<s>[INST] The next text is a question of a member of the European parliament:"The E101 form, which became the A1certificate following the entry into force of Regulations (EC) No883/2004 and (EU) No987/2009, serves to reduce the incidence of certain types of fraud in relation to the posting of workers under the provisions of Directive96/71/EC. On the basis of the Court of Justice (CJEU) judgments in the Fitzwilliam and Herbosch Kiere cases (C‐202/97 and C-2/05 respectively), the certificate serves as proof that workers posted by temporary employment agencies are covered by the social security scheme of their country of origin, and the institutions and courts of EU Member States are bound to recognise it.   In the circumstances of a case which has come before the CJEU (CaseC-359/16), E101 certificates had obviously been obtained by fraud but, because the Bulgarian authorities had not ruled as to their validity, the Belgian authorities found themselves unable to proceed.   The Advocate General, in his conclusions of 9November, took the view that an E101 certificate is not binding on a court of the host Member State where that court finds that the certificate was obtained or invoked fraudulently, and he added that the opposite solution would ‘result in an unacceptable outcome’.   Does the Commission therefore intend to authorise the courts of host Member States not to accept A1certificates which they find to have been obtained fraudulently?"
Analyze carefully the text and assign it to the most relevant policy area among those listed below. Do not explain your answer and return only a number.
Policy area numbers: 1 = Macroeconomics
2 = Civil Rights, Minority Issues and Civil Liberties
3 = Health
4 = Agriculture and Fisheries
5 = Labour, employment and pensions
6 = Education
7 = Environment
8 = Energy
9 = Immigration
10 = Transportation
12 = Law and Crime
13 = Social welfare
14 = Regional and Urban issues and Planning
15 = Banking, finance and domestic commerce issues
16 = Defence
17 = Space, science, technology, and communications issues
18 = Foreign trade
19 = International affairs and foreign aid
20 = Governance and government
21 = Public Lands, Water Management and Territorial Issues
23 = Culture and media
[/INST]. Answer = [3]. </s>
The E101 form, which became the A1certificate following the entry into force of Regulations (EC) No883/2004 and (EU) No987/2009, serves to reduce the incidence of certain types of fraud in relation to the posting of workers under the provisions of Directive96/71/EC. On the basis of the Court of Justice (CJEU) judgments in the Fitzwilliam and Herbosch Kiere cases (C‐202/97 and C-2/05 respectively), the certificate serves as proof that workers posted by temporary employment agencies are covered by the social security scheme of their country of origin, and the institutions and courts of EU Member States are bound to recognise it.   In the circumstances of a case which has come before the CJEU (CaseC-359/16), E101 certificates had obviously been obtained by fraud but, because the Bulgarian authorities had not ruled as to their validity, the Belgian authorities found themselves unable to proceed.   The Advocate General, in his conclusions of 9November, took the view that an E101 certificate is not binding on a court of the host Member State where that court finds that the certificate was obtained or invoked fraudulently, and he added that the opposite solution would ‘result in an unacceptable outcome’.   Does the Commission therefore intend to authorise the courts of host Member States not to accept A1certificates which they find to have been obtained fraudulently?