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The government's recently presented bill contains a comprehensive reform of labor immigration with stricter basic conditions for work permits, new offences to combat exploitation and trade in work permits, higher penalties for illegal employment and improvements for highly skilled workers.
On 16 December 2025, the government published the bill “New rules for labor immigration” (Prop. 2025/26:87). This follows the government inquiry appointed in 2022 to propose legislative changes to combat abuse of the work permit system and exploitation of foreign workers. The inquiry's report was presented in February 2024 with proposals including raising the wage threshold to the Swedish median wage level and changes aimed at tightening requirements while improving conditions for highly skilled workers.
Salary requirement of 90 per cent of the median wage introduced
A wage requirement of 90 percent of the median wage is introduced instead of the current 80 percent. With the current median wage level (SEK 37,100), this means an increase from SEK 29,680 to SEK 33,390. The requirement that wages, insurance and conditions must not fall below collective bargaining agreements or industry practice remains, meaning both requirements must be met in parallel.
Exceptions to wage requirements
The government may authorize exemptions from the wage requirement for individual professions or groups where needs cannot be met. Examples include certain licensed professions, recent graduates or highly skilled workers where there is acute shortage of skills. These lists will be set out in regulations and may be adjusted over time.
Certain occupational groups may be excluded from work permits
The Government proposes authorization to issue regulations stipulating that certain occupational groups shall not be granted work permits. The background is widespread abuse and exploitation in labor-intensive, low-skilled industries, particularly in construction, cleaning, car washing, car repair shops, restaurants, beauty salons, transport, staffing, assistance, and agriculture and forestry.
As a starting point, berry picking and personal assistance should be included in the list of excluded professional groups. The measure should be used restrictively and apply to professions, not entire industries.
Requirements for comprehensive health insurance
Applicants staying for a maximum of one year must have or have applied for comprehensive health insurance valid in Sweden. The insurance must cover healthcare and repatriation. This ensures shorter stays do not burden the Swedish healthcare system.
Stricter checks on employers
Work permits may be refused if the employer or representative is reasonably suspected or convicted of relevant crimes, or has been imposed a special fee or tax penalty relating to work reporting. Employers with a history of misconduct may be denied the opportunity to employ foreign workers.
Extended permit periods for EU Blue Cards and seasonal work
EU Blue Cards can be extended to a maximum of four years instead of two years. Employment contracts shorter than four years will be granted an additional three months beyond the employment period. This makes it easier for highly skilled workers and reduces administrative burden. The limit for seasonal permits is extended to nine months per twelve-month period from six months, providing greater flexibility.
New requirements for ICT and seasonal work
For ICT permits, seasonal permits and mobility exceeding 90 days, the current maintenance requirement is replaced by a requirement that salary or remuneration must correspond to at least the minimum remuneration or salary paid for full-time work according to Swedish collective bargaining agreements or practice within the profession or industry.
More people can apply from within Sweden
Holders of residence permits to seek work after studies or research may apply for research or doctoral permits from within Sweden. This makes it easier for highly qualified individuals already in Sweden to switch to other permit types without leaving the country.
Increased penalties for illegal employment
The special fee for employers who hire illegal labor is increased to two price base amounts per foreign national, and four price base amounts for violations lasting more than three months, which also applies to clients in the contracting chain. The price base amount for 2026 is SEK 59,200, meaning fees of SEK 118,400 per foreign national and SEK 236,800 for violations lasting more than three months - double the current levels. The increase is intended to increase the deterrent effect.
Transitional rules and entry into force
The legislative amendments are proposed to enter into force on 1 June 2026. Transitional rules will apply to extensions and appeals, ensuring previous rules are applied in these cases. Extension applications registered by 1 December 2026 will be assessed according to previous requirements for "adequate means of support", and previous rules will apply to appeals against decisions made before entry into force.
What does this mean for employers?
Employers planning to hire foreign workers need to prepare for new requirements. Third-country nationals applying for work permits must be offered a salary of at least 90 percent of the Swedish median wage, and terms of employment must meet collective agreement requirements or industry practice. For stays up to one year, comprehensive health insurance covering medical care and repatriation is required. The employer's history may result in refusal - previous sanctions, criminal offences or tax penalties may lead to refusal.
What does this mean for applicants?
For foreign workers applying for work permits in Sweden, the reform means both tightening and improvements. The salary requirement of 90 percent of median salary replaces the current "good livelihood" requirement. This may mean certain low-paid jobs no longer qualify. EU Blue Cards can now be valid for up to four years, providing greater security and predictability. The possibility of switching to research or doctoral permits from within Sweden makes it easier for those already in the country.
EY's analysis
EY welcomes the possibility of exemptions from the salary requirement and that such exemptions are decided through regulations that can be adapted as needed. Although most highly skilled professions are above 90 percent of median salary, young people and recent graduates are at risk of being affected. The exemption only applies to the first application, not extensions after probationary periods.
The proposal to make rules more equivalent between EU-based permits and national permits contributes to simpler application and more predictable conditions. Extended permits for Blue Card holders benefit employers using this basis and significantly reduce administrative burden.
The proposal to expand opportunities for persons with permits to seek employment after completing university education or research is welcome, as the requirement to leave the country is not compatible with making Sweden more attractive to highly skilled workers.
It will become much more noticeable for employers who hire people without ensuring their right to work and reside in Sweden, especially as authorities' compliance checks are increasing with more workplace inspections and follow-up checks by the Migration Agency.
Employers and applicants should prepare well in advance for the new requirements and follow upcoming regulations for details on exemptions and exclusions.
EY is monitoring this and will provide updates as the process evolves. Don't hesitate to reach out if you have any questions.
Authors:
- Andreas Bråthe, Partner Global Immigration, 073-397 24 33
- Elin Harrysson, Senior Manager Global Immigration, 073-255 77 02
- Karin Falkman Lundberg, Manager Global Immigration, 072-186 11 65
- Elsa Tirén, Manager Global Immigration, 076-853 19 79