Starting point
A financial institution with activities in twelve countries, regulated, with documentation duties well beyond what an industrial company would recognise. Every hire, every contract change, every certificate has to be filed so that an audit can retrieve it years later. I was employed there permanently in HR operations, with a clearly operational brief: carry the daily HR work for the locations, not set HR strategy.
Daily work meant contracts in several legal systems, certificates for authorities and the regulator, enquiries from employees and managers in twelve countries, deadlines that ran differently in each of them, and a filing system that recorded every decision with a date and a responsible person. It is the kind of work nobody notices while it runs and everybody notices when it does not.
Then Covid arrived, and with it a question nobody had asked before: may employees work from abroad? From a holiday home, from family in another country, for a few weeks or a few months. The requests came daily, from every country, and each one was answered individually, usually with a cautious no or an uncertain yes. For a regulated institution that was not an option. It needed a rule.
Approach
For the daily work, the task was order. The recurring cases became checklists per case type, each with its filing duties, so that every colleague in every country takes the same steps. Not more rules, but the same ones, visible and within reach. An audit asks for the evidence, not the intention, so the evidence sat at the centre of every step.
For working from abroad, I carried the policy from first draft to rollout. First the clarification of what is legally possible at all: social security, meaning an A1 certificate (the EU form proving which country's system applies) or an exemption agreement per country; tax, with the 183-day rule and the risk of creating a permanent establishment; residence law outside the EU; data protection and access to regulated systems from outside; health and safety. For each point, the tax advisers, the legal department and compliance agreed what the institution could carry and what it could not.
The answers became a policy with a country list, a maximum number of days per year, an application route with fixed review steps and a clear boundary: what falls inside the rule is approved, what falls outside is not negotiated case by case. The works council (Betriebsrat, the elected employee body in German companies) was involved early, because rules on place of work and availability touch co-determination, and the form was built so that HR operations can check it without referring to tax or legal. Then the rollout: communication to all 4,400 employees, briefing of line managers, filing of every application under the documentation duties.
Outcome
The policy came into force for all 4,400 employees. Daily individual decisions became an application route that HR operations checks in minutes, with a country list that covers tax and social security and a boundary that everyone knows. Line managers could answer requests themselves because the rule was unambiguous. The documentation of every application stood up to audit requirements.
Daily work for twelve countries continued throughout, with the same checklists, the same filing duties and fewer queries because the steps were visible to everyone. It was operational work, not strategic leadership. But it showed that a policy for thousands of people can come out of the operational side, provided tax, legal and the works council work on the same document from the start.
What transfers to your company
- Legal boundaries first, then the ruleSocial security, tax, residence, data protection. Write the policy before the clarification and you write it twice.
- Country list and maximum days instead of case by caseA list of permitted countries and a number of days per year remove ninety percent of the requests. The rest is a no with a reason.
- The form has to be checkable without a lawyerIf HR operations has to pass every application to tax or legal, the policy is not finished.
- Document as if the audit were tomorrowA duty in regulated industries and good practice everywhere else: every application filed with date, review steps and decision.
Case study from an earlier permanent role, anonymised. No company names, only the industry and the role. More about me
Frequently asked questions
Was this a strategic role?
No. I was a permanent employee in HR operations, with an operational brief for twelve countries. The policy for working from abroad was a project that grew out of the daily work, because that is where the requests arrived.
How long did the policy take from first draft to rollout?
About five months. Most of that went into clarification with the tax advisers, the legal department, compliance and the works council. Writing the policy itself was the smallest part.
Which countries were on the list?
That stays internal. The principle transfers: EU countries with the A1 procedure first, third countries only with individual review or not at all, and a maximum duration that stays below the tax threshold. Practical experience, not legal advice.
What role did the works council play?
It was informed before the first draft and worked on the rules for place of work, availability and documentation. That made the later communication to the workforce considerably easier.
Does this transfer to a company with 200 employees?
Yes, with less effort. The review fields are the same, the country list is shorter, and the alignment runs with one tax adviser instead of three departments. The application route fits on one page.