New immigration compliance measures under review in Sweden
The Swedish Government has appointed an inquiry to examine whether the rules concerning the use of illegal labour should be strengthened and whether responsibility should extend beyond the direct employer. The investigation is particularly relevant for businesses using contractors, subcontractors or other third parties to provide labour in Sweden. The inquiry forms part of Sweden’s broader efforts to combat labour-related crime and ensure fair competition and compliance in the Swedish labour market. The investigation is expected to report its findings by 1 November 2027.
Key Areas Being Investigated
Broader Responsibility in Contracting Chains
The inquiry will examine whether responsibility for the use of illegal labour should extend to more actors within a contracting or subcontracting chain.
This could potentially increase the compliance responsibilities of companies engaging contractors or other service providers, particularly where third-country nationals are involved.
Potential Penalties for Clients and Procurers
The inquiry will assess whether clients or procurers could be subject to a penalty fee where illegal labour is identified.
This could increase the importance of due diligence when selecting and monitoring contractors and other suppliers.
Potential Business Bans
The inquiry will also consider whether business bans could be imposed in cases involving serious or repeated violations connected to the use of illegal labour.
If introduced, this could represent a significant consequence for businesses or individuals repeatedly failing to comply with applicable requirements.
What This Means for Employers
Although these measures are not currently in force, the initiative signals a continued focus on stronger enforcement and broader accountability in relation to illegal labour in Sweden.
For employers using international talent, this reinforces the importance of ensuring that immigration and employment compliance is addressed throughout the employment relationship and, where relevant, across the wider contracting chain.
Employers should consider:
- Reviewing how right-to-work checks are performed and documented
- Ensuring employees and contractors have the correct immigration status and work authorisation
- Reviewing arrangements involving contractors, subcontractors and other third parties
- Clearly defining responsibility for immigration and employment compliance within supplier agreements
- Establishing processes for identifying and addressing compliance risks at an early stage
- Maintaining appropriate documentation demonstrating that relevant checks have been carried out
Why This Matters for International Workforce Management
For organisations recruiting and relocating employees from outside the EU/EEA, immigration compliance forms part of a wider employment and labour compliance framework.
A valid residence and work permit is only one part of the overall compliance picture. Employers should also ensure that employment conditions, salary, role, workplace and contractual arrangements remain consistent with the applicable requirements.
Where third parties are involved, additional considerations may apply. Companies should therefore ensure that responsibilities for immigration compliance are clearly understood and that appropriate controls are in place.
How K2 Can Support You
K2 can support your organisation in strengthening immigration compliance and identifying potential risk areas by:
- Assessing immigration requirements when engaging international employees
- Reviewing employment conditions against applicable immigration requirements
- Supporting compliance assessments for existing foreign employees
- Conducting right-to-work checks and reviewing supporting documentation
- Advising on changes to an employee’s role, employer, salary or working arrangements
we will continue to monitor the Government's investigation and provide further updates as the work progresses and any legislative proposals become clearer.
Should you have any questions or wish to discuss how these changes may impact your organisation or upcoming cases, please do not hesitate to contact our team at immigrationsweden@k2xborder.com.
This update is for informational purposes only, proper advice should be sought on a case by case basis.
