Sweden - New Work-Permit Application Process

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During a 12 May press conference, the Swedish government announced that the current certification scheme for work permits (known as “fast track”) will be replaced later in 2023.¹ Director General Mikael Ribbenvik has taken a directional decision for the Swedish Migration Agency in providing instructions for implementing a new process for work and residence permit applications. The current certification scheme that had provided a faster processing time will be replaced by a system that will categorise and prioritise applications based on occupation and industry. 

The new model -- to be introduced at the end of the year -- will promote, in particular, recruitment for employers looking for highly-qualified labor outside the European Union (EU). It also aims to shorten the processing time for all labour market matters. This aims to bring flexibility and efficiency to businesses in planning to meet their labour needs. 

When implemented, the old certification scheme was only intended for about 20 big companies that had a recurring need to employ large numbers of individuals outside of the EU. Today there are, according to the Migration Agency, far too many companies (640 mentioned during the press conference) that have been included in the certification process, and the authority has been unable to meet the target processing times of 10/20 days for the past 18 months. The extensive processing times have resulted in loss of talent and skills for companies in Sweden. The certification scheme has lost its original purpose and will now be replaced with a new system, based on four categories. The last day to apply for becoming a certified operator under the current scheme will be 31 May 2023.

The new priority list will consist of four categories.  The Immigration authority´s top priority is to shorten the work permit application process for highly-skilled workers who make up the first category. A maximum processing time of 30 days is promised for applications that are complete when submitted. Agents such as KPMG in Sweden will still be able to submit applications on behalf of the company and its employees.

Category A covers applications for highly-qualified occupations and applies to three areas: managerial occupations, occupations which require advanced university competence and occupations which requires higher education competence or equivalent. This category will be the authority´s way to replace the current certification scheme.

Category B includes applications for work permits in occupations which have specific rules, such as seasonal occupations, intra-corporate transfers (ICT), permits under the EU Blue Card Directive, etc. Both ICT and EU Blue Card applications today already have a specific processing time regulated in the Swedish Alien´s Act of 90 days. (For prior coverage, see GMS Flash Alert 2023-90, 2 May 2023.) This category will also include applications to start business activities.

Category C covers applications that do not require a higher education competence and non-highly-qualified occupations in sectors that do not require a higher level of case investigation by the authority. This category includes occupations that constitute an important social benefit even though not classified as highly-qualified. Applications for major new establishments in growth areas are also part of this category.

Category D is for the work permit applications within the sectors that the Migration Agency defines as particularly demanding in terms of case investigation. These sectors include cleaning, construction, personal assistance, and hotels and restaurants.

The Migration Agency will be working on implementing this new process, setting up new entities within the authority and will report back to the government before 4 September 2023. The changes are planned to go live by the end of this year.

The government and the Swedish Migration Agency taking action to improve the current system for work permit applications is a positive development. For far too long the certification scheme has failed to deliver on the set-out agreement between companies and the authority. At this stage, there is little information on the new process and how it will work, but KPMG in Sweden is encouraged. Although the current fast track or certification scheme will no longer be in place, it is hoped that this new commitment from the government will result in a system which is faster and more predictable.

Several changes have already been enforced when it comes to the process of applying for different types of work and residence permits in Sweden. It has been the experience of KPMG in Sweden that confusion has followed these changes. Little or no information has previously been communicated by the Migration Agency and it has taken time for the authority to implement and interpret new regulations. KPMG in Sweden will therefore closely follow unfolding developments and endeavour to report further on the subject.

1   See Swedish government Regeringskansliet website, (in Swedish) Redovisning av uppdrag om högkvalificerad arbetskraftsinvandring .

* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

The information contained in this newsletter was submitted by the KPMG International member firm in Sweden.