Migrationsverket Employer Audits: What to Expect and How to Prepare

Why Migrationsverket audits employers

Swedish law requires employers to maintain the conditions declared in work permit applications throughout the duration of each permit. Migrationsverket conducts targeted audits — arbetsgivarkontroller — to verify that salary, working hours, role, and employment conditions still match what was approved. Audits are triggered by complaints, random selection, or red flags such as unusually high application volumes from a single employer or prior refusals.

What auditors check

• Salary vs declared amount: Auditors compare payslips against the salary stated in the work permit application. If the employee is being paid below the declared salary, the permit can be revoked regardless of whether the salary still meets the collective agreement minimum.
• Working hours: The number of hours per week must match the application. Part-time employees whose hours have been reduced without a permit amendment are a common audit finding.
• Role and SSYK code: If the employee's actual duties have diverged significantly from the role described in the permit, this may constitute an unlicensed change of employment conditions.
• Ongoing employment: The employee must still be employed. If the employment has ended, the employer must have notified Migrationsverket. Failing to notify within the required timeframe is a compliance breach.
• EU/EEA advertisement records: For standard work permits, auditors may request evidence that the original advertisement was published for at least 10 days.

Document retention: what to keep and for how long

Swedish HR record retention requirements mandate that employment records be kept for at least 7 years. For work permit compliance specifically, HR should retain:

• The original signed job offer for each permit application
• Payslips covering the full permit period
• The advertisement proof used in the initial application
• Any correspondence with Migrationsverket regarding the case
• Records of any changes to salary, role, or hours during the permit period

Consequences of non-compliance

If an audit finds material non-compliance, Migrationsverket can:

• Revoke the employee's work permit — the employee loses the right to work and may have to leave Sweden.
• Issue a ban on the employer sponsoring new work permits for up to 2 years.
• Refer the case to the Swedish Tax Agency (Skatteverket) or the Police if deliberate fraud is suspected.

Preparing for an audit

Most employers are notified before an audit and given 2–4 weeks to prepare documentation. The most effective preparation:

1. Pull the complete case file for every active work permit holder: permit decision, job offer, payslips, and any amendments.
2. Cross-check current salaries against the declared amounts in each permit application. Flag any employees whose salary has changed since the permit was granted.
3. Verify that no permit holders have had their role or working hours changed without a corresponding permit amendment.
4. Confirm that employees whose employment ended had their termination reported to Migrationsverket promptly.

Settio maintains a complete audit trail for every case — job offers, payslips, activity log, and all correspondence — making audit preparation a matter of exporting a case report rather than a weeks-long document hunt.