Immigration updates – 22nd of May

Denmark

New online application forms for applicants for EU residence

On 15 May 2025, the Danish Agency for International Recruitment and Integration (SIRI) published four new online application forms for applicants for European Union residence in Denmark.

Applicants will experience several upgrades. Among other things, it will be much easier to apply using a mobile phone or tablet and digital applications may be processed faster. Applicants continue to be able to submit physical applications.

SIRI has moved the online form OD1 to a new IT system. At the same time the form has been divided into four new separate forms:

• OD1A – Application for EU residence, for a citizen of EU/EEA/Switzerland or a posted service provider;
• OD1B – Application for EU residence as a family member to an EU/EEA/Swiss citizen;
• OD1C – Application for permanent EU residence;
• OD1D – Application to change the grounds for EU residence

The four new forms contain a number of changes making it easier to use the forms:

• The forms in the new IT system have been optimized for mobile phones and tablets;
• The signed sworn declaration has been removed, making it possible to sign the application either when appearing at SIRI (OD1A and OD1B) or using MitID (OD1C and OD1D);
• The division into four separate forms makes each form simpler and faster to complete;
• After submission applicants can log on to their user profile in the new system and see the completed and submitted online application.

Those who have already begun to complete an application in the old system can continue to complete and submit their application in the old system for a limited period of time.

Applicants using the new system can log in and view their online application for up to 30 days after it has been submitted.

European Union

Agreement on a progressive start of the Entry/Exit system

On 19 May 2025, the European Parliament and the European Council reached political agreement on the European Commission’s proposal for a progressive start of operations of the Entry/Exit System (EES).

The agreement will allow member states to gradually benefit from the many advantages and capabilities of the system, while giving border authorities, the transport industry and travellers more time to adjust to the new procedures. 

The EES is a state-of-the-art IT system that will digitally record the person’s name, type of the travel document, biometric data (fingerprints and captured facial images) and the date and place of entry and exit. 

The EES will modernise the management of the external borders, facilitate travel, reduce identity fraud, while strengthening the security of the Schengen area. It will also simplify border procedures and improve travellers’ experience. Upon the completion of the progressive period, the EES will also automatically identify overstayers across all countries using the system. It will allow member states’ authorities to know who enters and exits the Schengen area and access essential information when needed.  

Next Steps

The Regulation must now be formally adopted by the European Parliament and the Council.  It will enter into force three days after publication in the Official Journal of the EU.

Finland

Amendments to family reunification provisions forthcoming

The Finnish parliament has approved a set of amendments to the Aliens Act that will enter into force on 16 June 2025. The amendments tighten the requirements that must be met in family reunification cases.

The changes are as follows:

New age requirement for spouses and partners

• When the spouse of a sponsor applies for a residence permit, both the spouse and the sponsor must be at least 21 years of age when the residence permit becomes valid. The spouse may be a wife or husband, a cohabiting partner or a partner in a same-sex registered partnership.
  • The new age requirement does not apply to sponsors who are Finnish citizens.
• The residence permit application may be submitted a maximum of nine months before turning 21.
  • For an established family member (an ‘old’ family member), there is an exception to this rule. In such cases, the residence permit application may be submitted within three months of the sponsor being served with a decision on his or her refugee status if:
    • the family was formed before the sponsor’s arrival in Finland, or
    • the family was formed before the sponsor was admitted into Finland’s refugee quota, or  
    • the family was formed before the sponsor was granted refugee status on the basis family ties.
• If the spouses have children in their joint custody, a residence permit application as the child’s parent or guardian can be submitted even though the parent is under 21 years of age.

New period of residence requirement

• A sponsor who has been granted international protection must live in Finland with a residence permit for at least two years before his or her family member or other relative can apply for a residence permit on the basis of the family relationship.
  • This requirement applies to all family members of a person who has been granted subsidiary protection, the new family members of refugees, and the other relatives of a person who has been granted international protection.
  • The new requirement does not apply to established family members of refugees or the family members or other relatives of beneficiaries of temporary protection..
• An exemption from the period of residence requirement is possible if there are exceptionally serious grounds for such an exemption or if it is in the best interest of the child.

Changes to the definition of when a sponsor who has been granted international protection is considered a minor

• Granting a residence permit to a family member of an unaccompanied minor sponsor who has been granted asylum requires:
  • that the sponsor was under 18 years of age on the day when he or she submitted the application for international protection, and
  • that the sponsor was granted asylum on the basis of that application, and
  • that the residence permit application on the basis of family ties is submitted within three months of the day when the sponsor was served with the decision that he or she has been granted asylum. 
• A sponsor who has been granted subsidiary protection or temporary protection or who has arrived in Finland as a quota refugee must be under 18 years of age when his or her family member applies for a residence permit.
• A parent or guardian who has custody of a child and has been granted asylum can apply for a residence permit for the child on the basis of family ties if:
  • the child was under 18 years of age on the day when the sponsor, who has been granted asylum, submitted the application for international protection in Finland, and
  • the sponsor was granted asylum on the basis of that application, and
  • the residence permit application on the basis of family ties is submitted within three months of the day when the sponsor was served with the decision that he or she has been granted asylum. 

Changes to the income requirement

• The family members of a minor sponsor who has been granted subsidiary protection or temporary protection must meet the income requirement. They must have sufficient financial resources.
• The income requirement does not need to be met if the sponsor is an unaccompanied minor and has been granted refugee status in Finland. The sponsor’s refugee status may have been granted in the form of asylum or as a quota refugee. 
• Other relatives of a minor sponsor who has been granted international or temporary protection must meet the income requirement. They must have sufficient financial resources.
• In individual cases, a derogation may be made from the income requirement if there are exceptionally serious grounds or if the derogation is in the best interest of the child.

Applications submitted before 16 June 2025 will be decided in accordance with the old version of the Aliens Act

Applications for a first or an extended permit on the basis of family ties submitted before 16 June 2025 are not affected by these changes.

Applications for a first residence permit on the basis of family ties submitted on or after 16 June 2025 will be decided in accordance with the new Act. 

Applications for an extended permit on the basis of family ties submitted on or after 16 June 2025 will be decided in accordance with the new Act in the following cases:

• the previous permit was issued on grounds other than family ties;
• the application is on the basis of a different family relationship than the previous family permit.

The Finnish Immigration Service is currently updating the application forms of family-based permits in the online service Enter Finland. Draft applications which have not been finished and submitted will not automatically be updated to the new application form. These applicants are advised to finish their draft application and submit the application before 16 June 2025.

Poland

New immigration laws take effect 1 June 2025

New laws introducing a range of significant changes to the immigration regulations have now been published in the official journal and will enter into force on 1 June 2025.

Among the principal changes are the following:

• The labour market test is no longer required. Henceforth, the district authorities will establish lists of protected professions which are closed to foreign nationals.
• All application procedures will be digitized.
• Employers must upload a copy of the signed employment contract before the job starts.
• Foreign nationals cannot work less than 25 percent of a full-time job. For jobs of less than 20 hours per week, the work permit will be issued for up to one year.
• Work permits will be issued for up to on year only for companies which have been operating for less than one year.
• Employers have new deadlines for submitting online notifications for, e.g., the date a foreign national starts or terminates employment.
• Fines for illegal employment will increase.

Further details of the implementation of the new rules are expected.

Spain

New immigration regulations take effect 20 May 2025

Royal Decree 1155/2024, published in the Official State Gazette (BOE) on 20 November 2024, came into force on 20 May 2025, introducing significant changes to Spain’s immigration and residence rules. Applications submitted before this date should be processed under the previous rules.

The key changes are as follows:

• Work permits will initially be issued for a duration of one year (previously this varied from six to 12 months. Renewals will be valid for four years (previously two years). Long-term residence cards for foreign nationals aged at least 30 years will be issued for 10 years (previously five years).
• Work permit holders will be permitted to engage in self-employment without first requesting permission.
• A new five-year family reunification permit for non-EU national relatives of Spanish nationals is introduced, with immediate work rights. This permit us eligible spouses and registered partners, unregistered partners, dependent children and dependent parents and grandparents.
• For family reunification, the age limit for dependent children has been raised from 21 to 26 years. Unmarried partners now qualify with proof of a stable relationship (usually 12 months of cohabitation or children in common).
• Students are now permitted to work up to 30 hours per week while studying.
• The regularization (“arraigo”) procedures for undocumented migrants has been expanded to more groups of people, including those with two years (previously three years) of prior residence in Spain with social, familial, work, training and other ties to Spain. The right to work immediately is generally now included in these permits.
• The validity of the job seeker visa for descendants of Spanish nationals and those seeking work in certain approved sectors has been extended from three to twelve months.

It may take some months for all of these changes to be implemented.