Totalization Agreements 2026: All 31 and the 15.3% Trap

Two freelancers earning $100,000 can hand over a $14,130 difference in social security for doing identical work from identical laptops, and the variable is not their income, their structure or their visa — it is whether the country they moved to appears on a list of 31 published by the Social Security Administration. A totalization agreement is the instrument that decides it: a bilateral treaty that assigns your social security coverage to exactly one country instead of leaving two of them to bill you in full. On 1 September 2026 Romania became the thirty-first. Seven EU member states are still not on the list at all, and several of them are the ones being marketed hardest to remote workers.

We built this from the primary documents, because the three pages currently ranking for this term disagree with each other: one publishes 30 countries and states that Romania is not included, one publishes 30 with no dates at all, and one claims 31 while omitting Romania from its own list. The SSA's operating manual settles the count, the IRS settles what the foreign earned income exclusion does not reach, and the Belgian federal social security service — depositary of the EU's telework agreement — settles the European half. We ran the 2026 self-employment arithmetic ourselves at six income points.

Key takeaways

• There are 31 agreements in force, not 30. Romania took effect 1 September 2026 per SSA POMS GN 01701.005, TN 20 (09-26). Twenty-four are in Europe, four in the Americas, three in Asia-Pacific.
• Seven EU states have none: Bulgaria, Croatia, Cyprus, Estonia, Latvia, Lithuania and Malta. The low-tax marketing and the agreement list point in opposite directions.
• The foreign earned income exclusion does not touch self-employment tax. The IRS requires excluded income to be counted in net earnings anyway, so a US freelancer in Dubai or Bangkok owes the full 15.3% with nothing to credit it against.
• At $100,000 of net earnings that is $14,130 a year. The Social Security half stops growing at about $199,783 of net earnings, which is why the effective rate falls from 14.13% to 10.30% between $150,000 and $300,000.
• The EU's telework framework agreement covers employees only. Twenty-three states have signed, Estonia from 1 February 2026, and a freelancer gets nothing from it — Article 13(2) and the 25% test still apply.

What a totalization agreement actually does

A totalization agreement does two unrelated jobs, and conflating them is the most common error in the material written about them. The first job is coverage: deciding which of two countries may collect social security contributions from you, so that only one does. The second is benefits: letting you add periods of work in both countries together to qualify for a pension you would otherwise be short of credits for. The first job is the one that affects your cash this year.

What an agreement does not do is reduce income tax. That is the work of a double tax treaty, and the two instruments are negotiated separately, cover different taxes and have different country lists. The IRS puts the coverage function plainly: these agreements exist "for the purpose of avoiding double taxation of income with respect to social security taxes", and must be considered when deciding whether someone is subject to US Social Security and Medicare tax at all.

The two lists do not overlap neatly. A country can have a tax treaty with the United States and no social security agreement, which is precisely the position that produces a surprise bill.

All 31 US totalization agreements, with effective dates

This is the SSA's own table, from section GN 01701.005 of its Program Operations Manual System, in the TN 20 revision dated September 2026. The dates are the agreements' effective dates, not signature dates.

Two notes on the table. The United Kingdom agreement came in two stages — the dual coverage and taxation provisions on 1 January 1985, the benefit provisions on 1 January 1988 — so the coverage date is the one that governs contributions. And Romania is the entry to check any secondary source against: it is two months old at the time of writing, and the pages ranking above this one were written before it took effect.

Read the list for what is absent as much as for what is there. There is no agreement with the United Arab Emirates, Thailand, Georgia, Panama, Mexico, Malaysia, Indonesia, Colombia, Paraguay, Albania, Vietnam, Türkiye, Singapore or Hong Kong — most of the jurisdictions that appear in a search for low-tax relocation. A US freelancer who moves to Dubai or Georgia is outside the network entirely.

The seven EU states with no US agreement

Twenty-four of the thirty-one agreements are European, which gives the impression that Europe is covered. It is not. Seven EU member states are missing from the SSA list, and the pattern in which ones they are is worth sitting with: they skew heavily towards the states that market themselves to mobile workers on tax grounds.

Every other EU member is on the list, including Romania since September. So a US person comparing Cyprus against Portugal is not comparing like with like: Portugal's agreement has been in force since 1 August 1989 and Cyprus has never had one. The income tax headline favours Cyprus; the social security position does not, and the social security position is the one nobody models.

It cuts both ways. A Bulgarian or Maltese freelancer who spends a few years working in the United States cannot totalize those periods towards a home pension — there is no instrument to do it with.

Why the foreign earned income exclusion does not help

Here is the trap, stated plainly. The foreign earned income exclusion is the relief most US freelancers abroad rely on, and it works — on income tax. It does nothing to self-employment tax. The IRS is explicit: net earnings from self-employment must include income excluded under the exclusion, "even if all, or a portion of, gross income was excluded because of the foreign earned income exclusion."

So the usual outcome for an American freelancing from a country with no agreement is federal income tax of zero and self-employment tax in full, with no foreign tax credit to set against it — the credit applies to income taxes, and this is not one.

The 2026 arithmetic, from the IRS's published rates — 15.3% total, being 12.4% Social Security and 2.9% Medicare, charged on 92.35% of net earnings, with the Social Security portion capped at the first $184,500:

One basis throughout: net earnings from self-employment, 2026 rates, single filer with no wages. The 0.9% Additional Medicare Tax above $200,000 is not charted — it adds $693.45 at the $300,000 row and nothing at the others.

The shape of that last column is the planning point. The Social Security portion stops growing once the base hits $184,500, which happens at roughly $199,783 of net earnings, so the effective rate is flat at 14.13% up to about $200,000 and then falls away. Below $200,000 — which is most of this site's readership — self-employment tax is close to a flat 14% levy on the whole of your profit, payable to a country you may not have set foot in all year. Half of it is deductible against income tax you may not owe.

The certificate of coverage, and who issues it

The agreement does not apply itself. The document that makes it operate is a certificate of coverage, and which agency issues it depends on which way you are facing.

If your earnings are subject only to a foreign social security system, the IRS directs you to request the certificate from the US Social Security Administration's Office of International Programs, and to attach a copy to your Form 1040 for every year you claim the exemption. The certificate, in the IRS's words, "will establish your exemption from the foreign Social Security tax." If the foreign country will not issue one, you can instead request a statement from the SSA that your income is not covered by the US system.

Coming the other way — a foreign worker claiming exemption from US Social Security and Medicare tax — the certificate is secured from the home country's agency and presented to the US employer. The IRS points to Revenue Procedures 80-56 and 84-54 and Revenue Ruling 92-9 for the mechanics.

For the self-employed, the allocation rule inside the agreements is residence. The SSA's manual describes it as coverage "only by the country in which the individual is a resident", with residence meaning the country where the person "has established the primary home", plus an exception for a transfer of five years or less, which keeps the activity under the system it moved from. That is a different test from the one your tax residency uses, and it is decided by the institutions, not by you.

Europe runs on a different machine

Inside the EU, the EEA and Switzerland, coverage is not allocated by bilateral treaty at all. It is allocated by Regulation 883/2004, which applies one country's legislation at a time and sets out which. The operative rules sit in Title II, and the distinction that trips people is employee versus self-employed.

"Substantial part" has a number attached to it. The Slovak labour ministry, applying the same regulation, puts the test as "at least 25% of the total working time and/or at least 25% of the total remuneration" in the state concerned; if a substantial part of the activity is in the state of residence, "the legislation of the Member State of residence shall apply." Below 25%, residence is not the answer and you fall through to the next limb — for a freelancer, the centre of their business interests.

Note the asymmetry in that table. The employee has four routes and a negotiated exception. The self-employed person has one.

The A1 certificate and the 24-month posting limit

The EU's equivalent of the certificate of coverage is the A1, formerly the E 101 and E 103. The EU's own Your Europe portal describes it as a "Statement of applicable legislation", useful for proving you pay contributions in another EU country either as a posted worker or while working in several countries at once. It is issued by the institution of the country where you are insured — for a posting, the sending country; for multi-state work, you start with the institution in your country of residence.

For postings there is a hard ceiling: "The maximum period allowed on the PD A1 is 24 months." Past that, you either join the host country's system or your employer asks the two institutions to agree an extension, which requires both to say yes. An A1 is not a formality to collect after the fact: on a labour inspection it proves you are not working undeclared, and it is the employer who applies for it — which is why a worker on an employed Dutch payroll has somebody doing this for them and a freelancer does not.

The telework framework agreement covers employees only

This is the finding the US-facing guides miss entirely, and the one that matters most to anyone reading this site. Since 1 July 2023 there has been a multilateral Framework Agreement on cross-border telework, built on the Article 16(1) exception, that lets a cross-border employee stay in their employer's social security system as long as telework from the state of residence is "less than 50% of the total working time". The Belgian federal social security service is the depositary and maintains the list.

Twenty-three states, with Estonia the most recent addition on 1 February 2026. The United Kingdom has indicated it will not sign.

Now the limitation. The depositary describes the agreement's scope as "a category of employed teleworkers and their employer(s)", and the application has to be made jointly — "the request is made in consent by employer and employee". A self-employed person has no employer to consent, and the agreement does not reach them. Nothing in it changes Article 13(2). A freelancer living in Spain and billing German clients is assessed on substantial part and centre of interests exactly as they were in 2022, while their employed neighbour doing the same work for the same client has a negotiated opt-out. If you are weighing a nomad permit that converts to permanent residency, this is the clause that decides whether the arrangement is administrable.

What to do if you are self-employed and moving in 2026

The order of operations is narrower than most relocation checklists suggest, and three of the five steps cost nothing.

• Check the SSA list first, before the tax tables. If your destination is not among the 31, assume 15.3% on top of whatever the local system charges, and price it. The agreement list is a harder constraint than a tax rate, because you cannot plan around its absence.
• Separate the two questions. Income tax and social security coverage are decided by different instruments with different country lists. A US LLC held by a non-resident can be transparent for income tax and irrelevant to coverage.
• Ask whoever decides, in writing. Coverage is determined by institutions — the SSA's Office of International Programs, or your EU institution of residence — and a determination beats any article.
• Expect the residence test to be its own test. The self-employment rule turns on your primary home, not your tax residency or your visa, and the two can point to different countries.
• Budget for a gap. Leaving one system before joining another is common and the interval is rarely zero. That is a cover problem rather than a contributions problem, and it is the part people discover late.

Who this is wrong for

• Employees of a single employer in a single country. Article 11(3)(a) or the local equivalent answers your question in one line, and your employer's payroll department already knows it.
• Anyone hoping an agreement cuts their income tax. It does not touch income tax. That is a treaty question and a different country list.
• US persons who read "no agreement" as "no liability". The absence of an agreement does not remove the US charge; it removes the relief. The 15.3% is the default, not the exception.
• Readers below the $400 threshold. Self-employment tax starts at $400 of net earnings for the year, so genuinely marginal side income is outside all of this.
• Anyone who needs an answer for a specific posting. Agreement texts differ country by country, and the five-year transferred-self-employment exception is not in all of them. Read the agreement for your pair, or get a determination.

Related reading

• Foreign earned income exclusion — the relief that zeroes your income tax and leaves the 15.3% standing.
• Netherlands 30% ruling — what the employed side of a European payroll looks like, and why it is a different question.
• DAFT visa Netherlands — self-employment in a country that does have a US agreement, from 1 November 1990.
• Cyprus non-dom — the low-tax EU route with no US social security agreement behind it.
• Digital nomad visas that lead to permanent residency — the permits whose clocks actually run, and the contributions question that follows them.
• SafetyWing review — what a nomad policy does and does not replace when you are between systems.

FAQ

How many totalization agreements does the US have in 2026?

Thirty-one. The Social Security Administration's own operating manual, GN 01701.005, lists 31 countries with agreements in force as of its September 2026 revision. Romania is the newest, effective 1 September 2026. Several widely cited expat-tax guides still publish 30, and at least one states that Romania is not on the list — that was true before September and is not true now.

Which EU countries have no social security agreement with the US?

Seven of the twenty-seven: Bulgaria, Croatia, Cyprus, Estonia, Latvia, Lithuania and Malta. Every other EU member state is on the SSA's list. The gap matters because several of those seven are the states most heavily marketed to remote workers on low-tax grounds, so the move that cuts your income tax can leave your social security contributions payable twice.

Does the foreign earned income exclusion reduce self-employment tax?

No. The IRS states that net earnings from self-employment must include income excluded under the foreign earned income exclusion, so the exclusion can take your US income tax to zero and leave the full 15.3% self-employment tax standing. Only a totalization agreement, through a certificate of coverage, can move that liability to another country's system.

What is the self-employment tax rate for 2026?

15.3% — 12.4% for Social Security plus 2.9% for Medicare — applied to 92.35% of net earnings from self-employment. The Social Security portion stops at the first $184,500 of combined wages and net earnings in 2026, which it reaches at about $199,783 of net earnings. Medicare has no ceiling, and an extra 0.9% applies above $200,000 for a single filer.

What is a certificate of coverage and who issues it?

It is the document that proves you are paying into one country's system so the other must leave you alone. If your earnings are subject only to a foreign system, the IRS says to request the certificate from the US Social Security Administration's Office of International Programs; a copy goes with your Form 1040 for each year you claim the exemption. Coming the other way, a worker claiming exemption from US tax secures the certificate from their home country's agency.

Does the EU telework framework agreement cover the self-employed?

No. The Belgian federal social security service, which is the agreement's depositary, describes its scope as a category of employed teleworkers and their employers, and the request has to be made jointly by employer and employee. A freelancer has neither, so the agreement does nothing for them. Self-employed people stay on the ordinary rules in Article 13(2) of Regulation 883/2004.

How long can an A1 posting last?

The PD A1 for a posted worker runs for a maximum of 24 months. After that you either move onto the host country's system or your employer asks the two countries' institutions to agree an extension, which is discretionary rather than automatic.

Is this tax or legal advice?

No. This is editorial research from primary SSA, IRS and EU sources, and Soveraine sells no tax, payroll or social security services. Coverage decisions are made by the institutions named above on a written application, and the facts of your own case decide the answer. Take advice in both countries before you move.

Sources

• SSA POMS GN 01701.005 — Status of Totalization Agreements, TN 20 (09-26) — the 31 countries and effective dates, Romania at 1 September 2026, and the UK's split 1985 coverage / 1988 benefit dates.
• SSA POMS RS 02001.271 — the self-employment rule: coverage "only by the country in which the individual is a resident", residence as where the person "has established the primary home", and the five-year transfer exception.
• IRS — Self-employment tax for businesses abroad — that net earnings include income excluded under the foreign earned income exclusion, and the certificate-of-coverage procedure.
• IRS — Self-employment tax (Social Security and Medicare taxes) — "The self-employment tax rate is 15.3%", the 12.4% and 2.9% split, the first $184,500 for 2026, and the 0.9% thresholds.
• IRS — Topic no. 554 — the 92.35% figure, the $400 threshold, and the one-half deduction.
• IRS — Totalization agreements — the purpose "avoiding double taxation of income with respect to social security taxes", and the home-country certificate route.
• Belgian FPS Social Security — Cross-border telework — the 23 signatories and dates, Article 16(1), telework "less than 50% of the total working time", the joint request, the "category of employed teleworkers" scope, and the UK's refusal.
• Your Europe — Social security forms — the A1 as a "Statement of applicable legislation", formerly E 101 and E 103.
• Your Europe — Posted workers — "The maximum period allowed on the PD A1 is 24 months", extendable only by agreement.
• Slovak Ministry of Labour — Work in two or more EU Member States — the substantial-part test at "at least 25% of the total working time and/or at least 25% of the total remuneration".
• Regulation 883/2004, Article 13 — UK government reproduction — the employed and self-employed limbs and the centre-of-interests fallback. Cited for wording; the authoritative text is the EU Official Journal version.