Swedish Employer Obligations for Work Permits

On this page · 9 sections

The Compliance Obligations: What Swedish Employers Must Do
What Most Employers Miss: The Post-Approval Gap
The June 2026 Law Changes: What's New
What Non-Compliance Costs
Building a Compliance Process That Works
Conclusion
Frequently Asked Questions
How Settio keeps permits on track
Sources

Example: a manufacturing company discovers that three of its employees on work permits are in breach of their permit conditions, not because anyone set out to break the rules, but because no one at the company knew the rules still applied after approval. The permits were granted, the employees were working, and everyone assumed that was the end of the compliance story. It wasn't. Swedish employer obligations for work permits extend well beyond the initial application. They run for every day of the permit's life and carry serious consequences if ignored, consequences that since 1 June 2026 include new crimes for exploiting foreign workers. This guide is the complete reference for HR teams managing international hires in Sweden.

The Compliance Obligations: What Swedish Employers Must Do

Sweden's work permit framework, governed by Migrationsverket, places the following obligations on employers:

1. Pay at least the salary the permit was granted on

For applications from 16 June 2026 the monthly salary must be at least 90% of the Swedish median, SEK 34,470, and also on par with the collective agreement (kollektivavtal) or what is normal in the occupation. Some exempt occupations and groups need 75% (SEK 28,725). This is not a point-in-time requirement, the agreed terms must be met throughout the permit.

2. Keep the insurances in place

The permit is granted on terms that include insurances such as occupational pension insurance. Coverage must be maintained at all times. If the company changes pension providers, check coverage for every employee on a permit explicitly during the transition.

3. Report worsened terms, if Migrationsverket has asked you to

Migrationsverket can give employers in certain sectors a reporting obligation (anmälningsskyldighet) when it grants a permit, and says so in the decision. The employer must then report worsened terms, such as a pay or hours cut, in writing within one month. Failing to report can lead to fines or imprisonment.

4. Check changes of occupation

During the first two years a work permit is tied to the employer and the occupation (after that, to the occupation only). Moving the employee to a different occupation, or giving them entirely new duties, requires a new permit application, not just an internal HR update.

5. Know what happens when employment ends or never starts

If the employment ends early, the permit's requirements are no longer met. The employee may stay for three months after the last working day to look for a new job, as long as the permit is still valid; after that the permit can be revoked. If the employee has not started work within four months of the permit being granted, the employer must report it to Migrationsverket.

6. Review permits when the employer entity changes

The permit is tied to the employer. Migrationsverket says employees with work permits need to apply for a new permit if the company changes owner or the employer changes its organisation number. Review every permit before a merger, acquisition or transfer of business.

What Most Employers Miss: The Post-Approval Gap

Most Swedish employers treat work permit compliance as an application task. File the application, get the approval, set a renewal reminder. This is the minimum, and it is not enough.

For example, imagine Lena works in HR at an Uppsala tech company. When they switch payroll providers, the new system categorises a portion of three employees' compensation as non-cash benefits, reducing their cash salary below the permit terms. Finance treats it as a standard payroll configuration. HR isn't involved. By the time the extension applications are filed 14 months later, all three employees have 14 months of payslips below the agreed salary, and the extensions are at risk.

The root cause of most permit violations is the absence of a cross-functional compliance process that connects Finance, HR, and Legal around the specific requirements of Swedish work permit law.

The June 2026 Law Changes: What's New

Swedish work permit law changed significantly on 1 June 2026:

Higher salary floor: 90% of the Swedish median (SEK 34,470 a month for applications from 16 June 2026), up from 80%. Extensions of permits first granted under the old rules need 80% (SEK 30,640) if applied for by 1 December 2026
Doubled special fee: The fee for employing someone without the right to work is now two price base amounts, or four if the work lasted more than three months
New crimes: Exploitation of foreign labour and trading in work permits, with up to two years in prison (four if gross)
The employer's own record: Migrationsverket can refuse permits where the employer is suspected or convicted of certain crimes, or has been charged the special fee or tax surcharges
Fewer revocations for minor errors: Migrationsverket no longer has to revoke a permit in minor cases or where revoking it would be unreasonable

What Non-Compliance Costs

Sweden's permit regime became stricter on 1 June 2026. The consequences of non-compliance include:

Revocation or refused extension: Migrationsverket can revoke a permit if the conditions are no longer met, or refuse the extension. Once a refusal has entered into force and can no longer be appealed, the employee must leave Sweden within the time stated in the decision.
Doubled special fee: Since 1 June 2026 the special fee (särskild avgift) for employing someone without the right to work in Sweden is two price base amounts, or four if the work lasted more than three months.
Criminal liability: Two new crimes were introduced on 1 June 2026, exploitation of foreign labour and trading in work permits, with up to two years in prison (four years if the crime is gross).
The employer's own record: Migrationsverket can now refuse work permits where the employer is suspected or convicted of certain crimes, or has been charged the special fee or tax surcharges.
Kompetensutvisning: Sweden's history of deporting skilled workers over employer mistakes, documented in cases such as Tayyab Shabab's. The June 2026 rules let Migrationsverket overlook minor shortfalls, but that is an assessment, not a guarantee. See our kompetensutvisning guide.

Migrationsverket can also check an employer during the permit period, not only at the extension. What it asks for and how to prepare is in our guide to Migrationsverket employer audits.

Building a Compliance Process That Works

For HR teams:

Create a permit register with: employee name, permit type, expiry date, salary threshold, last compliance check, pension insurance provider and review date
Run quarterly salary compliance checks against each permit's threshold
Implement a change notification protocol: Finance must notify HR (immigration team) before any salary or benefits change that affects sponsored employees
Brief your pension provider on the compliance implications of any coverage changes for sponsored employees
Set renewal reminders at 6 months before expiry to allow time for document gathering

Platforms like Settio add a continuous monitoring layer, flagging salary drift, upcoming extensions, or law changes before they become compliance failures.

Conclusion

Swedish employer obligations for work permits are comprehensive and continuous, and since June 2026 the penalties for serious failures are higher. The risk is not in the application stage. It is in the up to two years that follow. Building a structured compliance process, with cross-functional communication, a permit register, and continuous salary monitoring, is the only reliable way to meet these obligations. If your company hires international talent into Sweden, Settio can help you stay ahead of the risk. See how it works at settio.io.

Frequently Asked Questions

What must a Swedish employer report to Migrationsverket?

Employers must report if the employee has not started work within four months of the permit being granted. Employers that have been given a reporting obligation in the permit decision must also report worsened terms, such as a pay or hours cut, within one month. A change of occupation needs a new permit application rather than a report.

Does a role change require a new work permit in Sweden?

During the first two years, yes, if the employee moves to a different occupation: the permit is tied to the employer and the occupation. Migrationsverket also asks for a new permit when the employee gets entirely new duties. When in doubt, check before implementing the change.

What happens when a company is acquired and has sponsored employees?

Migrationsverket says that if the company changes owner, employees with work permits need to apply for new permits, and the same applies if the employer changes its organisation number. The employee can keep working if the new application is submitted before the new employment starts and before the old permit expires. Review every permit before a merger, acquisition or transfer of business.

How often should employers audit salary compliance for permit holders?

At a minimum, quarterly. Any event that changes compensation, payroll system migration, benefits restructuring, promotions, unpaid leave, should trigger an immediate audit for all permit-sponsored employees.

How Settio keeps permits on track

Most permit problems start with a date or a salary nobody was watching. Settio helps employers and immigration agencies watch both, for every person, before they move, after they arrive and at every renewal:

Permit and salary monitoring tracks every expiry date and the salary each permit was granted on, and turns a dip or a missing month into a follow-up step with an owner.
Plans for every case, from the first application to the extension, with each deadline counted for you.
Your whole international workforce at a glance: import the people already on permits and see their risks in minutes.

Try it with your own people: see plans and start for free.

Sources

8 official sources

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Swedish Employer Obligations for Work Permits: The Complete Guide