Immigration updates

Immigration updates – 4th of June

Contributor(s): Daniel King
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    Denmark

    AR6 and AR7 applications updated with questions about offshore work

    The Danish Agency for International Recruitment and Integration (SIRI) has announced that, effective 3 June 2026, it is adding questions about offshore work to the AR6 and AR7 application forms.

    When companies use the applications, they will have to answer a few extra questions if the applicant is going to be working offshore

    Companies will be asked to specify the duration of the shift work, how many days a week the applicant is required to work, and how many hours a day the applicant is required to work. They will also be asked whether hourly-paid applicants receive holiday allowance.

    Finland

    Changes to acceptance of travel documents issued by Russia

    The Finnish Immigration Service has reminded travellers that, as of 1 June 2026, Finland will no longer accept non-biometric passports issued by the Russian Federation as travel documents. Non-biometric passports are passports that do not have a microchip containing biometric identifiers.

    The aim of the decision is to ensure that travel documents approved by Finland are as reliable as possible. In future, non-biometric passports issued by Russia will not be accepted for residence permit applications, with certain exceptions.

    The decision includes a transition period from 1 June to 31 December 2026. During the transition period, Finland will accept non-biometric passports that contain a valid visa issued by Finland before 1 June 2026. During the transition period, Finland will also accept non-biometric passports containing a valid visa or a residence permit issued by another EU Member State or Schengen country before 1 June 2026.

    Which travel documents are accepted for residence permit applications?

    Applicants for a residence permit must usually have a valid and authentic national travel document with which the Finnish Immigration Service can identify them. Those who have been granted an alien’s passport for the purpose of obtaining a national passport should obtain a national passport as soon as possible. Those who have received international protection or are applying for asylum are not required to have a national passport.

    Applicants can check on the website of the Ministry for Foreign Affairs (um.fi) which national travel documents Finland accepts for entering the country. The Ministry notes that, while it accepts other documents for purposes such as travelling to Finland, applicants for a residence permit must have a national travel document.

    As of 1 June 2026, a non-biometric Russian passport usually does not meet the travel document requirement for obtaining a residence permit. The change applies to applications that are already pending and to new applications submitted on or after 1 June 2026. Those whose application have not been decided before 1 June 2026, must obtain a biometric passport. After 1 June 2026, a non-biometric passport can be accepted for residence permit applications only in exceptional cases.

    Exceptions in which a non-biometric passport is accepted after 1 June 2026

    • The Finnish Immigration Service may grant those under the age of 18 a residence permit even if they have a non-biometric passport. However, they must still be under the age of 18 at the time when the application is decided. Those who turn 18 during the processing of the application for a first residence permit must obtain a biometric passport.
    • If the Finnish Immigration Service has granted a residence permit before 1 June 2026, it may grant an extended permit or a permanent residence permit even if the holder has a non-biometric passport.
    • The Finnish Immigration Service may grant a residence permit to a holder of a non-biometric passport if the Ministry has accepted the non-biometric passport for a special reason based on individual consideration.

    Ireland

    New jobs eligible for employment permits in construction, healthcare, transport, and agri-food sectors

    On 28 May 2026, the Department of Tourism, Enterprise and Employment announced a series of updates to Ireland’s employment permits system to address ongoing skills and labour shortages across key sectors.

    The measures are designed to support industries experiencing acute shortages across the EU construction sector, the healthcare sector, the transport sector, and the agri-food sectors.

    A total of 32 changes to jobs eligible for an employment permit are now confirmed, following a comprehensive review that commenced in Summer 2025:

    • 6 roles are recommended to be made eligible for Critical Skills Employment Permits (CSEPs)
    • 9 roles are recommended to be made eligible for General Employment Permits (GEPs) (without quota)
    • 2 roles are recommended to be made eligible for GEPs subject to newly established quotas
    • 15 roles are recommended to have their existing GEP quotas renewed

    The full report can be found here: Employment Permits Occupations Lists: Report of the Review 2025.

    The government has also approved a proposal to begin preparations to amend the Employment Permits Act 2024 with regard to the criteria that restricts the number of employment permits individual employers can hold (50:50 Rule). The “50:50 rule” means an employer must ensure at least 50% of its workforce are UK/EEA nationals. This is to implement findings of an internal review of the impact of this rule on the health and social care sector.

    While the majority of sectors do not report issues meeting the 50:50 rule, the issues currently faced by the health and social care sector, including continuity of patient care, is of concern. In the case of healthcare assistants in nursing homes, disability care and homecare, flexibility within the 50:50 rule is required to sustain long-term care capacity and manage Ireland’s demographic and fiscal trajectory.         


    Background

    For the purposes of the employment permits system, occupations fall into three categories:

    1. Occupations listed on the Critical Skills Occupations List are highly skilled professional roles that are in high demand and are not always available in the resident labour force. Occupations on this list are eligible for a Critical Skills Employment Permit (CSEP) and include roles such as medicine, ICT, sciences, finance, and business.
    2. Ineligible occupations are those with evidence suggesting there are sufficient Irish/EEA workers to fill such vacancies. Employment permits are not granted for these occupations.
    3. Every other job in the labour market, where an employer cannot find a worker, is eligible for an employment permit. For these occupations, the employer is required to undertake a Labour Market Needs Test and if no-one suitable applies for the job, the employer is free to apply for an employment permit. Occupations such as these may be skills of a more general nature and are eligible for a General Employment Permit (GEP).

    Netherlands

    Changes to residence permit rules take effect

    The Immigration and Naturalisation Service (IND) has confirmed that the revised version of European Directive 2011/98/EU (2024/1233) entered into force on 22 May 2026. This directive is applicable to most permits for residence and employment in the Netherlands. It covers the following purposes of residence:

    • Paid employment.
    • Work as a highly skilled migrant.
    • European Blue Card.
    • Research under Directive (EU) 2016/801.
    • Work experience.
    • Employment as non-privileged military or non-privileged civilian personnel.
    • Orientation year (seeking and engaging in (paid) employment).

    The entry into force of the revised single permit directive has resulted in the following changes:

    The IND is permitted to extend the legal decision period by 30 days

    As from 22 May 2026, the IND can extend the legal decision period by 30 days in the case of first residence applications. This applies to an initial application for the residence purposes of paid employment, employment as a highly skilled migrant, an orientation year and employment as non-privileged civilian personnel. However, the IND has to provide reasons as to why the decision period is being extended, for example because of additional research.

    The IND must assess a change of employer within 45 days

    This deadline applies to holders of residence permits for the following purposes of residence:

    • Paid employment.
    • Work as a highly skilled migrant.
    • European Blue Card. 
    • Research under Directive (EU) 2016/801.
    • Work experience.
    Change of employer within period of validity of the current residence permit

    If the holder of one of the above-listed residence permits changes employer within the period of validity of this permit, a legal decision period of 45 days will apply. The IND can extend this period by 15 days in exceptional cases. On the grounds of the EU Blue Card Directive, a statutory 30-day deadline applies when changing employers.

    Change of residence purpose

    If the holder of this residence permit changes to one of the above-listed residence purposes, a legal decision period of 45 days will again apply. The IND can extend this period by 15 days in exceptional cases. On the grounds of the EU Blue Card Directive, a statutory 30-day deadline applies if an authorised sponsor submits the application.

    Decision period expired

    If the IND fails to decide within the decision period, the applicant will be legally permitted to work for the new employer for the remainder of the period of validity of the current permit.

    Changing employer and extending

    The applicant can also directly request an extension of the period of validity of the residence permit when changing employers. Two decision periods then apply:

    • A period of 45 days will apply for the remaining period of validity of the residence permit.
    • A period of 90 days will apply if the period of validity is extended.

    Fees must be paid when extending the period of validity of the residence permit and/or changing the residence purpose. If the requirements have been met, the IND will grant the permit for the term of the employment contract with the new employer.

    6-month extension of search period in the event of unemployment

    If the holder of a residence permit covered by the Directive becomes unemployed and has held this permit for two years or more, they will be allowed to look for a new job for a maximum period of six months instead of three. The same applies if the permit holder has been the victim of labour exploitation. The period of time permitted to look for a new job will never exceed the period of validity of the residence permit.

    Sweden

    New rules for work permits in force from 1 June

    The Swedish Migration Agency has announced that previously-announced new rules for work permits came into effect in Sweden on 1 June 2026. This affects employers who want to hire people from countries outside the EU/EEA. The changes include a new salary requirement and a possibility for the Swedish Migration Agency to reject applications because of deficiencies linked to the employer.

    One of the biggest changes from 1 June 2026 is a new salary requirement for work permits. This means that the employee’s salary must amount to at least 90 per cent of the median salary in Sweden at the time of the application.

    The new salary requirement applies to people applying for a work permit for the first time who receive a decision on or after 1 June 2026. This means that the new salary requirement may also apply to people who submitted their application before 1 June 2026, if the Swedish Migration Agency makes its decision after that date.

    Employers must still offer terms of employment that are at least on par with Swedish collective agreements or what is customary within the occupation or industry.

    Transitional period for applications to extend permits

    There are transitional rules for the new salary requirement. These rules mean that people who were granted their current work permit before 1 June 2026 are not covered by the new salary requirement if they apply to extend their permit between 1 June and 1 December 2026.

    Instead, the previous maintenance requirement will apply to them. This means that the monthly salary must amount to at least 80 per cent of the median salary published by Statistics Sweden (SCB) that applied at the time of the application.

    However, if a person applies to extend their permit on or after 2 December 2026, they will need to meet the new salary requirement.

    Exemptions from new salary requirement

    Certain occupational groups are not subject to the salary requirement, effective 1 June 2026. Through amendments to the Aliens Ordinance, around twenty occupations are exempted from the salary threshold (listed here). For these occupations, the salary instead must amount to at least 75 percent of the median salary in Sweden at the time of application.

    Four additional categories of applicants are also exempt from the 90 percent requirement. For these groups as well, the salary must amount to 75 percent of the median salary:

    • former students who are allowed to apply for a work permit from within Sweden,
    • persons with foreign qualifications seeking employment in order to obtain a Swedish licence as a pharmacist, doctor, nurse or dentist,
    • persons granted residence permits with or after temporary protection under the EU’s Temporary Protection Directive, who apply for permits based on employment,
    • employees at certain tech or life science companies. The company must be in a start-up phase, less than five years old, and have fewer than one hundred employees.

    The exemption for these groups will apply from 11 June 2026.

    Deficiencies linked to the employer can lead to rejection

    Under the new rules, the Swedish Migration Agency may reject applications for work permits due to circumstances relating to the employer or the employer’s representatives. This may, for example, relate to:

    • certain crimes committed by the employer or offences for which the employer is suspected on reasonable grounds
    • sanctions imposed on the employer for employing people without the required permits
    • sanctions imposed on the employer because of deficiencies in information relating to taxes or fees linked to work.

    Notification of employment not starting

    From 1 June 2026, employers must notify the Swedish Migration Agency if an employee has not started their employment within four months of being granted a work permit. If employment does not begin within four months of a work permit being granted, the permit may be revoked.

    Minimum salary levels for seasonal work and ICT permits

    From 1 June 2026, salaries for seasonal work must correspond to at least the minimum salary for full-time work under Swedish collective agreements or established practice within the profession or industry. This also applies if the employee will be working part-time. The same applies regarding compensation for ICT permits.

    Longer permit periods for EU Blue Cards and seasonal work permits

    The permit period for EU Blue Cards is extended from two years to four years at a time. The permit period for seasonal work is extended from six to nine months during a twelve-month period.

    Occupations that can no longer qualify for work permits

    From 1 June 2026, it is no longer possible to obtain a work permit to work as a forest berry picker (subgroup 9210 in SSYK 2012). However, people who are going to work as berry pickers for an employer established in Sweden may apply for a seasonal work permit.

    It is also no longer possible to obtain a work permit as a personal assistant (subgroup 5343 in SSYK 2012).

    This is because these types of work permits are included in the list of occupations that are not eligible for work permits.

    Employees must have comprehensive health insurance

    From 1 June 2026, employees who are to stay in Sweden for a maximum of one year must also have, or have applied for, comprehensive health insurance that is valid during the period of employment.

    Employers are advised to:

    • Find out which rules apply to the type of work permit that the application concerns;
    • Check that the salary you have offered meets the new salary requirement;
    • Ensure that the terms of employment otherwise meet the requirements according to collective agreements or what is customary within the industry;
    • If the employment is for a maximum of one year, check that the person has or has applied for a comprehensive health insurance policy;
    • If applying for an extension for an employee, check if the application is covered by the transitional rules.
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