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🇸🇪HR Compliance29 May 2026 · 10 min read

Swedish Employer Obligations for Work Permits, from Offer to Expiry

Swedish employer obligations for work permits run for the whole permit period: salary, insurances, reporting, changes of role or employer entity, and what the June 2026 rules added.

On this page · 8 sections
  1. What the employer must do
  2. Where it goes wrong after approval
  3. The June 2026 Law Changes: What's New
  4. What Non-Compliance Costs
  5. Building a Compliance Process That Works
  6. Frequently Asked Questions
  7. How Settio keeps permits on track
  8. Sources

Swedish employer obligations for work permits do not end when the permit is granted. The terms the permit was granted on have to hold for the whole permit period, and they are checked again at the extension. Since 1 June 2026 the sanctions for serious failures are also higher, including two new crimes. This guide lists what the employer is responsible for, in the order it comes up.

What the employer must do

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.

Where it goes wrong after approval

Gaps usually open in other departments. A new payroll system that books part of the pay as a non-cash benefit can take the cash salary below the permit terms; a change of pension provider can leave someone without occupational pension insurance. Nobody notices until the extension, when the payslips for the whole period are checked. Agree with payroll and finance that any change to pay or benefits for an employee on a permit goes past HR first.

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

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 reported since 2016. Since 2022 the law lets Migrationsverket overlook minor cases, 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
  • Agree that finance and payroll tell HR before any salary or benefits change for an employee on a permit
  • When the pension provider or plan changes, check the coverage of every employee on a permit
  • Set renewal reminders at 6 months before expiry to allow time for document gathering

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 to work permits when a company is acquired?

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?

There is no legal interval. Checking every quarter, and again after any event that changes pay (a payroll system change, a benefits change, a promotion, unpaid leave), catches a gap long before the extension.

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:

Try it with your own people: see how to start for free.

Sources

8 official sources

More in our guide toWork permit mistakesAI immigration compliance

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