Immigration updates

Immigration updates – 4th of December

Contributor(s): Daniel King
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    Bulgaria

    Minimum wage increase confirmed

    The Bulgarian government has decided that, effective 1 January 2026, the minimum monthly wage will increase by 12.6% to EUR 620.20 (BGN 1213). The minimum hourly wage is set at EUR 3.74 (BGN 7.31).

    The increase will affect the qualifying salary thresholds for the single permit for residence and work and the intra-corporate transferee card.

    Bulgaria is adopting the euro currency from 1 January 2026.

    Denmark

    Clarification of rules for accompanying family members of third-country students in non-state-approved higher educational programmes

    On 30 April 2025, the Ministry of Immigration and Integration published an amendment to the ‘Executive Order on the Granting of Residence and Work Permits to Students’ (the Executive Order on study programmes). On 1 December 2025, The Danish Agency for International Recruitment and Integration (SIRI) clarified how the amendment means that accompanying family of third-country students in non-state-approved higher educational programmes are no longer eligible for residence permits. 

    The changes came into effect on 2 May 2025 and only apply to those who applied for a residence permit on or after that date. 

    Students in non-state-approved higher educational programmes who applied for a residence permit before 2 May 2025 are not covered by the new rules and will therefore be entitled to work and to a jobseeking permit. These students can get a residence permit in Denmark for their minor children, even if the children have applied on or after 2 May 2025.

    Spouses, cohabiting partners and registered partners who have applied for a residence permit as accompanying family members of a student in a non-state-approved higher educational programme before 2 May 2025 are also not covered by the new rules and will therefore also be able to get a residence permit as accompanying family members of the student.

    Spouses, cohabiting partners and registered partners who apply for a residence permit as accompanying family members of a student in a non-state-approved higher educational programme on or after 2 May 2025 are covered by the new rules and will therefore not be able to get a residence permit as accompanying family members of the student.

    This means:

    • The spouse, cohabiting partner or registered partner of a student in a non-state-approved higher educational programme in Denmark who applied for a residence permit before 2 May 2025 will still be able to get a residence permit as an accompanying family member of the student.
    • The spouse, cohabiting partner or registered partner of a student in a non-state-approved higher educational programme in Denmark who applies for a residence permit on or after 2 May 2025 will not be able to get a residence permit as an accompanying family member of the student.
    • A minor child of a student in a non-state-approved higher educational programme in Denmark who applied for a residence permit before 2 May 2025 will still be able to get a residence permit as an accompanying family member of the student.
    • A child of a student in a non-state-approved higher educational programme in Denmark who applied for a residence permit on or after 2 May 2025 will not be able to get aresidence permit as an accompanying family member of the student.

    Ireland

    Government publishes roadmap for gradual increase in employment permit salary thresholds

    The Department of Enterprise, Tourism and Employment has announced the publication of a new roadmap for Minimum Annual Remuneration (MAR) Salary Thresholds. The first increase will take effect 1 March 2026, with further adjustments phased in through 2030.

    The Roadmap outlines a gradual approach to increasing salary thresholds across all employment permit types, while removing very low thresholds on a phased basis for certain roles in the agri-food and healthcare sectors.

    Key changes

    • From 1 March 2026:
      • The minimum salary for the General Employment Permit (GEP) will rise by 7.66% from EUR 34,000 to EUR 36,605, instead of the previously planned 14.7%;
      • The minimum salary for the Critical Skills Employment Permit (CSEP) will increase by 7.66% from EUR 38,000 to EUR 40,904, instead of 15.8%;
      • The minimum salary for meat processors, horticultural workers, healthcare assistants, and home carers will increase by 9% from EUR 30,000 to EUR32,691 and will be phased out by 2030 rather than by 2026.
    • Lower starting thresholds will apply for recent graduates, reflecting their early career stage.

    Background

    Minimum Annual Remuneration (MAR) is the lowest annual salary that must be paid to a non-EEA worker for an employment permit to be issued or renewed. There is also an associated hourly rate for each MAR that must also be satisfied

    In 2023, alongside a review of the occupations lists, the Department of Enterprise, Trade and Employment (DETE) reviewed Minimum Annual Remuneration (MAR) thresholds. It found that thresholds had stagnated since 2014 and had not kept pace with inflation and economic changes.

    The original roadmap announced increases from January 2024, but following consultation with the healthcare sector, increases for health care assistants, home carers, and care workers were deferred to January 2025.

    In response to concerns about rising business costs—including statutory sick leave and pension auto-enrolment—a further review commenced in Summer 2024. Submissions from sectors and CSO data informed this process.

    ISD announces initiative to facilitate customers travelling at Christmas

    Immigration Service Delivery (ISD) has announced that it is currently experiencing a backlog in processing registrations. Following the completion of a registration, it may take a further two weeks to receive an Irish Residence Permit (IRP) card via post.

    To facilitate Non-EEA Nationals legally resident in Ireland who are required to renew their current permission and who wish to travel internationally during the Christmas period, the Minister is issuing a Travel Confirmation Notice requesting carriers to allow individuals to travel on their recently expired IRP card where an application to renew their permission was submitted in advance of the expiry date of their IRP card.

    Non-EEA Nationals in Ireland who are required to apply for a renewal of their IRP card may use their current, recently-expired IRP card to enable them to travel from 8 December 2025 to 31 January 2026, provided an application to renew their registration permission was submitted in advance of the expiry date of their IRP Card.

    ISD notes that:

    • Customers should download and print the Travel Confirmation Notice and present it, along with their expired IRP card, and proof of renewal application (email confirmation which details the date of application) to immigration authorities and airlines if requested to do so;
    • The Department will continue to process applications for renewals;
    • The Department will advise all airlines and foreign missions of the initiatives in place;
    • Those who have to travel through a third country to return to Ireland must meet the immigration requirements of that country;
    • Further details on these arrangements can be found in the FAQs for Website Travel Confirmation Notice 2025.

    Malta

    Mandatory Pre-Departure course and examination for non-EU workers

    On 27 November 2025, the government announced the latest phase of implementation of the Malta Labour Migration Policy – namely, a new requirement to complete a pre-departure course and examination for all third-country nationals seeking to work in Malta.

    All applicants will undergo a Suitability Check conducted by Jobsplus. Applicants must provide documentation in the following four categories:

    1. Certificate of the Pre-Departure Course or the Skills Pass;
    2. Approval from the relevant regulatory body for regulated professions, where required;
    3. Recognition of qualifications from the Malta Qualifications Recognition and Information Centre (MQRIC), where applicable;
    4. A declaration from the employer confirming the applicant’s suitability for the specific role.

    The Pre-Departure Course will cover essential elements including basic English language skills, cultural awareness, hygiene and basic conduct, rights and obligations in the workplace, respect for civil rights, among others.

    Applicants will be required to sit for an assessment, and only those who pass may proceed to apply for work in Malta. Passing the test is the first step in the application process. The test, which will cost EUR 250, will be mandatory for all workers.

    In sectors where the Skills Pass already applies, such as tourism, applicants must complete the second part of the Skills Pass linked to that sector. As the Skills Pass is expanded to additional sectors, the second-stage requirement will follow accordingly, with further details provided by the relevant authorities.

    The Pre-Departure Course will commence on 5 January 2026 and, from 1 March 2026, the immigration authority (Identità) will only consider applications from individuals who have successfully completed the course and assessment.

    Moreover, workers who have been in Malta for at least one year may have their permit renewed for more than one year, subject to conditions. Low-skilled workers will be required to undertake a training programme, while a two-year extension will be granted automatically for higher-skilled roles, provided the worker has a valid employment contract.

    The training programme will be delivered by licensed Maltese institutions and will cover areas including Maltese culture and traditions, civic participation, legal and safety awareness, personal and professional development, and English and Maltese language learning.

    Background

    On 8 January 2025, the Maltese Government launched a new Labour Migration Policy for public consultation, which closed on 9 February 2025.

    During 2025, 15 measures have been implemented, with an additional five being rolled out on an ongoing basis.

    Among the measures implemented in recent months are the following:

    • Minimum termination rates before new applications;
    • Strengthened obligation to publicly advertise job vacancies;
    • Restrictions preventing employers who dismissed workers unjustifiably in the previous 12 months from applying for new workers;
    • Emphasis on timely submission of employment and termination forms;
    • Doubling of fees for new worker applications (with exceptions in health, elderly care and disability services);
    • Restrictions for employers who fail to comply with disability employment quota obligations;
    • New rules for applicants who do not enter Malta with a valid work visa;
    • Mandatory payment of salaries through bank deposits or electronic means.

    Poland

    New application form for a temporary residence permit

    Effective 1 December 2025, a new application form for a temporary residence permit has been implemented. The annexes attached to the application form have also been updated.

    The new form template was introduced by the Regulation of the Minister of Internal Affairs and Administration of 25 November 2025. For manually submitted applications., the case status can be checked here.

    The update was made necessary by the amendments introduced by the Act of 24 April 2025 amending the Act on Foreigners and certain other acts and the Act of 20 March 2025 on the conditions for the admissibility of entrusting work to foreigners on the territory of the Republic of Poland.

    The government is planning to require residence permit applications to be submitted electronically from sometime in 2026.

    Meanwhile, the online temporary residence permit application module, on the Moduł Obsługi Spraw (MOS) portal, was also upgraded on 1 December 2025. It now consists of an interactive PDF form with drop-down menus, multilingual help and in-built validation. Currently, applications completed online still need to be printed and physically signed. The implementation of electronic signatures, and the requirement to submit applications online, are planned for 2026.

    New regulations on the employment of foreign nationals

    On 1 December 2025, new regulations came into effect which, among other changes, removed Georgia from the list of countries whose citizens are eligible for a simplified work authorisation process known as the “declaration on entrusting work to foreign nationals”.

    Declarations on entrusting work to foreign nationals

    A declaration on entrusting work to a foreigner is a simplified procedure, compared to a work permit, for legalizing work in Poland. It is issued by the employer’s local county labour office (not by the voivodeship office as in the case of a work permit).

    However, the declaration procedure applies only to citizens of a few countries indicated in an interministerial regulation. Under the new regulation, declarations only apply to citizens of Armenia, Belarus, Moldova and Ukraine. Effective 1 December 2025, Georgia has been removed from the list.

    Citizens of Georgia who have been entrusted with work based on a declaration registered before the amended regulation entered into force may continue working under that declaration until the expiry date of the declaration.

    Higher fees for declarations and work permits

    Another regulation entering into force on 1 December 2025 is the regulation on the amount of fees for work permit applications and declarations on entrusting work to a foreigner.

    From 1 December 2025, the fee submitted with a declaration will be 400 PLN (previously 100 PLN). Cases already initiated before the effective date will follow the previous rules.

    Work permit application fees will also change on 1 December 2025:

    • 200 PLN – for work permits up to 3 months
    • 400 PLN – for work permits longer than 3 months
    • 800 PLN – for delegations of foreign workers to Poland
    • 100 PLN – for seasonal work permits.

    Precise specification of cases exempt from work permits

    The new regulation (issued under Article 3(7) of the Act of 20 March 2025) clarifies the special cases where foreigners can work without a work permit, complementing the statutory provisions introduced on 1 June 2025. These include:

    • Participation in EU and international assistance programmes (programme development/supervision or training)
    • Teachers conducting instruction in foreign languages – clarified with reference to the Education Law and specific types of institutions
    • Delegation connected with defence programmes under agreements involving Poland
    • Journalists – foreign correspondents accredited by the Ministry of Foreign Affairs
    • Artistic and audiovisual work – with explicit limits (up to 30 days per calendar year)
    • Occasional lectures/speeches/presentations – also with a 30-day limit
    • Athletes and sports-related staff – clarified rules for persons delegated by international sports organisations; 30-day limit for athletes employed by Polish clubs
    • Pupils and youth workers in vocational training or internships
    • Participants in government business internship programmes for Polish diaspora communities
    • Researchers and scientific staff – a catalogue of technical and research-related activities
    • Medical professions and other regulated professions (including physiotherapists and pharmacists), requiring valid professional licenses.

    New time limits and more detailed conditions

    In 2025, explicit 30-day annual limits were introduced for several categories (artistic performances, occasional lectures, athletes hired by Polish clubs), which is a significant clarification compared to the 2015 regulation.

    Delegation of foreign employers (short delegations)

    The new regulation also clarifies cases of delegating a person living abroad by a foreign employer for no more than 3 months per year, listing specific types of work (assembly, equipment acceptance, training, installation/dismantling of trade fair stands). These provisions formalize earlier practices.

    Transitional rules – shortened adjustment period

    According to §2 of the new regulation, foreigners working under the 2015 regulation whose situations are not covered by the new regulation may continue working without a permit, but not longer than 6 months from the effective date of the new regulation.

    New requirements in the work permit procedure – unified and updated document lists

    The regulation of 20 November 2025 specifies the exact list of documents that must be attached to a work permit application or a declaration.

    Note that, since 1 June 2025, work permit applications and attachments must be submitted exclusively electronically.

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