By: HUB’s EB Global Benefits Team

What is it about?

Effective June 1, 2026, Sweden implemented significant changes to its labor migration framework affecting employers sponsoring non-EU/EEA nationals for work permits. The reforms introduce stricter salary requirements, new health insurance obligations, expanded employer scrutiny, and broader compliance powers for the Swedish Migration Agency.

The reforms reflect a broader policy direction in Sweden toward a more selective labor migration framework emphasizing higher-skilled employment, stronger employer accountability, and tighter immigration compliance controls.

One of the most important changes is the introduction of a new salary threshold for work permit eligibility. Under the revised rules, non-EU/EEA nationals (hereinafter referred to as “foreign individuals”) applying for a new work permit must generally receive compensation equal to at least 90% of Sweden’s median salary at the time of application. This replaces the previous “good maintenance” standard that had been used to assess whether compensation levels were sufficient. Employers must still ensure that compensation and employment conditions remain aligned with Swedish collective bargaining agreements or prevailing industry standards.

Although the government introduced certain exemptions from the 90% salary threshold for select occupations and categories of applicants, the exemptions remain relatively narrow and subject to evolving regulatory guidance.

The new salary threshold requirement applies based on the date the decision is issued rather than the date the application was submitted. As a result, applications filed before June 1, 2026 may still become subject to the new requirements if adjudicated after the implementation date.

The Swedish government has also introduced a limited transition rule for certain applications for work permit extension. Employees already holding work permits under the prior framework who apply for permit extensions between June 1 and December 1, 2026 remain subject to the earlier salary requirement equivalent to 80% of Sweden’s median salary.

Additional compliance obligations have been introduced for employers sponsoring foreign individuals. New notification requirements may obligate employers to inform authorities if sponsored employees fail to commence employment within specified timeframes. The reforms also expand information-sharing mechanisms between government agencies relating to employers involved in work permit sponsorship.

Another significant development involves health insurance requirements for foreign individuals assigned to Sweden for shorter durations. From June 1, 2026, individuals staying in Sweden for up to one year must demonstrate that they have obtained (or at minimum applied for) comprehensive health insurance coverage valid in Sweden.

This new requirement is particularly relevant because many temporary assignees and newly arrived foreign individuals may not immediately qualify for full access to the Swedish social insurance system upon arrival. As a result, employers may increasingly need to secure private health coverage solutions to support work permit compliance and employee protection during transitional periods.

The new rules are expected to have the greatest impact on:

  • Employers hiring foreign individuals into mid-level salary positions;
  • Companies with high international mobility activity;
  • Employers utilizing short-term assignments or project-based transfers;
  • Organizations relying heavily on foreign talent recruitment in competitive labor markets

Guidance should be sought from the Swedish Migration Agency on insurance products that comply with the health insurance requirements. In particular, requirements for comprehensive medical coverage during periods when employees are not yet fully covered by the Swedish social insurance system. Product solutions may include coverage for medical treatment, hospitalization, repatriation, travel-related risks, and other international assignment-related exposures.

Impact on companies

  • Organizations utilizing short-term international assignments or newly relocated employees will need to implement additional processes to secure compliant health insurance coverage.
  • HR, mobility, immigration, and legal teams will experience increased administrative obligations related to employer due diligence, permit documentation, government notifications, and ongoing immigration compliance monitoring.
  • Employers sponsoring non-EU/EEA workers will face materially higher compensation thresholds, increased compliance scrutiny, and greater work permit application complexity.

Suggested employer action

  • Review compensation structures for foreign individuals and pending work permit applications to assess compliance with the new salary thresholds effective June 1, 2026.
  • Evaluate whether any pending applications may be impacted by adjudication timing and consider alternative job filling where appropriate.
  • Coordinate with immigration counsel and mobility providers to assess new employer compliance obligations and enhanced scrutiny standards.
  • Review international assignment and onboarding processes to ensure appropriate compliant health insurance coverage is arranged for employees staying in Sweden for up to one year.
  • Assess whether existing global mobility insurance programs adequately address Swedish work permit and immigration-related insurance requirements.
  • Communicate the new requirements to HR, talent acquisition, mobility, and business leadership teams involved in international hiring and employee relocation activities.

If you have any questions, please contact your HUB advisor. View more updates in our Global Benefits Directory.