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🇸🇪Swedish Immigration10 November 2026 · 10 min read

Hiring From Outside the EU as a Swedish Agency: How to Stay Compliant (2026)

For staffing, recruitment and relocation agencies in Sweden: the fee bans, the crimes and special fee from June 2026, what the permit needs and the duties after.

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Key takeaways

  • Never take money from the worker for a job or a placement: Swedish law bans it for staffing and recruitment firms.
  • Since 1 June 2026, asking a foreign worker for a payment clearly out of proportion to the service, for a job or for help with a work permit, is a crime.
  • A staffing agency that employs the worker is the employer, and staffing must show it can pay the salary for at least three months.
  • The permit needs a salary of at least SEK 34,470 a month (from 16 June 2026), four insurances from the first day and terms on a par with collective agreements.
  • After approval: tell Skatteverket, keep a copy of the permit until 12 months after the job ends, and tell Migrationsverket if the work hasn't started within four months.
On this page · 11 sections
  1. First, which role does your agency have?
  2. Never charge the worker
  3. The crime of exploiting foreign labour
  4. What the work permit needs
  5. Migrationsverket now checks the employer
  6. After approval: the duties that don't stop
  7. What happens if it goes wrong
  8. A compliance checklist for agencies
  9. Frequently Asked Questions
  10. How Settio helps agencies stay compliant
  11. Sources

If your agency recruits people from outside the EU for Swedish employers, or employs them and leases them to client companies, and handles their paperwork, your duties depend on your role. The stakes rose on 1 June 2026: two new crimes, a special fee that doubled, and a Migration Agency (Migrationsverket) that can now refuse a work permit because of the employer's own record. This guide sets out what the law and the authorities say, role by role, with a checklist at the end.

First, which role does your agency have?

Your agencyWho is the employerWhat that means
Staffing agency (bemanningsföretag) that employs workers and leases them to client companiesYour agencyEvery employer duty is yours: the permit's conditions, the salary and insurance each month, the records and the reports. Staffing is also an industry with higher requirements (below).
Recruitment agency (private employment service, privat arbetsförmedling) that places a candidate with a client employerThe clientThe client meets the permit's conditions. You may not charge the candidate, and if you help with the permit, a payment from the worker clearly out of proportion to your service is the crime of trading in work permits.
Immigration or relocation agency that files for an employerThe clientYou act for the employer with its power of attorney, so the information you send in its name has to be right. The same rules on payments from the worker apply.

Many agencies have more than one role, for example recruiting for one client and leasing staff to another. Write down the role for each client and each case, because the duties follow it.

Never charge the worker

Three rules point the same way, and a fourth makes it a crime in the worst cases:

  • Staffing agencies: the Act on the leasing of workers (lag (2012:854) om uthyrning av arbetstagare, section 10) says a staffing agency may not demand, agree to or receive payment from a worker for placing them with a client company, or for the worker taking a job with a client they work or worked for. Section 9 adds that the agency may not stop the worker from taking that job.
  • Recruitment agencies: the Act on private employment services (lag (1993:440) om privat arbetsförmedling, section 6) says whoever runs an employment service may not demand, agree to or receive payment from job seekers for offering or referring them to work.
  • EU law: the Temporary Agency Work Directive (2008/104/EC, Article 6(3)) says temporary-work agencies shall not charge workers any fees for arranging their recruitment by a user undertaking.
  • The crime of trading in work permits (handel med arbetstillstånd, Aliens Act chapter 20, section 10 a, since 1 June 2026): anyone who employs a foreigner, or helps a foreigner apply for a work permit, and demands or receives a payment clearly out of proportion to what they give in return, can be sentenced to up to two years in prison, or six months to four years if the crime is gross. Agreeing to such a payment is covered too. A contract term on such a payment is void, and whoever received it must pay it back (section 10 b).

The laws speak of payment that is demanded, agreed to or received, so look at every cost that reaches the worker, not only an invoice. The simplest way to stay clear is to bill the client company for your work. The short answer: can an agency charge workers a fee?

The crime of exploiting foreign labour

Also since 1 June 2026, anyone who employs a foreigner, or has decisive influence over their working conditions, and exploits them in work under clearly unreasonable conditions is guilty of exploitation of foreign labour (exploatering av utländsk arbetskraft, Aliens Act chapter 20, section 10): up to two years in prison, or six months to four years if the crime is gross. A staffing agency is the employer, and a client company may have the decisive influence, so both sides of a lease should know where the work is done and under which conditions.

What the work permit needs

These are the employer's conditions on Migrationsverket's pages. When your agency is the employer, they are yours; when it isn't, they are the conditions your client has to meet before you file.

  • Advertise the job in Sweden and in the EU/EEA and Switzerland for at least ten days, usually on the Public Employment Service's Platsbanken, whose ads also appear in EURES. This applies to new recruitment.
  • Sign the employment agreement after the advertising period has ended.
  • Terms at least on a par with Swedish collective agreements or what is customary in the occupation or industry. The relevant trade union gets the chance to comment; if it doesn't, Migrationsverket decides.
  • Salary of at least 90% of the median salary: SEK 34,470 a month for applications from 16 June 2026. Some occupations and groups need 75%: SEK 28,725. Check the level on the day you apply; see the salary threshold.
  • Four insurances taken out by the day the employment begins: health, life, occupational injury and occupational pension. At an extension, the employee must have been covered for the whole time they held a permit. Since 1 June 2026, a worker staying a year or less also needs comprehensive health insurance. See the insurance proof.

Staffing is an industry with higher requirements

Migrationsverket lists staffing (industry code 782) among the industries with higher requirements, with cleaning, hotels and restaurants, construction, trade, agriculture and forestry, automotive workshops and some services. An employer in these industries must show how it can guarantee the pay and that it can pay the salary for at least three months. The documents: proof of cash or cash equivalents, the balance sheet and income statement for the previous and current years, and, if it has employed workers from outside the EU before, a tax account statement for the last three months. Migrationsverket also states that the work permit requirement applies to a person employed by a staffing agency that leases workers to a Swedish company.

Filing for an employer

The employer starts the application in Migrationsverket's e-service, and the employee then gets a link to complete their part. A representative needs the employer's power of attorney, attached to the application; the representative creates the application with their own e-ID and then handles the employer's part, including any request for more documents. See the employer e-service, step by step.

Migrationsverket now checks the employer

Since 1 June 2026, Migrationsverket may reject a work permit application because of circumstances relating to the employer. The grounds it lists:

  • certain crimes by the employer, or offences the employer is reasonably suspected of;
  • sanctions for employing people without the permits they need;
  • sanctions for shortcomings in the tax or fee information linked to work.

For a staffing agency, its own record now travels with every application it files as the employer. Check it before you sign, not when a refusal arrives.

After approval: the duties that don't stop

  • Check and keep the permit: before the job starts, check that the person has a valid residence permit or equivalent document, and keep a copy for the whole employment and 12 months after it ends.
  • Tell Skatteverket about the employment of a citizen of a country outside the EU/EEA, on form SKV 1160, one form per employee.
  • Four months: if the employee hasn't started within four months of the permit being granted, tell Migrationsverket. The permit may be revoked.
  • Worsened terms: if Migrationsverket's decision gave you a reporting obligation (it does so for employers in certain sectors), report worsened pay, insurance or other terms in writing within one month of them starting to apply. Not reporting can lead to a fine or prison.
  • Every month: pay at least what the permit states and keep the insurances. In a follow-up inspection, Migrationsverket asks for salary and insurance information, which you confirm on your word of honour.
  • New occupation or duties: the employee needs a new work permit, applied for before the current one expires. See changing jobs on a permit.

What happens if it goes wrong

WhatConsequence
Employing someone without the right to stay or the work permit they needA fine or up to two years in prison (Aliens Act chapter 20, section 5)
The special fee (särskild avgift) for the sameTwo price base amounts per person, or four if it went on for more than three months. The price base amount for 2026 is SEK 59,200.
Trading in work permits, exploiting foreign labourUp to two years in prison, six months to four years if gross
Sanctions on your recordGrounds for Migrationsverket to refuse your next applications
Terms below the permitThe employee's permit can be revoked, and the person may have to leave Sweden

More on the fee: what särskild avgift is.

A compliance checklist for agencies

  1. Write down your role for each client and case: employer, recruiter or representative.
  2. Bill the client company, never the worker, and look at every cost that reaches the worker.
  3. Before you file as the employer, check your own record on tax, fees and sanctions.
  4. As a staffing agency, keep the three-month salary proof ready: cash, the year's reports and the tax account.
  5. Check the salary against the level in force on the day you apply.
  6. Have the four insurances in place from the first day, and keep the certificates for the whole permit period.
  7. Advertise for ten days and sign the contract only after the advertising period.
  8. Get a power of attorney from every employer you file for.
  9. After the decision: form SKV 1160, a copy of the permit and the four-month rule.
  10. Every month: salary and insurance against the permit, and a report within a month if you have a reporting obligation.
  11. Collect only the personal data each step needs: GDPR asks for data that is adequate, relevant and limited to what is necessary (Article 5(1)(c)).

Frequently Asked Questions

Can a recruitment agency charge a candidate a fee in Sweden?

No. Under the Act on private employment services (section 6), whoever runs an employment service may not demand, agree to or receive payment from job seekers for offering or referring them to work. Staffing agencies have the same ban in the Act on the leasing of workers (section 10). Since 1 June 2026, a payment clearly out of proportion to the service, for a job or for help with a work permit, can also be the crime of trading in work permits.

Is a staffing agency the employer on a work permit?

Yes, when it employs the worker and leases them to a client company. Migrationsverket states that the work permit requirement applies to people employed by a staffing agency, and staffing is one of the industries that must show it can pay the salary for at least three months.

What is trading in work permits (handel med arbetstillstånd)?

A crime in the Aliens Act since 1 June 2026: employing a foreigner, or helping a foreigner apply for a work permit, and demanding or receiving a payment clearly out of proportion to the service. It carries up to two years in prison, or six months to four years if gross, and the payment must be paid back.

How much is the special fee for employers in 2026?

Two price base amounts per person employed without the right to stay or the work permit they need, or four if it went on for more than three months. The price base amount for 2026 is SEK 59,200.

Can an agency submit the work permit application for an employer?

Yes, with the employer's power of attorney attached. The representative creates the application in Migrationsverket's e-service with their own e-ID and handles the employer's part, and the employee then completes theirs.

What must an employer do after the work permit is granted?

Check the permit before the job starts and keep a copy for the whole employment and 12 months after it ends, tell Skatteverket on form SKV 1160, tell Migrationsverket if the work hasn't started within four months, and keep the salary and insurances at the permit's level every month.

How Settio helps agencies stay compliant

Settio is relocation and work permit software for relocation and immigration agencies and HR teams, made in Sweden and built for every EU country. For an agency hiring from outside the EU, it keeps the duties above in one place:

  • A plan for every case from the country's rules, with an owner and a deadline for each step, moved when the start date moves.
  • Documents checked on upload and compared with each other before you file.
  • Each month checked against the permit's terms and the minimum in force, with a follow-up task the month something falls short.
  • Quotes from your price list and invoices at every milestone, so your work is billed to the client company.
  • The worker's own page on their phone, in their language, with your agency's logo and colour.

See Settio for agencies, the short version of this guide in how an agency stays compliant, or Swedish platforms for work permits and relocation.

Sources

13 official sources

More in our guide toImmigration to SwedenSwedish immigration news

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