Global Employment Tax and Compliance Newsletter. September 2026

Labour law, tax and immigration usually land on different desks. HR and legal follow contracts and dismissal rules, finance tracks contributions and withholding, and mobility teams watch permits and fees. An international hire depends on all three at once. A work permit salary floor sets the offer. A contribution increase moves the budget that offer […]

Global Employment Tax and Compliance Newsletter. September 2026

Labour law, tax and immigration usually land on different desks. HR and legal follow contracts and dismissal rules, finance tracks contributions and withholding, and mobility teams watch permits and fees. An international hire depends on all three at once. A work permit salary floor sets the offer. A contribution increase moves the budget that offer was approved against. A shorter notice period changes what an exit will cost before the person has even started.

This September edition brings September’s changes from all three onto one page, so the offer, the budget and the permit are settled against the same set of rules.

United Kingdom Extends Right to Work Liability Beyond Direct Employees

From 1 October 2026, the UK Right to Work regime will apply to a much wider range of working arrangements, extending beyond traditional employees.

Businesses can face civil penalty liability for illegal working involving workers engaged under worker contracts, individual subcontractors and certain individuals supplied through other businesses or online matching services. Liability can also extend further up the contractual chain where another organisation provides workers to fulfil a contract.

Businesses can protect themselves by carrying out prescribed Right to Work checks or meeting the new requirements governing contractual arrangements with labour suppliers.

For employers using outsourced workers, subcontractors or other non-standard workforce models, Right to Work compliance can no longer be treated solely as the responsibility of the organisation directly engaging the individual.

United Kingdom Tightens Sponsor Management System Security

The UK Home Office has introduced new security and user-management requirements for organisations holding sponsor licences.

Mandatory multi-factor authentication for Sponsor Management System users began rolling out on 3 September 2026 and is expected to cover all sponsors by November. Organisations granted a new sponsor licence from 9 September have MFA enabled from the outset.

From 9 September, sponsors can no longer appoint new Level 2 users. Existing Level 2 users must either be upgraded to Level 1, where eligible, or removed by 8 March 2027, when the Level 2 role will be abolished.

The Home Office is also introducing controls for inactive SMS accounts. Sponsors must ensure users access the system regularly and keep their personal and contact details current; failure to maintain active users can put the sponsor licence at risk.

EU Introduces New Social Security Rules for Posted Workers

The EU is finalising a major revision of its social security coordination rules, with important changes for employers sending workers temporarily to another Member State.

To remain covered by the home-country social security system, a worker must have been insured there for at least three months before the posting.

Postings of up to 24 months can continue under home-country coverage, but a two-month break is required before a new posting to the same country. Employers will also generally need to notify the competent authorities before the cross-border work begins, with limited exceptions for business trips and very short postings.

For international employers, the changes make social security status something to establish earlier in assignment planning. Employee history, posting duration and advance notification will all affect whether home-country coverage, and the corresponding A1 certificate, can be maintained.

Spain Expands Employer Information Duties from 5 October

Spain has adopted new rules requiring employers to give workers more detailed written information about their employment conditions before work begins.

The information must cover core terms including pay and its components, working time, overtime, probation, training, applicable collective agreements and termination procedures. Employers must also disclose the existence of algorithmic or automated decision-making systems where they influence working hours, task allocation, pay, progression, workplace or termination decisions.

Employees working abroad must receive additional information before departure, including the destination country, assignment duration and payment currency. Changes to covered employment conditions must be communicated no later than the date they take effect.

The Royal Decree was published on 15 September 2026 and takes effect on 5 October 2026. Employers should review contracts, onboarding documentation and processes for communicating changes to employment terms before the new requirements begin.

Denmark Introduces New Work Permit Route for Certified Employers

Denmark has adopted a new work permit scheme allowing qualifying certified employers to recruit foreign workers under collective agreement-based conditions.

To use the scheme, employers must be certified by the Danish Agency for International Recruitment and Integration (SIRI), be covered by a qualifying collective agreement and meet the scheme’s requirements on pay and working conditions. The route is intended to give eligible employers another way to recruit workers from outside the EU where the existing immigration schemes do not fit the hire.

The Danish Parliament adopted the legislation on 3 September 2026. The new scheme will take effect on 1 January 2027.

France Cuts Statutory Sickness Benefit Duration

France has reduced the maximum period for statutory daily sickness benefits from three years to one year for certain employees on prolonged sick leave.

The three-year entitlement remains for employees with qualifying long-term conditions. The new rules apply to sick leave prescribed from 15 October 2026 and to certain ongoing absences that reach six months from that date.

UAE Ends Nafis Reimbursement of Employer Pension Contributions

The UAE has changed pension support under the Nafis programme for Emiratis working in the private and banking sectors.

From September 2026, Nafis will no longer reimburse the employer’s statutory pension contribution. Employers must pay their legally required share in full, while Nafis support will cover only the contribution payable on behalf of the eligible Emirati employee.

The pension support applies to eligible UAE nationals earning between AED 6,000 and AED 20,000 per month and registered with the GPSSA, Abu Dhabi Pension Fund or another UAE pension fund.

Denmark Introduces Mandatory Worker ID Cards on Large Construction Sites

Denmark has adopted a new law requiring workers on large construction and civil-engineering projects to carry an identification card while on site.

The requirement applies to projects with a total value above DKK 100 million. The ID system will allow authorities to identify who is working on a site, which employer they work for and whether foreign workers hold the required residence and work permissions.

The law also introduces registration and reporting requirements intended to strengthen enforcement against illegal employment, undeclared work and non-compliance involving foreign labour. Authorities including the Danish Working Environment Authority, tax administration and immigration authorities will be able to use the ID system during inspections.

EU Pay Transparency Implementation Remains Fragmented

Three months after the deadline for transposing the EU Pay Transparency Directive, only five Member States — Italy, Lithuania, Malta, Slovakia and Greece — have finalised full national legislation.

Implementation across the rest of the EU remains uneven. Some countries have draft laws under consideration, while others have introduced only partial measures or have yet to publish implementing legislation. National commencement dates also differ: for example, most of Greece’s employer obligations take effect on 1 November 2026.

The Directive affects recruitment, pay structures and employee information rights, and introduces gender pay gap reporting requirements for larger employers.

Serbia Raises Minimum Wage for 2027

Serbia has set a new nationwide minimum wage for 2027, increasing the minimum net hourly rate from RSD 371 to RSD 405.

The new rate applies from 1 January through 31 December 2027. Because Serbia calculates the minimum wage by working hour rather than as a fixed monthly salary, the actual monthly minimum will vary with the number of working hours in each month.

The Government has also announced that the non-taxable portion of salary will rise from RSD 34,221 to RSD 37,369 from January 2027.

Permanent Establishment Risk

A company can create a taxable business presence in another country without opening an office or registering an entity. The risk can arise from what employees do, the authority they exercise, the places they use and how consistently the business operates there.

Our new Permanent Establishment Risk Guide explains the main PE tests, the cross-border working arrangements that can increase risk, and what the Hyatt ruling tells employers about control, continuity and the use of premises.

Read the Permanent Establishment Risk Guide →

Global EOR or Global Mobility Company

Global EOR or Global Mobility Company

A company may own entities in three countries and need to hire in seven. The transfers into its own entities are work for a global mobility partner. In the remaining four, Acumen acts as the legal employer, and the hires go ahead without the client incorporating.

The guide compares the two services point by point and maps the seven areas of cross-border employment, showing who carries the employer’s side of each under either arrangement. It is written for teams planning hires across several markets at once, who need to settle which markets go to which partner before the first offer goes out.

Read the guide →