Source: ISSA, Forthcoming.

Globally, European countries are party to the highest number of bilateral social security agreements, followed by the Americas, Asia-Pacific and Africa. European countries and territories are party to 530 of the 631 bilateral agreements in force worldwide (84 per cent), while Asia-Pacific countries are party to 147 or 23 per cent of the global total. The number of bilateral social security agreements worldwide has grown rapidly since the 1970s, with a stronger growth involving Asia‑Pacific countries since the 1980s (Figure 2).

Figure 2. Total number of bilateral social security agreements over time, by region of countries involved (one or both parties)

Source: ISSA, Forthcoming.
Note: As this graph displays social security agreements that are still actively implemented, many early Europe-Europe agreements are not shown because these matters are now governed by EU regulations. The earliest agreement was in 1919 between Italy and France (Butcher and Erdos. 1988).

Bilateral social security agreements in Asia-Pacific

Main contracting regions

Currently, the regional breakdown of agreements involving countries in Asia-Pacific is as follows: 76.9 per cent are with countries from Europe (113 agreements), 12.9 per cent with the Americas (19 agreements), 9.5 per cent are intraregional to Asia-Pacific (14 agreements) and 0.7 per cent with Africa (1 agreement) (Figure 3). While agreements with Europe continue to predominate, since 2000, there has been a noticeable increase in the number of intraregional agreements and agreements with countries from the Americas.

Figure 3: Number of bilateral agreements involving countries/territories in Asia-Pacific, by region of other contracting party

Source: ISSA. Forthcoming.

Sub-regional characteristics

Given its vast geographical size and population, and its cultural, linguistic and political diversity, it is interesting to look closer at subregional trends in bilateral agreements (Figure 4). Looking by ISSA subregions, most agreements involve countries from East Asia (48 per cent) and from the Pacific subregion (25 per cent), followed by South Asia, South East Asia and the Arab Countries. 
 
Figure 4. Number of bilateral agreements involving an Asia-Pacific party by ISSA subregion

Source: ISSA. Forthcoming.
Note: [1] The total number of agreements is higher than in earlier figures, because intra-regional agreements are counted for both contracting parties. [2] Countries with agreements in force are as follows by subregion: (a) East Asia: China, Japan, Korea (Republic of), Mongolia; (b) Pacific Islands: Australia, New Zealand; (c) South Asia: India, Iran (Islamic Republic of), Pakistan; (d) South East Asia: Philippines, Viet Nam, Thailand; and (e) Arab countries: Syrian Arab Republic.

As noted above, while countries from the region are involved in 147 agreements (23.3 per cent of the global total), only 13 Asia-Pacific countries have active agreements. Looking across individual countries, most agreements are concentrated among just a few countries (Figure 5). The Republic of Korea has the most agreements at 39, followed by Australia with 31, Japan with 22, India with 19 and the Philippines with 14.
 
Figure 5. Number of bilateral agreements by Asia-Pacific contracting party

Source: ISSA. Forthcoming.
Note: As some agreements involve two Asia-Pacific countries, some agreements appear twice.

Focusing on countries with 5 or more agreements, we can see distinct trends in growth over time (Figure 6). Traditionally, Australia was the country most likely to be party to bilateral agreements in the region, but in 2017, the Republic of Korea surpassed Australia, and now has the highest count overall by 2024. Overall, the chart illustrates the varying pace of engagement in international social security agreements over the observed period, with a notable increase in the number of agreements entering into force after the 2000s.

Figure 6. Total number of bilateral social security agreements over time, by contracting party

Note: This graph only includes countries with five or more agreements.
Source: ISSA, Forthcoming.

Facilitated access to benefits

One of the main functions of social security agreements is to facilitate access to benefits, either through maintenance of rights in the course of acquisition (also known as totalization) or through other means (ILO, ISSA, ITCILO, 2021). Such provisions allow for the accumulation of qualifying periods under different national social security schemes to aggregate the qualifying periods (either insurance, employment or residence), and maintain or recover rights (ILO, ISSA, ITCILO, 2021). Finally, each country provides a benefit proportionate to the length of the worker’s affiliation with their social security system, following a calculation method established in the agreement.

Globally, international social security agreements cover pensions (old age, disability, and survivors) to a much higher rate than any other branch. In bilateral agreements involving countries in the Asia-Pacific region, the share of pensions covered for totalization is consistent with agreements outside the region, standing at around 80 per cent. However, facilitation of access to other branches remains notably low, below 20 per cent for all of the other six classic branches of social security (Figure 7). That said, pensions are by far the most developed branch in the region, with provisions covering the private sector existing in 94 per cent of countries, compared with 50 to 56 per cent of countries for all other cash benefits (excluding employer-liability provisions; ISSA country profiles - Asia 2022).

Figure 7. Branches covered by bilateral agreements involving Asia-Pacific countries and excluding Asia-Pacific countries

Source: ISSA. Forthcoming.

Some social security agreements include a clause allowing for the aggregation of qualification periods from third countries, which enhances social security protection by offering additional safeguards for migrant workers' rights. Specificities vary depending on the agreement, but often these clauses allow workers who have spent time in a third country, with which both contracting parties already have an agreement, to have those periods considered in determining their eligibility for benefits. Alternatively, it might be possible to aggregate periods from third countries with which only one of the parties has an agreement (ILO, 2012).

Globally, third-country totalization clauses are included in 41 per cent of social security agreements, while in Asia-Pacific, this rate is 24 per cent, as shown in Figure 8. However, it is important to note that these rates have increased significantly in recent agreements. For agreements signed or renegotiated after 1990, the inclusion of such clauses has risen to 64 per cent  for agreements outside the Asia-Pacific region and 40 per cent  for those involving Asia‑Pacific countries. This trend indicates a growing emphasis on including third-country totalization clauses in newer agreements.

Figure 8. Percentage of agreements with a third country clause for third country totalisation (bilateral agreements involving Asia-Pacific countries).

Source: ISSA. Forthcoming.

Posted workers

Posting or detachment occurs when a company sends its employees to another country to perform temporary activities on its behalf, or when a self-employed person is temporarily active in another country, different from the one where they usually conduct their business. In these situations, social security coordination instruments often provide an exception to the usual principle that the laws of the country where the work is carried out should apply (Nickless and Siedl. 2004). Therefore, they allow workers to remain under their home country's system rather than that of the country where the work is performed, exempting them from the payment of social security contributions. The main goal is to avoid double contributions or double entitlement to benefits and reduce administrative burden for companies and insured individuals.

Clauses on the determination of applicable legislation and exemption of payment of social security contributions are the most common in social security agreements. Box 2 summarizes the key concepts concerning posted workers.

As shown in Figure 9, approximately 90 per cent of agreements worldwide include provisions on coverage for posted workers. Interestingly, it is more common for agreements in the Asia-Pacific region to exclusively cover posting compared to other regions. While only about 2 per cent of agreements outside this region cover posting only, 17 per cent of agreements involving countries in the Asia-Pacific region are exclusively dedicated to posting, without including other provisions on facilitation of access to benefits.

Figure 9. Features of social security agreements with and without Asia-Pacific countries as parties

Source: ISSA. Forthcoming. International agreements database, 2024. Geneva, International Social Security Association.

Such exceptions cannot continue indefinitely, and countries typically establish specific timeframes for these postings, often defining both an initial and a maximum posting period. As illustrated in Figure 10, agreements involving countries in the Asia-Pacific region tend to allow longer maximum exemption periods for posted employees. For instance, 82 per cent of agreements in this region have a maximum period of at least five years, compared to approximately 33 per cent in other parts of the world. Notably, Asia-Pacific is the only region to have agreements with a maximum duration of more than 96 months.

Figure 10. Maximum period of exemptions for posted employees in bilateral agreements involving or not Asia-Pacific countries (months) 

Source: ISSA, Forthcoming.

Self-employed workers may also benefit from exemptions on social security contributions under international agreements when they temporarily work in a country other than their usual place of business. However, such provisions for self-employed persons are far less common than those for employees. For instance, only 31 per cent of agreements involving Asia-Pacific countries include provisions for the self-employed, compared to 90 per cent for employees. A five-year exemption period is the most common for self-employed workers as it is for employees.

Multilateral agreements involving Asia-Pacific countries

Currently, 98 countries and territories worldwide (48 per cent) have at least one active multilateral agreement, with 18 per cent of Asia-Pacific countries participating in a multilateral agreement. There are two multilateral agreements in force in the Asia-Pacific region: (1) the Totalization Agreement between the Republic of the Marshall Islands, the Federated States of Micronesia, and the Republic of Palau on Social Security (referred to as the “Pacific Totalization Agreement”), and (2) the Unified Law of Insurance Protection Extension for the Gulf Cooperation (referred to as the “GCC Agreement”), signed by six member countries of the Cooperation Council for the Arab States of the Gulf (GCC): Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates (UAE).

The Pacific Totalization Agreement, which entered into force in July 2005, provides for equality of treatment, applicable legislation and totalization. In addition, it provides for a 3-year exemption on double payment of contributions for workers and self-employed over the age of 60.

The GCC Agreement, which came into force in January 2006, allows GCC nationals employed in any of the member states to remain covered by pension schemes as if they were working in their home country. The interesting feature of this agreement is that employers in the host GCC state are required to transfer social security contributions to the relevant social security administration in the employee's home country.

Although there are currently only two international agreements in the Asia-Pacific region, recent efforts indicate a promising trend towards greater international cooperation related to social security, particularly in Southeast Asia. Notably, the adoption of the ASEAN Declaration on Portability of Social Security Benefits for Migrant Workers in 2022, and the development of the ASEAN Regional Guidelines on Portability of Social Security Benefits for Migrant Workers in 2024.

Final remarks

With increasing labour migration, social security agreements are an essential tool for improving the portability of social rights. Box 3 summarizes the key facts and figures regarding social security agreements in Asia and the Pacific and highlights some specificities of the region. Although the number of such agreements in the Asia-Pacific region remains relatively low, as social security systems develop and economic formalization progresses, a more favourable environment is likely to foster an increase in agreements, both within the region and with other countries.

The guide Extending social protection to migrant workers, refugees and their families (ILO, ISSA, ITCILO, 2021) aims to help institutions strengthen their capacity to cover mobile workers effectively. More recently, the International Social Security Review published a special issue entitled "Leaving no one behind: Social security coverage for displaced populations and migrant workers" (International Social Security Review, 2023).

For international social security agreements to be fully effective, a key factor is the close coordination between the various administrative organizations in the signatory countries and communication between the different parties through their liaison agencies. The ISSA aims to support member institutions in their efforts to effectively manage and implement an increasing number of agreements, including through the Working Group on International Social Security Agreements Implementation and Data Exchange. The group is focused on contributing to the development of a common, standardized, technology-based solution for international data exchange that could improve the effectiveness and efficiency of the implementation of international social security agreements.

References