[PUBLISHED]
A Polish welding subcontractor crossing the border into Sweden, Finland, France, Germany, Denmark, or Belgium faces five overlapping but distinct compliance regimes. “We have A1” is the baseline — the thing that says the social security contributions stay in Poland. It is necessary. It is not sufficient.
Here is what each jurisdiction looks like on top of the A1 baseline. The one thing these regimes have in common: inspection is binary. If the paperwork is not in place before the welders arrive on site, the site supervisor sends the team back.
Sweden — ID06 and CBA alignment
Sweden’s posting-compliance gates are ID06 (site-attendance system — every person on a Swedish industrial site needs an ID06 photo card), Utstationeringsregistret notification to Arbetsmiljöverket before first day, and F-skatt registration with Skatteverket for the operating period.
Wages follow the applicable sectoral CBA — IF Metall for piping and manufacturing scope, Byggnads where the work is classified as construction. Wage alignment is not optional; the Swedish unions verify this on sites.
Failure mode: no ID06 card, no site entry. The supervisor physically does not let the welder through the gate.
Finland — Työturvallisuuskortti
Finnish industrial sites — refineries, chemical plants, pulp and paper — gate access on the Occupational Safety Card (Työturvallisuuskortti). Posted-worker notification goes to Aluehallintovirasto (AVI) under the Posted Workers Act.
Wages follow the Finnish sectoral CBA (Teknologiateollisuus for metalworking / Rakennusliitto for construction).
Failure mode: expired Työturvallisuuskortti. The gate scanner reads the card, sees it is expired, sends the welder home.
France — SIPSI declaration and local representative
France’s posting framework is document-intensive. The SIPSI declaration has to be filed on the French government portal before the posting, not during. A représentant en France must be named and available for the duration of the posting, per Code du travail Article R1263-2-1. The Carte BTP is required for site personnel performing construction work.
Wages follow the applicable Convention Collective — Métallurgie for metalworking scope, Bâtiment for construction.
Failure mode: SIPSI not filed. URSSAF inspection finds this during a site visit, the main contractor absorbs penalties and the subcontractor is off the approved-supplier list.
Germany — Zoll Meldepflicht and SOKA-BAU
Germany distinguishes “construction” scope from pure piping/manufacturing scope and the posting stack differs accordingly.
For any work on German industrial sites, Zoll Meldepflicht (notification to German customs under the AEntG / GMLG) is mandatory before site entry. If the scope is classified as construction, add SOKA-BAU registration with monthly contribution filings, plus Berufsgenossenschaft membership (BG BAU for construction or BGHM for metal/wood).
Wages follow the relevant Tarifvertrag — Bauhauptgewerbe for construction, Metall for manufacturing. Mindestlohn is the floor; CBA-specific rates are typically above.
Failure mode: scope misclassified. Calling a site installation “piping” when the SOKA-BAU definition calls it “construction” results in back-payment of SOKA-BAU contributions plus penalties.
Belgium — Limosa L-1 and VCA
Belgian posting is gated on the Limosa L-1 declaration filed before each posting, plus Checkinatwork daily registration for high-value contracts. Belgian and Dutch petrochemical sites (Antwerp cluster — BASF, Covestro, INEOS, Borealis) also require VCA certification at company level and VCA Basic Safety or VOL VCA at personnel level.
Wages follow the applicable Paritair Comité CCT — PC 111 for metal construction, PC 124 for construction.
Failure mode: no VCA card at the gate. Antwerp-cluster sites run VCA verification at site entry; the welder without a valid card does not come in.
What we do with this
We treat all six jurisdictions as standing compliance, not per-mobilization scramble. This means:
- A1 PDs standing at-ready for the active welder pool, refreshed on a rolling basis as deployment schedules change.
- ID06, Työturvallisuuskortti, BTP, and VCA cards for the welder pool that can be deployed into these jurisdictions — tracked against expiry dates in a scheduling matrix.
- SOKA-BAU, SIPSI, RUT, Tööinspektsioon, and Limosa filing capability — actioned within the timelines needed by the contract.
- A named welding coordinator (EN ISO 14731) who owns the posting-and-compliance stack alongside the welding-quality stack.
For a main contractor, the test is simple: can the subcontractor arrive at the gate with the paperwork sorted? We treat that as the minimum, not a differentiator. See /countries/ for the full per-jurisdiction stack.