Exemptions from the increased salary requirements
As previously communicated, the new main rule requires employees applying for a work permit to receive a salary of at least SEK 33.390, corresponding to 90% of the median salary in Sweden. However, exemptions will apply for occupations where there is considered to be a particular need for international recruitment.
Purpose of the Exemptions
According to the Government, the exemptions are intended to ensure that sectors experiencing labour shortages or long-term recruitment challenges can continue to access international competence despite the increased salary threshold.
The exemptions aim to balance:
- Stricter labour immigration requirements
- The protection of employees against exploitation
- Sweden’s continued need for international talent within key sectors
Occupations Covered by the Exemptions
The exempted occupations have been identified by the Swedish Migration Agency together with the Swedish Public Employment Service based on labour market needs.
Examples of occupations expected to be covered include roles within:
- Healthcare and elderly care
- Education
- Technical and engineering professions
- IT and digital infrastructure
- Certain industrial and manufacturing sectors
- Other occupations experiencing long-term labour shortages
For exempted occupations, the applicable salary threshold will instead be 75% of the median salary, provided that:
- The salary and employment conditions remain in line with collective agreements or industry practice
- All other work permit requirements are fulfilled
Additional exempted groups:
Four additional categories of applicants are also exempt from the 90% salary requirement. For these groups, it will also be required that the salary corresponds to at least 75% of the median salary.
The additional exempted groups are:
- 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 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 full list of all exempted occupational groups can be found on the Migration Agency’s website.
It is important to note that it is the employer who specifies which occupation the employment concerns.
What This Means for Employers
The introduction of exemptions provides additional flexibility for employers recruiting international employees in shortage occupations. However, the rules also create a greater need for careful assessment before initiating recruitment or submitting applications.
Employers should therefore ensure that:
- The offered role is correctly classified under the applicable occupation category
- Salary levels continue to meet collective agreement standards
- Recruitment planning takes into consideration whether an exemption may apply
- Documentation supporting the position and salary assessment is properly prepared
As the practical application of the new framework develops, we expect further clarification from the Swedish Migration Agency regarding interpretation and case handling.
How K2 Can Support You
K2 can assist your organisation by:
- Assessing whether a role may qualify for exemption from the salary requirement
- Reviewing salary levels and employment terms
- Support with occupation classification assessments
- Advising on work permit strategy and application timing
- Monitoring ongoing regulatory developments and authority practice
Should you have any questions regarding the new salary requirement exemptions or wish to discuss how these changes may impact your organisation and upcoming recruitment, please do not hesitate to contact our team at immigrationsweden@k2xborder.com.
