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Inquiry recommends setting threshold at median salary 

The inquiry’s recommends in its conclusions that the government set the new minimum salary for a work permit at Sweden’s median salary, as reported each year by Statistics Sweden (although scroll down to read some of the inquiry’s criticisms of the median salary threshold).

The median salary for 2022 was 34,200 kronor a month and the 2023 figure is set to be released on June 18th. 

To be eligible for a work permit, jobs would have to have a salary at least equal to the median salary in place at the time of application.  

The report proposes that the new salary threshold for work permits come into force by June 1st 2025.

The regulations, it said, should apply from the time of decision, so if you apply before June 1st 2025 but your case is decided on by the Migration Agency after June 1st, the new rules will apply. 

For work permit renewals, current rules (80 percent of the median salary) will continue to apply for any applications for extensions submitted to the Migration Agency by June 1st 2026 at the latest.

A list of in-demand professions exempted from median salary threshold 

The inquiry suggests that the Swedish Public Employment Service (Arbetsförmedlingen) should draw up a list of in-demand professions or jobs which should be exempted from the threshold because they are typically paid below median wage but are in demand in Sweden.

As the jobs and skills in demand will vary between Sweden’s various regions, it recommends that there be different lists for each region in Sweden. 

The Migration Agency will then add any changes it deems necessary from the perspective of migration policy, passing the lists to the government, which will then once a year, take a regeringsbeslut, “governmental decision”, issuing that year’s regional lists of exempted professions. 

The jobs or professions exempted will have to be classified under the SSYK 2012 system of job classifications used in Sweden. 

When assessing applications for work permits, the Migration Agency will determine exemptions based on the list in place at the time of application.

This means that if the applicant’s profession or job is removed from the list while their application is being processed, they will still be eligible. 

Professions exempted from median salary requirement will have a lower salary requirement 

The inquiry recommends a lower salary requirement for work permit applicants in professions exempted from the higher salary threshold.

The main recommendation is that the salary should correspond to “the lowest monthly salary covered by a Swedish collective bargaining agreement with unions”. This would prevent labour migrants from undercutting the salaries of workers in Sweden.  

As an alternative, the inquiry suggests that the salary for those receiving work permits for exempted professions should correspond to “half the median salary for the profession exempted from the salary requirement”. 

Researchers and qualified medical professionals should be exempted 

While the inquiry generally did not specify which professions should be exempted from the higher work permit threshold, it did highlight two groups. 

These were newly graduated students and PhD students in Sweden who are switching from a student permit to a work permit and foreigners with a degree in medicine, nursing or dentistry from their home country, who are working in a lower-paid role while they learn Swedish and try to obtain their Swedish certification.

Students and PhD students are exempted because they are often offered salaries below the median wage if they are employed as post-docs at universities or move into industry, but are nonetheless the kind of highly educated workers Sweden wants to keep in the country. 

The inquiry recommends that those who have had residency for research, higher education studies, work placements connected to higher education, or residency after completed research or studies, should be excused from the median salary requirement if they then apply for a work permit.   

Foreign doctors, nurses and dentists are exempted because they need to prove they can speak and write adequate Swedish, pass exams testing their knowledge, and get practical experience in Swedish in order to convert their foreign qualifications into Swedish qualifications.

Often, they will be employed by the regional health authority or private health or dental company in another role while they do what is needed to qualify. 

The inquiry proposes that doctors nurses and dentists who have signed such an employment contract need not meet the median salary requirement.

Changed salary requirement for inter-company transfers

Currently, foreign workers posted to the Swedish arm of a multinational company from an overseas office – a so-called “inter-company transfer” – need only to be paid “enough to support themselves”.

The inquiry proposes that they should be paid a salary equivalent to “the lowest monthly salary for the role or profession which is covered by a collective bargaining agreement” with unions. 

Alternatively, it suggests that those transferred to Sweden be paid at least half the Swedish median salary. 

Employers required to notify Migration Agency of changes to job conditions 

The inquiry recommends that the government impose a “duty to report” on employers hiring foreigners with a work permit.

This would mean that if an employee living in Sweden on a work permit left their job, or if their job conditions changed, the employer would need to notify the agency immediately. 

Fine for employing foreigners without work permit should be increased

The inquiry recommends that the fine for employing foreigners without a permit should be increased from 57,300 kronor to 85,950 kronor. If the abuse has continued for more more than three months, the fine should be increased from 114,600 kronor to 171,900 kronor.

This fine should be increased annually to keep pace with inflation.

The spårbyte or ‘track change’ system to be abolished 

The inquiry recommends scrapping the “track change” system, which allows those refused asylum to instead apply for a work permit without having to leave Sweden. The system, which was brought in as part of a migration deal between the Green Party and the Moderate-led Alliance government in 2011, has been criticised as encouraging those refused asylum to try and stay in Sweden. 

This means that rejected asylum seekers who are eligible for a work permit will from June 2025 have to leave Sweden before they can submit a work permit application. 

MEASURES TO ATTRACT SKILLED WORKERS 

As well as tightening salary requirements, the inquiry was also asked to suggest regulatory changes which might help attract highly skilled workers to Sweden. It suggested the following reforms: 

EU Blue Card valid for twice as long

The EU Blue Card is far less popular in Sweden than it is in countries such as Germany, primarily because Sweden’s work permit system has until recently been relatively liberal. 

The inquiry suggested making the card more attractive by doubling the time that it is valid from two years to four years. If an employee is contracted to work in Sweden for less than four years, then the card should be valid for the length of their contract, plus three months. 

New rules for babies born to Blue Card holders, researchers and company transferees

Currently, family members of Blue Card holders, researchers and company transferees need to apply for residency in Sweden from outside the country, a rule that applies even to newborn babies. 

The inquiry suggests that newborn babies of people with such permits be allowed to apply for residency from inside Sweden to prevent their parents being forced to leave the country. 

Researchers or students able to apply for residency for further studies from inside Sweden

Today people who have residency in Sweden to look for work or start a company after finishing their studies cannot apply for further studies from within Sweden. The inquiry proposes that they should be able to do so.  

CRITICISMS OF ITS OWN PROPOSALS 

The inquiry was given a narrow remit from the government, meaning it was required both to propose a threshold close to the median salary and to give the government the final say on which professions should be exempted.

In its conclusions, it questions whether these instructions were right. 

Median salary ‘too high’ 

The inquiry warned that the median salary might be too high a threshold, as it risked exacerbating existing labour shortages, and also ignored the fact that young people and women typically earn below the median salary.  

“There are circumstances that support a lower salary requirement than the median salary,” the investigators wrote. “A large proportion of today’s labour migrants will not satisfy the demand for a salary corresponding to the median salary, and there are already labour shortages in Sweden in certain professions which risk getting worse if fewer labour migrants can come here.” 

The inquiry said it had considered recommending different salary requirements depending on gender and age. 

“The median salary is,” it argued, “lower for younger employees than for older ones and the average age of labour migrants is lower than the average age of people employed in Sweden”. Women, it said, also have a lower median wage. 

It concluded, however, that bringing in a range of different thresholds between today’s level of 80 percent of the median salary and the full median salary would be too complex. 

“There is reason to strive after having as simple and uncomplicated a system as possible, particularly as it should be possible to except certain professions from the requirement.”

Cutting government out of system would lead to ‘shorter processing times’ 

The inquiry said that the three-stage process for deciding which professions should be exempted from the threshold would be made more efficient if the final stage involving the government were removed. 

Under its proposed system, the development of the list starts with the Swedish Public Employment Service, then moves to the Migration Agency, and then to the government, which makes a decision on any changes to the list of exempted professions once a year.

This could mean a lag of up to two years between a business deciding that it needs to bring in a certain type of worker and that job being included on the list of exempted professions.

This means it could be just as slow as Sweden’s old system of labour market testing, under which unions and employers agreed a list of in-demand professions eligible for work permits.  

The inquiry made an “alternative proposal”, passing the final power to decide on the list to the Migration Agency. 

“This would mean the agency could issue regular, new updated regulations which should entail a shorter handling time than if a governmental decision needs to be taken every time the regulations are changed,” the inquiry concludes. 

Jobs exempted will have to be taken from outdated SSYK 2012 list of professions

The inquiry admits that using Sweden’s SSYK 2012 classification system to decide on the jobs to be exempted could be a problem for employers seeking to hire foreign expertise, particularly for cutting-edge technical businesses. 

“It has been brought to the notice of the inquiry that there could be some new types of profession, for example within battery manufacturing, which are not classified according to SSYK 2012,” the inquiry concedes. 

As existing work permit applications already have to use this system, it said, it felt it was also most suitable for the exemptions, adding that JobTech Development, a division of the Swedish Public Employment Service, was currently working on classifying such new professions under SSYK 2012.