India–UK Social Security Agreement 2026: Employer Guide

GST Composition Scheme: A Boon for Small Businesses

24 Oct 2026

Updated 24 October 2026 · By Regi Tom Antony, FCA, MBA (Australia), ACMA (UK), CGMA (USA), CISA (USA)

A client who runs a mid-sized IT services company in Infopark called me in August with a question I have heard in different forms many times since. "We are sending four engineers to a client site in Manchester for two years. Do we still have to pay UK National Insurance on top of PF here?"

From 15 July 2026, for most genuine short-term postings, the answer is no. If the employee qualifies as a detached worker and you have the right certificate, contributions continue in the home country only, for postings expected to last up to 60 months. The catch is in the conditions, the paperwork and the position of people who were already posted before July.

What the agreement actually is

India and the UK signed an Agreement on Social Security relating to Social Security Contributions on 10 February 2026. The UK calls it a Double Contributions Convention, or DCC. It came into force on 15 July 2026, the same day as the India–UK Comprehensive Economic and Trade Agreement.

It is a contributions-only agreement. It decides which country's system you pay into; it does not create pension rights you would not otherwise have, and it does not cover the self-employed. The general rule remains that contributions are paid where the work is done. The relief is an exception for detached workers.

Who counts as a detached worker

Under Article 8, a person is a detached worker if they are employed in their home country by an employer that normally carries on business there, are sent by that employer to work in the other country, and the work there is not expected to exceed 60 months.

You may see older articles quoting 36 months. That was the figure in the text signed in February; an amendment has since raised it to 60 months, as HMRC's National Insurance Manual (NIM33251 and NIM33258) now confirms. If a posting was planned for less than 60 months and later stretches beyond that, home-country cover continues only until the posting ends or reaches 60 months, whichever comes first.

There is a threshold condition that catches people out. The employee must have been subject to home-country contributions, with both employee and employer contributions paid, for at least 30 days before leaving or for the calendar month before the posting begins. Someone hired in Kochi on Monday and put on a flight to London on Friday will usually not qualify.

There is also a gap rule. After one detachment ends, a fresh one cannot start until six months have passed. If the earlier posting was shorter than six months, the gap must be at least as long as that posting.

The certificate of coverage

The exemption is not automatic in practice. The host country will expect proof that the person remains covered at home, and that proof is a certificate of coverage.

For an Indian employee going to the UK, the certificate is issued by the Employees' Provident Fund Organisation, which the agreement names as India's competent institution. EPFO announced its procedure shortly after 15 July, with the employee applying through the employer and the regional office issuing the certificate. For a UK employee coming to India, HMRC issues the certificate through its CA9107 application, which was updated in July 2026 to include India.

Once covered, the Indian detached worker and the employer keep paying Indian contributions on total wages, as defined in the Code on Social Security, 2020. You are not escaping contributions; you are paying them in one place instead of two.

What about people already posted before 15 July?

The agreement does not treat existing secondees as detached workers. However, HMRC and EPFO have agreed a transitional arrangement under Article 12, explained in HMRC's manual at NIM33262.

Take Priya (not her real name), a Kochi-based analyst whose employer sent her to London on 1 January 2026. Before the agreement, she was exempt from UK National Insurance for her first 52 weeks under UK domestic rules. Under the transitional arrangement she stays outside UK National Insurance until 1 January 2027, and she does not need an Indian certificate for that. From the following contribution week, she becomes liable to UK National Insurance like any UK employee. Because she was already in the UK on 15 July, she cannot become a detached worker for the rest of this posting. If her posting runs to 2028, her employer needs to budget for UK contributions from January 2027 and look at how her Indian PF position is handled alongside.

The mirror image applies to UK staff who were already in India on 15 July. They can apply to HMRC to keep paying UK contributions for the rest of their first 52 weeks, after which Indian rules apply.

The Indian PF angle for UK nationals here

For foreign companies with Indian subsidiaries, and for Indian companies hosting UK staff, the question is usually PF. India's provident fund rules treat foreign nationals working for Indian establishments as international workers who must contribute, generally on their full salary. Workers covered by a social security agreement and holding a home-country certificate of coverage can be excluded. With the UK agreement now in force, a UK secondee with an HMRC certificate falls into that category for the period it covers. Without the certificate, Indian PF applies from the first month.

Social security is not income tax

People often ask me whether this agreement means the engineer's salary is no longer taxed in the UK. It does not. Income tax is governed by domestic law and the separate India–UK Double Taxation Avoidance Agreement, with its own rules on residence, the 183-day test and who bears the salary cost. A secondee can be fully covered by the DCC and still owe UK income tax from day one, or the reverse.

Another common question is whether someone posted for, say, 70 months can claim the exemption for the first 60. If the posting was expected from the outset to exceed 60 months, the detached worker rule does not apply at all. Article 12 lets the two authorities agree exceptions for individuals, but treat that as a request made in advance, not an assumption to budget on. Secondments are one of the areas we cover in our cross-border tax and FEMA work, because payroll, treaty and foreign exchange questions tend to arrive together.

If you want to talk through your own case, write to us at letstalk@rtaandassociates.com.

For how this fits with FEMA, treaties and GST more broadly, see our guide to cross-border tax and FEMA advisory.

Related guides

Regi Tom Antony, FCA, MBA (Australia), ACMA (UK), CGMA (USA), CISA (USA)
Regi Tom Antony & Associates, Chartered Accountants, Kochi

This is general information based on the law as at 24 October 2026, not advice for your particular situation.