Unpacking the Definitions of “Cross-border Worker” and “Posted Worker”
07/10/2025
In the context of the EU labour market, it is important to distinguish between two different types of workers operating across national borders within the EU, namely cross-border workers and posted workers. Navigating employment across national borders requires careful attention to key issues including workers’ rights as well as taxation, social security and residence rules.
Who is a “cross-border worker”?
In general terms, a “cross-border worker” (or “cross-border commuter”) is someone who lives in one EU country and travels regularly to work in another EU country – usually every day or every week. The term “cross-border worker” may be understood differently under social security or tax rules.
The term “cross-border worker” is often used interchangeably with “frontier worker”, but the two are not always the same. Frontier workers are employed in the border area of an EU country and return daily or at least once a week to the border area of a neighbouring country, where they live and are a citizen. Cross-border workers may work anywhere in the host country, not just near the border, making them a broader category.
A cross-border worker can also be a “seasonal worker” – under EU law, this refers to a person from outside the EU who comes to an EU country for a limited time to do seasonal jobs, like in the agriculture industry (e.g. fruit pickers) or tourism industry (e.g. cleaners in hotels). They have permission to say temporarily and have a fixed-term contract with an employer in that country. Even though this definition focuses on non-EU nationals, the term “seasonal worker” is also used more generally to include nationals from the same country or from other EU countries doing temporary employment tied to specific periods of the year and industries.
The term “cross-border worker” can also cover those workers who live in one country but work remotely for an employer based in another country.
In sum, therefore, cross-border workers encompass:
- Frontier workers
- Seasonal workers
- Remote workers
So, who is a “posted worker”?
Under the Posting of Workers Directive (PWD), a “posted worker” is defined as: “a worker who, for a limited period, carries out his work in the territory of a Member State other than the State in which he normally works.”
To better understand this definition, it helps to consider its key elements:
The worker has an existing employment relationship in their home State and remains employed by the same employer throughout the posting.
The worker is sent to a different Member State for a limited period. A posting must be temporary in nature.
The work is carried out in a Member State other than the one where the worker normally works.
In terms of the PWD, a company can post workers to another State in three scenarios. Let’s break them down
Your business has a contract to provide services in another Member State?
You can post your workers there to carry out those services – on your account and under your direction.
Part of a multinational group?
You can post a worker to a branch, subsidiary, or affiliate in another Member State — as long as it is part of the group.
Are you a temporary work agency or placement firm?
You can post a worker to a client (user undertaking) based or operating in another Member State.
Workers sent temporarily to another Member State on business trips or for purposes like attending meetings, conferences, or training courses – without providing a service – are not considered posted workers.
Posted Drivers
When discussing posted workers, there is a specific category worth highlighting: the posted drivers. A driver is considered as posted when conducting cross-trade or cabotage operations in a Member State other than where their employer is established.
This involves transport between two Member States or between an Member State and a non-EU country, and the driver’s employer is not established in any of these countries.
This refers to domestic transport operations carried out temporarily within a Member State other than where their employer is established
However, drivers engaged in certain activities—such as international bilateral transport—are not considered as posted.
Labour Mobility in Number
The “Annual Report on Intra-EU Labour Mobility – 2024 Edition” finds that the number of cross-border workers and postings increased in 2023. It reveals that there were approximately 1.8 million cross-border workers in the EU and EFTA. The total number of postings in the EU and EFTA reached 5.5 million. You can access the full report HERE.
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