Immigration Insights – March Edition 2024

As the vibrant hues of spring begin to unfold, we find ourselves on the cusp of a season marked by renewal and growth. It is with great excitement that we share this edition of our Immigration Insights not only to celebrate the blossoming beauty of the season but also to bring your attention to some significant changes in immigration policies here in Sweden.

The New Model From The Swedish Migration Agency

Shorter Processing Times. We have noticed a positive change in the processing times for applications. This means shorter waiting times for you as customers. We are delighted with this development and look forward to continuing to closely monitor this trend over time. However, despite this improvement, you can still expect a processing time of 30 days for your applications. We will let you know when you can expect shorter wait times.

Application Timeframes. With the implementation of the new model, you now can initiate your applications earlier than before. This means that you can start the application process well in advance, allowing ample time for processing and ensuring that you receive approval before the start date of your desired position or before your current permit expires.

This adjustment creates significant value for you as it eliminates unnecessary delays and uncertainties, giving you peace of mind and allowing for smoother transitions. By initiating your applications earlier, you can better plan and prepare for your future endeavors, whether it be a case for a new position or extending someone’s current permit.

Migration Agencies timeframes:

• New: For new applications, we can apply six (6) months due to start date of your employment.
• Extensions: Applications for extension can be applied four (4) months before the expiration date of the current permit.
• PUT (Permanent Residence Permit) and COS (Change of Status): Initiation and application can be done one (1) month before the expiration date of the current permit.

These are the current processing times from the Swedish Migration Agency.

Legislative Changes

A press conference was held to present the findings of the Swedish Government Official Report on changes to labour immigration. The task given by the government was to promote the immigration of highly skilled labourers to Sweden and at the same time make the requirements stricter for others.

The below is proposed to take effect as of June 1st, 2025.

• Raised Minimum Salary Level: The MSL should be raised to equal the median salary in Sweden (per yearly revisions by SCB). The salary level effective at the time of submission will be relevant for the application – which currently falls at 34 200 SEK per month. It is proposed to delay this requirement for extensions until June 1st, 2026. Professions deemed to be in shortage, newly graduated students, researchers, medicinal personnel working towards a Swedish license and ICT-permit holders should be exempt from the MSL requirement. For exempt categories, the salary must meet minimum levels per applicable collective bargaining agreements.
• Exclusion of specific professions: Employment in specific professions are no longer valid grounds for work permits. Which professions should be excluded will be based on yearly revisions involving the Migration Agency and other agencies. The report suggests (wild) berry pickers and care assistants.
• Promote highly skilled labourers: EU-bluecards can be granted for four years at a time (currently only two years at a time). Children born in Sweden to parent(s) who hold ICT, EU-bluecard or researcher permits should be granted residence permits without leaving Sweden. It should be possible to apply for a permit based on research or a doctorate without leaving Sweden for an applicant with a valid job seeking permit. To a greater extent, permits based assignments, secondments and/or deputations will get more specific and clear regulations.
• Comprehensive health insurance: CHI is proposed to be a requirement for all work permits valid for less than twelve months. The current four required insurances will still be needed.
• Other changes: The fine for employing someone without a valid permit (for the specific occupation) should be increased. It should become mandatory for all employers to report to the Migration Agency if a work permit holder’s employment is terminated or not assumed at all. The so called track-change (for previous asylum applicants who hold employment) should be abolished, meaning this category will no longer be able to apply for work permits without leaving Sweden.

In essence: The increased MSL is a hard blow to many business sectors in Sweden – the service and construction sector specifically. Exactly which professions will be exempt is yet unknown. Based on the current salary levels we experience, this will likely affect junior roles among white collar professionals as well. The exclusion of specific professions is a change that has been discussed for many years, therefore it came as no surprise. As for the promotions of highly skilled labourers, the proposed changes are quite exiguous. While four year long EU-bluecards would be a welcomed change, the proposed change related to new-borns is rather a fix to previous mistakes than promoting action. The “other changes” signify that work permits in general will be surrounded by tighter control. Among other things – making sure routines are in place to keep track of employee´s permit validity and expiry will be vital moving forward.

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