, member states are gradually implementing the system at their external border crossing points over a six-month transition period. During this progressive rollout, countries have the flexibility to determine which border crossing points will adopt EES first and on what timeline. For the initial 60 days, some member states may operate the system without full biometric capabilities. By the end of the first month, countries aim to register at least 10 percent of border crossings, increasing to a minimum of 35 percent at the three-month mark. By April 10, 2026, the EES will be fully operational at all external border crossing points throughout the participating countries. Until that date, traditional passport stamps will continue alongside the new digital system. Who Does EES Apply To? The system specifically targets non-EU nationals making short stays in the Schengen Area. This includes both visa-exempt travelers and those holding short-stay visas who plan to remain in the Schengen zone for up to 90 days within any 180-day period. British nationals, following Brexit, are among those now subject to EES registration. Other affected travelers include citizens from countries like the United States, Canada, Australia, Japan, and numerous other nations outside the European Union. Importantly, several categories of travelers are exempt from EES registration. EU citizens and their family members are not subject to the system. Additionally, individuals holding residence permits issued by Schengen states, including special legitimation cards and diplomatic credentials, are excluded from EES requirements. The Registration Process When non-EU travelers arrive at their first Schengen entry point after the system becomes operational, they will undergo a one-time registration process. This involves providing fingerprints, having a facial image captured, and supplying relevant passport and travel information. At certain locations, such as Eurostar terminals, pre-registration kiosks may be available opposite priority ticket gates. These allow travelers to complete their biometric registration before reaching the actual border control point, streamlining the overall process. Once registered in the system, the traveler's information remains valid for three years or until their travel document expires, whichever comes first. Subsequent entries and exits will be automatically recorded, with border authorities able to verify the traveler's identity and check compliance with authorized stay periods. Benefits and Security Enhancements The EES addresses several critical shortcomings of the manual stamping system. Traditional passport stamps are time-consuming, fail to provide reliable data on actual border crossings, and cannot systematically detect individuals who overstay their authorized periods. With real-time digital tracking, border authorities gain immediate access to comprehensive information about who enters the EU and when. This enhanced visibility helps prevent irregular migration and strengthens the detection of identity fraud and document falsification. The system also facilitates more efficient use of automated border control gates and self-service checkpoints, potentially reducing waiting times for compliant travelers once the system is fully operational. These technological improvements align with the EU's broader Security Union objectives and support efforts to combat cross-border crime and terrorism. Implications for Business Travelers For organizations with employees traveling to Europe, EES introduces new compliance considerations. Business travelers will undergo biometric registration at their first Schengen entry point, and the system will automatically track their time within the zone. Non-compliance carries serious consequences. Individuals who overstay their authorized period or engage in unauthorized work may face entry into the Schengen Information System, potential five-year travel bans, and other sanctions. Employers may also face audits and inspections related to their employees' compliance with entry conditions. Companies should ensure their business travel programs account for these changes. This includes understanding the 90/180-day rule, tracking employee travel to prevent inadvertent overstays, and recognizing that personal travel to the Schengen Area counts toward the same limit as business trips. Data Protection and Privacy The EES operates under stringent data protection standards aligned with EU fundamental rights and privacy regulations. Biometric information and travel data are stored securely and used exclusively for authorized border management and law enforcement purposes. Travelers maintain rights regarding their personal information, including the ability to request access to their data and seek corrections if necessary. The system's design incorporates multiple safeguards to prevent unauthorized access or misuse of sensitive biometric information. Looking Ahead The introduction of EES represents just one component of the EU's modernized border management architecture. The system will eventually work in conjunction with the European Travel Information and Authorization System (ETIAS), currently scheduled for launch in late 2026. While ETIAS will pre-screen visa-exempt travelers before they depart for Europe, EES will handle the actual recording of border crossings. Together, these systems create a comprehensive framework for managing third-country national movement across Schengen borders. As the progressive rollout continues through early 2026, travelers should stay informed about which border crossing points have implemented the system and what to expect during their journeys. Border authorities and transport operators across Europe are conducting awareness campaigns to help travelers prepare for these significant changes in border procedures. Preparing for Your Journey If you're planning travel to the Schengen Area, arrive at departure points with adequate time for the new procedures, especially during the transition period when both traditional and digital processes may be operating simultaneously. Some delays should be expected as border personnel and travelers adjust to the new system. Check with your specific point of entry about their EES implementation status, as some locations began full operations on October 12 while others are phasing in capabilities gradually. Major airports in Switzerland, including Geneva, Zurich, and Basel, were among the first to implement the system. The Entry-Exit System marks a historic transformation in how Europe manages its borders. While the transition requires adjustment from travelers and border authorities alike, the long-term goal is a more secure, efficient, and transparent system that benefits both European security and legitimate travel.

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EU Court Brings Clarity on Cross-Border Social Security

September 25, 2025
Compliance

For years, companies and employees have wrestled with one question: how do you decide which country’s social security system applies when someone works in more than one EU state? In September 2025, the Court of Justice answered that question in the Hakamp case (C-203/24). The message was simple: when you are applying the 25% test under EU Regulation 987/2009, the only things that count are working time and pay. What happened in Hakamp? A Dutch resident worked for a Liechtenstein employer on a ship that operated across the Netherlands, Belgium and Germany. Dutch authorities argued that “other circumstances” should be taken into account when deciding if at least 25% of the work was done in the Netherlands. The Court rejected that approach. The judgment makes it crystal clear: ≥25% of time or pay in your home country → insured there. <25% → insured where the employer is based. That’s it. No extra factors like where the company is registered or where equipment is located. Why this matters For employers, this means less guesswork and fewer disputes. You can rely on objective numbers instead of subjective interpretations. For employees, it means certainty about which system they’re covered under. How this links with telework This decision sits alongside the Framework Agreement on cross-border telework, in force since July 2023. That agreement lets employees work up to 49.9% from their country of residence and still stay covered in the employer’s state, provided an A1 certificate is applied for under Article 16. So, the baseline 25% test still applies, but there’s flexibility if the telework agreement is used. What employers should do Track working time and pay by country. Keep records up to date. Use the telework agreement if it applies to your situation. Revisit old cases if national authorities relied on “other circumstances” instead of time/pay. The takeaway With Hakamp, the Court has finally put an end to inconsistent approaches. For social security coverage, it all comes down to two objective numbers: either the share of working time or the share of remuneration earned in each country. In practice, most employers track working time, but pay can also be used where it provides a clearer measure. Case C-203/24, Hakamp

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EU Posted Workers E-Declaration Portal: A Big Step in Single Market Digitalization

September 25, 2025
Compliance

On 13 November 2024, the European Commission proposed a regulation (COM/2024/531) to create a digital portal for declaring posted workers across the EU. On 22 May 2025, the Council adopted its negotiating position, paving the way for talks with the European Parliament. This initiative is part of the EU’s broader push to cut red tape and modernize the Single Market. Why it matters A “posted worker” is someone sent by their employer to work temporarily in another Member State — whether through a services contract, intra-group transfer, or agency posting. According to the European Labour Authority, there are about 3.6 million postings each year, involving 2.6 million workers, and roughly 1.2million of those work in two or more countries. Right now, all 27 Member States require declarations before postings, but each country’s system looks different. They’re not connected to each other, so companies face duplicated forms, unfamiliar portals, and time-consuming admin. What the new portal will do The regulation would build a multilingual electronic interface, connected to the Internal Market Information System (IMI) — the EU’s existing tool for administrative cooperation. The idea is to reuse the infrastructure already working for posted road transport workers, where a similar IMI link has been live since 2022. Core functions will include: Secure accounts for employers to access the system Creation, submission, and management of posting declarations A standard form covering details of the employer, workers, assignment, service recipient, and liaison contact Direct transmission of declarations into the IMI for authorities The Council’s position strengthens this with extra features: Employers can upload supporting documents directly Built-in data validation and communication tools between authorities and companies Workers can access electronic extracts of their postings Expected benefits Lower costs and less admin: The Commission estimates completing a declaration will be 73% faster than the current EU average. Cost savings could reach 58% even if only some Member States join. If all 27 participate, administrative costs could fall by as much as 81%. Fairer competition and better worker protection: A harmonized, standard form should make checks easier, helping ensure posted workers enjoy the rights they’re entitled to. For context, a 2024 business survey found that 46.1% of over 1,000 companies saw significant problems or uncertainties with posting. Time to file a declaration today ranges from 21 minutes (Estonia/Slovakia) to 87 minutes (Greece). The initiative fits into the EU’s promise to cut reporting burdens by 25% while keeping worker protections intact. It also supports the Commission’s digital transformation agenda. As the Council put it: “Digitalising the administrative work for posted workers is a game changer in the internal market for services. Sending employees to another member state will be faster, cheaper and easier; workers will continue to enjoy their rights, and the single market for services will be closer to completion.” Looking ahead With the Council position now agreed, attention turns to the European Parliament. The file is already marked as “close to adoption” on the EU’s Legislative Train Schedule, so final approval could come soon. Once in place, the e-declaration portal will make posting workers simpler for companies, lighter for authorities, and fairer for workers — a practical win for a more digital, integrated Europe.

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