Swedish government proposes fewer restrictions on work permits

The proposal involves simplified application procedure for combined residence and work permits.

Swedish version here

On June 10, 2025, the government published a memorandum on proposals for the implementation of an EU directive (Directive 2024/1233) on a simplified application procedure for combined residence and work permits. The proposals include, among other things, that work permits should no longer be tied to a specific employer or profession and that the worker should be able to retain their work permit for a longer period of unemployment than before (6 months instead of 3 months). The government's proposal for legislative changes is proposed to enter into force on May 21, 2026. 

The background to the directive adopted by the European Parliament and the Council of the European Union on April 12, 2024, is the EU's goal to design a common policy for legal migration and increase the attractiveness for highly educated labor. Most of the proposals in the EU directive are already incorporated into Swedish legislation, and the memorandum then proposes that no change is needed. However, some parts involve changes that can have a significant impact on employers and workers. The most important changes are:

Work permits

• Work permits should no longer be tied to a specific employer or a specific type of work. Instead, a notification obligation should be introduced when changing employers.
• The notification obligation also means that it is the responsibility of the foreigner to notify the Swedish Migration Agency if a probationary employment does not transition into permanent employment. Previously, the Swedish Migration Agency has only granted permits in accordance with the probationary period, which has meant that an extension application often needs to be made after 6 months. With the proposal in the memorandum, the permit period will no longer be limited to the probationary period but can be granted for up to two years.
• Longer transition period during unemployment for those who have had a work permit for more than two years (it should be possible to retain the permit during unemployment for up to 6 months instead of the current rule of 90 days).

Processing time

• Decisions should be made within 90 days from the submission of a complete application.

Fees

• Employers who pay the application fee may not demand reimbursement from the third-country national.

Entry into force

• The legislative amendments are proposed to enter into force on May 21, 2026

It is also proposed that the current provision be amended so that those who have had a work permit, regardless of how long, and who apply for an extension within the validity period of the permit do not need to have a work permit until the permit issue has been decided, or if a deportation decision is issued, until the deportation decision has become final. According to current regulations, the applicant must have had a work permit for at least 6 months to have the right to work during the processing of a new application. 

EY has previously informed about proposals for new work permit rules presented in a report to the government on February 15, 2024 (New rules for labor immigration, etc.). These rules were proposed to enter into force on June 1, 2025, but as parts of the proposals (such as the abolition of track change) have already entered into force, other parts are still under investigation (such as exceptions from the requirement for minimum wage for certain shortage occupations). The proposals in the above memorandum have been sent for consultation to referral bodies, and responses should be received no later than September 30, 2025. 

EY assesses that the application process will be facilitated for employers but also impose requirements on control and assessments to ensure that workers have the right conditions to avoid the risk of a permit being deemed invalid. EY follows the development and will provide more detailed updates in the next step of the legislative process.

Authors:

• Andreas Bråthe, Partner Global Immigration, 073-397 24 33
• Elsa Tirén, Manager Global Immigration, 076-853 19 79
• Karin Falkman Lundberg, Senior Global Immigration, 072-186 11 65