The outcome of the revision of the Coordination Regulations remains uncertain.

UM – 07/2025

Back in May, the mood was still optimistic. After a lengthy pause, negotiations resumed on the revision of Regulations (EC) No 883/2004 and (EC) No 987/2009 on the coordination of social security systems. Following technical clarifications, two political trilogues were planned for June to break the deadlock. The chances were not bad – after all, the Council had, albeit with some difficulty, reached an agreement on a compromise proposal in the Committee of Permanent Representatives (Coreper) on 11 April.

A missed opportunity

The political trilogue began on 3 June, but according to reports, it started late and was substantively disappointing. It apparently amounted to little more than a restatement of well-known positions. At least a second negotiation date – potentially 20 June – was discussed. However, the then Polish Council Presidency failed to issue a formal invitation. It quickly became apparent: nothing more would come of it.

Denmark opts out

Denmark has held the Council Presidency since July. But the Danes had already indicated early on that they did not intend to take on the “883” file. So what now? According to reports, Commission President Ursula von der Leyen had announced before the start of the negotiations that this would be the final attempt. Now that the talks have ended without result, it is unclear whether and how the process will continue. The Commission has yet to comment on how it intends to handle this difficult dossier going forward. Whether it will actually withdraw the proposal is still unknown. In any case, the mood is no longer as positive as it was in May.

Focus shifts to Cyprus

Still, the revision of the coordination regulations – which has now been under negotiation for nearly nine years – does not yet appear to be completely off the table. Attention is therefore turning to the country set to take over the Council Presidency after Denmark: Cyprus. If that happens, the Cypriots will inherit a bundle of unresolved issues, including the A1 procedure, the export of unemployment benefits, and applicable law (see also News 05/2025). But they would also have the opportunity to finally push through the parts of the legislative process that have already been agreed upon. For the German Social Insurance (DSV), these include, in particular, the provisions for coordinating long-term care benefits and the urgently needed clarification as to which health insurance fund is responsible for covering the healthcare costs of children whose parents live and work in different Member States. Legal clarity in this area could finally put an end to long-standing disputes between health insurance institutions.

What happens next?

In mid-March, the Commission announced a package on labour mobility, due to be presented in early 2026 in the form of a communication. Among other things, it is expected to include information on the European Social Security Pass (ESSPASS) and the digital procedure for carrying the A1 certificate. If no clarity on the future of the coordination regulations dossier is provided in the coming months, the Commission should use this package to indicate the path forward.