Germany–U.S. · Social Security
Certificate of Coverage Germany–U.S.
How do you prove that only one social-security system continues to apply when work is performed across Germany and the United States? The key documents are the German D/USA 101 certificate and the U.S. Certificate of Coverage.
Proof of Applicable Legislation
The Certificate of Coverage Prevents Practical Double Contributions
The Germany–U.S. Social Security Agreement determines which social-security system applies to a cross-border worker. In practice, however, the legal allocation alone is not enough: employers, social-security institutions and authorities generally need documentary proof that one country's legislation applies and that parallel contributions in the other country are not due.
If a person works in the United States while German legislation continues to apply, this status is documented with D/USA 101. If the U.S. system continues to apply, the Social Security Administration issues a U.S. Certificate of Coverage.
Overview
Three Common Certificates
D/USA 101
Proof that German social-security legislation continues to apply while the individual works in the United States.
U.S. Certificate of Coverage
Proof issued by the Social Security Administration that the U.S. system continues to apply while the individual works in Germany.
D/USA 101 A
A special German certificate for U.S. citizens working in Germany who need to document the application of German social-security law to U.S. authorities.
D/USA 101
German Coverage Despite Work in the United States
D/USA 101 is issued for individuals who work in the United States but remain subject to German social-security legislation under the agreement. The certificate serves as evidence to U.S. and German authorities that German law applies exclusively for the branches covered by the agreement.
A typical case is a temporary assignment from Germany to the United States for no more than five years. Other agreement cases or an approved exception agreement may also result in issuance of D/USA 101.
- documents continued application of German social-security law
- prevents parallel U.S. contributions for covered branches
- commonly used for assignments Germany → U.S.
- also relevant in certain self-employment cases
- can also follow an approved exception agreement
- retain the certificate for payroll and audits
Effect
The Certificate Applies to the Facts It Certifies
Evidence for U.S. Authorities
D/USA 101 confirms that German law applies under the agreement and that parallel coverage under the U.S. Social Security system should not apply for the covered branches.
Evidence for German Authorities
The certificate also documents the German coverage determination for German social-security institutions and employers.
Review Is Possible
If there are doubts about the facts on which the certificate was issued, the issuing authority may review it and, where appropriate, correct it retroactively or declare it invalid.
Changes in Facts
If the planned duration, employer or nature of the activity changes, it should be reviewed whether the certificate still reflects the actual circumstances.
Application From 2026
D/USA 101 for Employees Is Generally Requested Electronically
Statutory Health-Insurance Fund
If German pension-insurance contributions are paid to a statutory health-insurance fund acting as the collection agency, that fund is generally responsible for issuing the certificate.
DVKA
If no German pension-insurance contributions are paid to a statutory health-insurance fund, the GKV-Spitzenverband, DVKA is responsible in the relevant cases.
Electronic Submission
Applications for employed individuals are generally submitted electronically to the competent health-insurance fund or the DVKA.
SVLFG Special Case
A separate application procedure applies to individuals whose pension-insurance contributions are paid to the Social Insurance for Agriculture, Forestry and Horticulture.
Timing
Request the Certificate Before the Foreign Work Begins Whenever Possible
In practice, the coverage determination should be clarified before the assignment or foreign work starts and the certificate should be requested in good time. This allows payroll to apply the correct social-security system from the beginning.
Late applications may still be possible in certain cases. For retroactive exception-agreement requests, the DVKA may require an explanation and information on whether contributions continued to be paid exclusively in Germany.
- determine the assignment start date and expected duration before applying
- review the assignment requirements in advance
- provide the certificate to payroll
- retain it for U.S. audits and tax records
- report or reassess material changes during the assignment
United States → Germany
U.S. Certificate of Coverage Issued by the Social Security Administration
If a person remains subject to the U.S. system while working in Germany under the Social Security Agreement, the Social Security Administration issues the U.S. Certificate of Coverage.
The certificate serves as evidence to German authorities that the person remains covered under the U.S. Social Security system and is exempt from parallel German contributions for the branches covered by the agreement.
The classic case is a temporary assignment of an employee from the United States to Germany for no more than five years.
D/USA 101 A
Special Certificate for U.S. Citizens Covered by the German System
D/USA 101 A can be relevant for U.S. citizens who work in Germany and are subject to German social-security legislation under the agreement. The certificate may be used with U.S. tax authorities to document the application of German social-security law and the corresponding exemption from U.S. social-security contributions.
D/USA 101 A should therefore be distinguished from the standard D/USA 101: D/USA 101 generally applies to individuals working in the United States who remain subject to German law, while D/USA 101 A addresses the special proof required for U.S. citizens working in Germany.
Self-Employed Individuals
D/USA 101 May Also Be Required for Self-Employment
A person who normally carries out self-employment in Germany and temporarily transfers the activity to the United States may continue to be subject to German legislation if the agreement requirements are met.
Since 2026, applications for D/USA 101 for self-employed individuals are submitted electronically to the GKV-Spitzenverband, DVKA.
- review whether the self-employment activity is only temporarily transferred
- observe the agreement's five-year limit
- applications since 2026 are submitted electronically to the DVKA
- retain the certificate for the IRS, SSA and other U.S. authorities
- exclude U.S. Self-Employment Tax only after the coverage determination is correct
Exception Agreement
A Certificate Can Also Result Outside the Normal Assignment Rule
Alternative Coverage Determination
The competent authorities of both countries can agree in certain cases that the existing social-security system continues to apply despite the normal allocation rules.
Germany and the U.S. Must Agree
On the German side, the DVKA is involved; on the U.S. side, the Social Security Administration is involved. The DVKA coordinates communication with the U.S. authority.
Electronic Application
Where continued German coverage is requested, applications for employees are submitted electronically by the employer and applications for self-employed individuals are submitted electronically to the DVKA.
D/USA 101 After Approval
If both authorities approve the exception agreement, the DVKA issues D/USA 101 as evidence that German legislation continues to apply.
Typical Situations
Certificates of Coverage in Practice
Three-Year Assignment Germany → U.S.
If the requirements are met, German law continues to apply. D/USA 101 serves as evidence to U.S. authorities.
U.S. Employee in Germany for Two Years
If the U.S. system continues to apply under the agreement, the SSA Certificate of Coverage documents continued U.S. coverage.
Self-Employed Individual Temporarily Working in the U.S.
If German law continues to apply, D/USA 101 is required; since 2026, the application is submitted electronically to the DVKA.
Assignment Extended Beyond Five Years
The normal assignment rule may no longer be sufficient. An exception agreement should be reviewed before the five-year period expires.
U.S. Citizen Working Permanently in Germany
If German social-security legislation applies, D/USA 101 A may be relevant as evidence for U.S. tax authorities.
The Certified Facts Change
A change of employer, activity or assignment duration can require a new analysis and potentially an amendment to the certificate.
Related Guidance
Related Topics
Frequently Asked Questions
Certificate of Coverage Germany–U.S.
What is D/USA 101?
Where does an employer apply for D/USA 101?
Is D/USA 101 still requested on paper?
What is the difference between D/USA 101 and a U.S. Certificate of Coverage?
What is D/USA 101 A?
Can an issued certificate later be changed?
Germany–U.S. Tax & Social Security Advice
Do You Need D/USA 101 or a Certificate of Coverage?
We first determine which social-security system actually applies under the Germany–U.S. agreement and then coordinate assignments, self-employment, exception agreements, Certificates of Coverage, payroll and the related tax treatment.
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