Social insurance and pensions for Ukrainians working in the EU: where contributions count, A1 and aggregation of periods (2026)

The main point: if you are Ukrainian and work in the EU, your social contributions are paid in the country where you actually work, and the legislation of only one country applies to you. The EU coordination rules (aggregation of periods, the A1 document) start to apply when you are linked to at least two EU states. Periods accrued in Ukraine count towards an EU pension not automatically, but only where there is a bilateral agreement between Ukraine and the specific country.

Where contributions are paid: the country-of-work rule

The basic principle of coordination is lex loci laboris (Art. 11(1) of Regulation (EC) No 883/2004): an employed or self-employed worker is subject to the legislation of the state where they work, even if they reside in another EU country. The single-country insurance principle applies: at any one time you are insured in only one state, and the other national systems are excluded.

• If you work under an employment contract in Poland, Czechia, Germany, etc., the employer pays contributions there, and that is where you accrue EU pension periods.
• If you live in one EU country but work in another, contributions go to the country of work, not of residence.
• As a general rule, double contributions (both in the country of work and at home) are not paid.

When a Ukrainian is covered by EU rules at all

Coordination is extended to third-country nationals by Regulation (EU) No 1231/2010. It applies to those who legally reside in the territory of a member state and are in a situation that is not entirely internal to one country (a cross-border situation within the EU). The practical conclusion for Ukrainians:

• If you legally reside and work in only one EU state, the EU coordination rules do not apply to you; only the national legislation of that country applies (its rates, its pension rules).
• EU coordination (aggregation of periods between EU countries, A1, export of a pension within the EU) kicks in when you are linked to at least two EU states — for example, you worked in Poland and then moved to work in Czechia.
• Regulation 1231/2010 does not apply to Denmark.

Aggregation of periods and a pension in the EU

If you have worked in several EU countries, insurance periods are aggregated (Art. 6 of Regulation 883/2004) in order to reach the minimum period for a pension entitlement. The calculation of the pension itself is governed by Art. 52:

• The periods from all EU states are added together to cross the minimum-period threshold for granting a pension.
• Then each country in which you paid contributions calculates its share of the pension (pro rata, Art. 52) — in proportion to the periods worked there.
• A pension granted in one EU state can be received while living in another EU state.

The coordination rules apply in the 27 EU states, as well as in Norway, Iceland, Liechtenstein (EEA) and Switzerland.

Why the A1 document is needed

An A1 is a portable document confirming the legislation of which country your social insurance is subject to. It does not in itself grant any benefits, but proves where you are insured in order to avoid double contributions. An A1 is needed in two typical situations:

• Posting (Art. 12 of Regulation 883/2004): the employer temporarily sends you to another EU country — you remain in the system of the sending country for up to 24 months.
• Work in two or more states (Art. 13): the A1 determines the legislation of which country applies (usually the country of residence, if a substantial part of the activity is carried out there; otherwise the country where the employer is registered).

Ukrainian periods: counted only under a bilateral agreement

EU law does not oblige EU countries to credit Ukrainian periods towards a pension — coordination under 883/2004 applies between EU/EEA states, not with Ukraine. The Ukraine–EU Association Agreement (in force since 1 September 2017), Art. 17, guarantees legally employed Ukrainians non-discrimination as regards working conditions, pay and dismissal, but does not create a mechanism for aggregating pension periods between Ukraine and the EU.

The crediting of Ukrainian periods towards a pension is provided by separate bilateral social security agreements. Ukraine has concluded such agreements, among others, with:

• Poland — the agreement has been in force since 1 January 2014; ZUS may take into account periods accrued in Ukraine.
• Czechia, Spain, Portugal, Estonia, Latvia, Lithuania, Slovakia, Bulgaria.

Under such an agreement you receive two separate pensions: part from the EU country for periods there, and part from Ukraine for periods in Ukraine. Without a bilateral agreement, Ukrainian periods are generally not credited towards a foreign pension.

What the April 2026 reform changes (not yet in force)

On 22 April 2026, the Council of the EU and the European Parliament reached a provisional agreement on updating Regulations 883/2004 and 987/2009 (confirmed by representatives of the member states on 29 April 2026). Key changes regarding postings:

• A worker must be insured in the sending country for at least 3 months before the posting begins.
• Between consecutive postings of the same worker, a 2-month break is mandatory.
• The maximum posting period remains 24 months.

The agreement still has to be finally approved by the European Parliament and the Council and, for most of its provisions, will take effect about 24 months after publication of the regulation, so for now these rules do not apply.

What a Ukrainian should do in practice

• Check that contributions are actually being paid in the country of work — this is your future EU period.
• For a posting or work in 2+ EU countries, ask your employer to obtain an A1.
• If you are planning a pension taking Ukrainian periods into account, check whether there is a bilateral agreement between Ukraine and your country of work at the social security institution (for example, ZUS in Poland) or at the Pension Fund of Ukraine.
• Keep documents on periods of work and contributions in each country — they will be needed for aggregation.