Mar 03 2021

Minimum Salary Changes Announced

Albania, Austria, Belarus, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, France, Georgia, Germany, Ireland, Latvia, Lithuania, Luxembourg, Netherlands, Poland, Portugal, Romania, Serbia, Slovak Republic, Slovenia, Turkey, Ukraine

 The following countries have announced changes in salary requirements effective in 2021: 

Albania

Effective January 1, 2021, the national minimum wage increased to ALL 30,000 gross per month, up 15.4% from the previous threshold ALL 26,000.

Other relevant considerations:

  • Market salary. Foreign workers must receive the market salary rate for the proposed position, not below ALL 30,000. Most foreign workers receive a salary well above the minimum wage level.
  • Compliance. The new requirements apply to current permit holders, pending and new / renewal applications.​
  • Benefits and allowances. Benefits and allowances may only be included in the minimum salary calculation if they are specified in the employment contract, guaranteed and fixed, and are not paid in kind.
  • Currency. Employers must ensure that the salary threshold in ALL is met, regardless of payroll location and/or exchange rate fluctuations.
  • Cost of living. The foreign national’s salary must be sufficient to cover the cost of living of the principal and any accompanying dependents. Applicants must submit bank statements with their residence permit application to demonstrate access to sufficient funds.

 

Austria

The salary levels increased by 2.4-3.4% on January 1, 2021 as follows: 

  • Red-White-Red Card (key employee) – over 30: EUR 3,300 gross per month, up from EUR 3,222
  • Red-White-Red Card (key employee) – under 30: EUR 2,775 gross per month, up from EUR 2,685 per month
  • Red-White-Red Card – graduate from Austrian university: EUR 2,497.50 gross per month, up from EUR 2,416.50
  • EU Blue Card: EUR 4,684.22 gross per month, up from EUR 4,548.00

Other relevant considerations include:

  • Existing employees. Employers of foreign nationals currently under a Red-White-Red Card need not increase foreign nationals’ salaries to comply with the new rule.
  • Initial and renewal applications. Employers of foreign nationals seeking to obtain or renew a Red-White-Red Card (for key employees and University Graduates) on or after January 1, 2021 must increase foreign nationals’ salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.
  • Pending applications. Employers of foreign nationals with pending applications as of January 1, 2021 need not increase foreign nationals’ salaries to comply with the new rule.
  • Unaffected categories. For the Short-Term Work Permit, the Short-Term Secondment Permit, the EU Intracompany Transferee (ICT) Permit and the Red-White-Red Card for professionals in shortage occupations, applicants and permit holders must meet the salary rate per the applicable collective bargaining agreement for the position. This requirement is not affected by the current changes. Employers are advised to monitor changes in collective bargaining agreements to ensure compliance.
  • Collective bargaining agreement. As before, salaries must also meet the salary rate set by collective bargaining agreement for the proposed position, if applicable. Exact figures depend on the company industry and the foreign worker’s qualifications and experience.
  • 14 payments per year. As before, salaries must be paid per the above listed amounts 14 times per year in general (applicable to local hire permits). 
  • Currency. As before, employers are required to guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations.
  • Dependents. If dependents are accompanying the third-country national, then the income must be sufficient to provide for the family. As a basic rule, EUR 1,578.36 gross per month for married couples and an additional EUR 154.37 for each child is required.

 

Belarus

Effective January 1, 2021, the minimum salary level required for Special Work Permit and Temporary Residence Permit applications increased as below:

  • Highly qualified employees: BYN 6,000 per month (15 times the minimum wage of BYN 400), up 6.6% from BYN 5,625;  
  • Other applicants: BYN 1,450 per month (50 basic units of BYN 29), up 7.4% from BYN 1,350.  
  • Dependents: Additional BYN 262.87 (until April 30, 2021) per month per accompanying dependent (updated quarterly).
  • Other relevant considerations:
    • Compliance. The new amounts apply to pending and new applications.  
    • Local payroll and currency. Foreign workers must be on Belarussian payroll and employers pay the salary in BYN. The amount of the salary may be set in a foreign currency at the rate of the service bank on the day of payment.
    • Sufficient funds upon entry. Foreign nationals must also be able to prove sufficient monetary funds in the amount of BYN 1,450 per month (50 basic units) upon entering Belarus.
    • Social security. The employer contributes an additional 34% of the monthly salary as mandatory social security insurance payments. 1% of the monthly salary is withheld from the foreign national as a mandatory social security insurance payment. The employer also pays a mandatory accident insurance contribution of approximately .6% of the salary.
    • Income tax. 13% of the salary is withheld from the foreign national as personal income tax (in some cases, the payer is eligible for tax deductions).

 

Belgium

The minimum salary level increased by 1.23-1.94% on January 1, 2021 as follows: 

Flanders (1.94% increase)

  • Executives (including managers under the forthcoming EU Intra-Company Transferee (ICT) Permit): From EUR 68,314 to EUR 69,638
  • EU Blue Card applicants: From EUR 51,235 to EUR 52,229
  • Specialists and trainees under the EU ICT Permit and for highly-skilled permit applicants: From EUR 42,696 to EUR 43,524
  • Locally hired staff under 30 years old: From EUR 34,156.80 to EUR 34,819.20

 

Brussels (1.23% increase):

  • Executives: From EUR 71,521 to EUR 72,399  
  • EU Blue Card applicants and managers under the EU ICT permit: From EUR 55,431 to EUR 56,111
  • Specialists under the EU ICT Permit: From EUR 44,344 to EUR 44,889       
  • Trainees under the EU ICT Permit: From EUR 27,715 to  EUR 28,056                       
  • Highly-skilled permit applicants: From EUR 42,869 to EUR 43,395          

 

Wallonia (1.23% increase):

  • Executives: From EUR 71,521 to EUR 72,399  
  • EU Blue Card applicants: From EUR 55,431 to EUR 56,112
  • Highly-skilled permit applicants: From EUR 42,869 to EUR 43,395
  • The Wallonia region will publish salary requirements for managers, specialists and trainees under the EU ICT Permit upon publication of the executing royal decree that would allow EU ICT Permit issuance. The publication date for this royal decree is not yet known.

 

Other relevant considerations include:

  • Currency. Employers must guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations. The exchange rate at the time of publication of this alert is 1 EUR to 1.08 USD.

  • Compliance. Employers of foreign nationals seeking to obtain or renew work authorization on or after January 1, 2021 must increase foreign nationals’ minimum salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be rejected.

  • Pending applications. Employers of foreign nationals with pending work authorization applications as of January 1, 2021 must increase foreign nationals’ minimum salaries to comply with the new rule, and must notify the authorities of the salary increase. Immigration applications that do not meet the minimum salary will be refused.

  • Benefits and allowances. Benefits and allowances generally cannot be included in the minimum salary calculation. In exceptional cases, allowances can be included provide they are: (1) a remuneration for services, (2) guaranteed and fixed, (3) taxable, and (4) indicated in the employee’s pay slip.

 

Bulgaria

The national minimum wage increased to BGN 650 per month, up 6.6% from BGN 610.

  • Affected categories. The increase affects the EU Intra-Company Transferee Permit, the Combined Permit and EU nationals. EU Blue Card applicants are subject to a different threshold.
  • Compliance. In case of threshold changes, salaries of current permit holders, workers with pending applications and new applications must all meet the new threshold.​​
  • Market salary rate. Applicants should receive the market salary rate for the proposed position, or the salary rate set by collective bargaining agreement, if applicable. The minimum wage serves as a final salary requirement.
  • Benefits and allowances. Benefits and allowances cannot be included in the minimum salary calculation.

 

Croatia

The national minimum wage increased to HRK 4,250 per month, up 4.6% from HRK 4,062.51.

  • Affected categories. The increase affects EU nationals and general Stay and Work Permit applications. Stay and Work Permit applicants under the Key Personnel and EU Blue Card routes are subject to a separate salary threshold. Stay and Work Permit applicants under the EU Intra-Company Transferee Permit route should receive a salary comparable to locally hired staff in similar job roles (market salary rate). Posted workers’ salaries must be in line with the wage of a local worker according to Croatian law (collective bargaining agreement) if the law is more favorable than the employment agreement.
  • Compliance. In case the threshold changes, employers must adjust the salaries of current foreign workers and those with pending or new applications, if required​.​​​​​​​
  • Benefits and allowances. Benefits and allowances cannot be included in the minimum salary calculation.
  • Currency. Employers are required to guarantee the salary in HRK regardless of payroll location and/or exchange rate fluctuations.

 

Czech Republic

UPDATE: Effective May 1, 2021, the EU Blue Card salary level will increase to CZK 53,417, up 4.4% from the current threshold of CZK 51,188.

  • Employment contract. The amount must be specified in the employment contract.
  • Recalculate threshold upon renewal. The thresholds may be recalculated upon renewal, depending on the family size.

 

The national minimum wage increased 4.1% on January 1, 2021, to CZK 15,200 per month from CZK 14,600 per month.  

  • Affected categories. The increase affects the Employee Card and Work Permit. The EU Blue Card is subject to a separate threshold updated mid-April. 

  • Formalities. The amount must be specified in the employment contract. 

  • Benefits and allowances. Benefits and bonuses are not included in the calculation. 

  • Minimum subsistence amount. Long-term visa applicants must each hold 15 times the minimum subsistence amount (currently CZK 2,490) for the first month of stay, and twice the minimum subsistence amount for every consecutive month of stay. I.e., for six months of stay, applicants require CZK 62,250 per person. Applicants under 18 need only show half this amount. Long-term business visa applicants must hold 50 times the minimum subsistence amount per month, currently CZK 124,500, for the full one-year visa validity. The full required amount must be available in a bank account when filing the application.  

  • Compliance. In case of threshold changes, the new amount applies to current employees, pending applications, and new or renewal applications. 

 

Denmark

The new minimum salary level in Denmark is DKK 445,000 per year, up 2% from the prior threshold DKK 436,000.

  • Initial applications. Employers of foreign nationals seeking to obtain a Work Permit after January 1, 2021 must increase the foreign national’s salary to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.
  • Pending applications. The changes do not affect pending applications.
  • Renewal applications.The changes do not affect renewal applications. Renewal applications can be filed based on the salary used in the previous application.
  • Benefits and allowances. As before, benefits and allowances generally cannot be included in the minimum salary calculation. Only basic salary, paid holiday allowance and payments to the labor market pension scheme can be included in the minimum salary calculation.

 

Estonia

The minimum monthly salary level in Estonia increased by 2.9% as below, and will be in effect until March 2, 2022.

  • Residence Permit for Employment: firm average or EUR 2,896 per month for top specialists; EUR 1,448 per month for other specialists (experts, advisors, consultants).
  • EU Blue Card: EUR 2,172 per month; or EUR 1,810 per month for specific sought-after occupations.

 

Other relevant considerations:

  • Additional funds for dependents. Foreign workers should receive sufficient salary to generate a legal income of EUR 360 per month per person in the family (threshold relevant if traveling to Estonia with several dependents).
  • Compliance. Current permit holders and pending applications continue to fall under former thresholds. Salaries need only be indexed when filing a new / renewal application.
  • Benefits and allowances. Benefits cannot be included in the calculation of the threshold.
  • Currency. Employers are required to guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations.
  • Start of payments. The salary must be paid per the threshold from the first day of work onwards. The salary must be paid monthly and cannot be prorated.​

 

France

Effective January 1, 2021, the minimum wage in France increased by 0.9% to EUR 1,554.58 per month, up from EUR 1,539.42 per month.  

  • Market salary rate. Most other French work authorization types require applicants to receive either the peer salary rate per the applicable French collective bargaining agreement; or a comparable rate to a local worker in a similar position; or the minimum wage; whichever is higher. Talent Passport – Salarié en Mission applicants must receive at least 1.8 times the minimum wage. 
  • Benefits and allowances. Benefits and allowances may only be included if they are a fixed amount, taxable, subject to social security, and visible on the payslip. Reimbursement of relocation expenses such as allowances for food, transportation, housing, and/or per diem cannot be included. An economic adjustment or assignment premium may be included if paid by the home employer and visible on the payslip. 
  • Currency. Employers are required to guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations. 
  • Compliance. The new threshold applies to current permit holders, pending and new applications. 
  • Unaffected categories. The EU Blue Card is subject to a separate salary threshold.

 

Georgia

The minimum salary level decreased to GEL 965 (five times the national minimum monthly wage of GEL 193), down 2.1% from GEL 985. The average national monthly salary is GEL 1,239.50.

  • Compliance. There is no restriction on decreasing salaries of foreign workers, provided that the new minimum salary level continues to be met.
  • Benefits and allowances. Benefits and allowances may only be included in the minimum salary calculation if they are specified in the employment contract, are guaranteed and fixed, and​ not paid in kind. Holiday allowance cannot be included in the minimum salary calculation.​

 

Germany

The EU Blue Card minimum salary increased 2.9% on January 1, 2021, to at least a gross annual salary of EUR 56,800. The minimum salary for shortage occupations will increase to at least a gross annual salary of EUR 44,304 EUR.

  • Existing employees and renewal applications. Employers of foreign nationals currently under an EU Blue Card need not adjust the foreign national’s salary. Employers of foreign nationals seeking to renew an EU Blue Card on or after January 1, 2021 need not adjust the foreign national’s salary.
  • Initial applications. Employers of foreign nationals seeking to obtain an EU Blue Card on or after January 1, 2021 must increase the foreign national’s salary to comply with the new rule.
  • Pending applications. Employers of foreign nationals with pending EU Blue Card applications as of January 1, 2021 must increase the foreign national’s salary to comply with the new rule if the employment contract start date is on or after January 1, 2021.
  • Other permit types. As a reminder, under the EU Intracompany Transferee (ICT) Permit (locally called ICT Card) and Local Hire Work & Residence Permit, foreign nationals must receive a salary comparable to a local worker.
  • Benefits and allowances. Contact your immigration professional for advice on benefits and allowances.
  • Currency. As before, employers are required to guarantee the salary in EUR, since EU Blue Card applicants must be on local payroll and paid in EUR.

 

Hungary

Effective January 28, 2021, the following salary levels increased in Hungary:

  • Minimum wage. The minimum wage increased by 3.9% to HUF 167,400 per month, up from HUF 161,000 per month; or HUF 219,000 per month for professional workers, up from HUF 210,600 per month. This increase primarily affects EU nationals, as other foreign workers are subject to different salary requirements that in most cases require a salary well above the minium wage level.
  • EU Blue Card. EU Blue Card applicants should now receive HUF 598,950, up 21% from the prior threshold of HUF 494,850. This increase is based on a 21% national average salary to HUF 399,300, up from HUF 329,900; EU Blue Card applicants should receive at least 150% of the national average wage.
  • Unaffected categories. The wage increase does not affect Short-Term Work Permits and Single Permits for local hires, for which foreign workers should receive at least 80% of the national average salary for the relevant position; or the EU Intra-Company Transferee (ICT) Permit, for which applicants should receive the national average salary for the relevant position.
  • Exchange rate. The exchange rate at the time of publication of this alert is 1 HUF to 0.0034 USD.
  • Existing employees. Employers of EU nationals and foreign nationals currently under a Short-Term Work Permit or Single Permit for Local Hire must increase foreign nationals’ salaries to comply with the new rule.
  • Initial and renewal applications. Employers of foreign nationals seeking to obtain or renew a Short-Term Work Permit or Single Permit for Local Hire on or after January 1, 2020 must increase foreign nationals’ salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.
  • Pending applications. Employers of foreign nationals with pending Short-Term Work Permit or Single Permit for Local Hire applications as of January 28, 2021 must increase foreign nationals’ salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.
  • Benefits and allowances. As before, benefits and allowances cannot be included in the minimum salary calculation.
  • Net amounts. Net amounts may change based on correction factors (like family allowance, company cafeteria etc.) which depend on personal conditions and company policies.

 

Ireland

The minimum wage increased by 1% on January 1, 2021, to EUR 10.20 per hour from EUR 10.10 per hour.

  • Affected categories. The increase affects the short-term Atypical Working Scheme (AWS) and Intra-Company Transferee Permit (for the latter, the home base salary should meet the national minimum wage); but does not affect the Critical Skills Employment Permit (CSEP) or General Employment Permit.

  • Currency. Employers must guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations. The exchange rate at the time of publication of this alert is 1 EUR to 1.08 USD.

  • Compliance. Employers of foreign nationals seeking to obtain or renew AWS or ICT work authorization on or after January 1, 2021 must increase foreign nationals’ salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.

  • Pending applications. Employers of foreign nationals with pending AWS or ICT work authorization applications as of January 1, 2021 must increase foreign nationals’ salaries to comply with the new rule. Immigration applications that do not meet the minimum salary will be refused.

  • Benefits and allowances. Inclusion of allowances in the salary calculation varies between permit types.

 

Latvia

UPDATE: Effective April 1, 2021, the minimum salary level for Residence Permit with Work Authorization and EU Intra-Company Transferee Permit applicants increased to EUR 1,143 gross per month, up 6.2 percent from the current EUR 1,076 threshold.  

Also, effective April 1, 2021, the minimum salary level for EU Blue Card applicants increased to EUR 1,715 gross per month, up 6.3 percent from the current EUR 1,614 threshold. 

  • Benefits and allowances. Benefits and allowances may only be included in the minimum salary calculation if they are specified in the employment contract, guaranteed and fixed, and are not paid in kind. Specifically, discretionary compensation, insurance contributions, and non-recurring payments can be included in the salary calculation. 
  • Staff on home contract. For staff on home employment contract, benefits and allowances may not be intended as expense reimbursement to include them in the salary calculation. If the compensation package includes reimbursements, and various pay elements are insufficiently substantiated, the full home salary will be considered expense reimbursement and cannot be included in the calculation.  
  • Currency. Employers are required to guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations. 

The national minimum wage in Latvia increased to EUR 500 gross per month, up 16.2% from EUR 430. The additional sum foreign workers must receive for accompanying children increased to EUR 150 gross per month, up 16.2% from EUR 129.

  • Affected categories. The increases affect EU nationals and foreign workers with accompanying family, as they must receive EUR 500 in addition to the minimum salary requirement for an accompanying spouse, and EUR 150 in addition to the minimum salary requirement for each accompanying child. Residence Permit with Work Authorization and EU Blue Card applicants are subject to a different salary requirement which remains unchanged.
  • Compliance. The new amounts apply to current permit holders, pending and new applications.

 

Lithuania

The national minimum wage in Lithuania increased to EUR 642 per month, up 5.8% from EUR 607 per month. EU Blue Card applicants should receive a salary 1.5 times the national average monthly gross salary.

 

Luxembourg

Minimum salary levels in Luxembourg increased by 2.8% on January 1, 2021.

  • Non-graduate workers: EUR 2,201.93 gross per month, up from EUR 2,141.99 gross per month. This category applies to non-graduate Work Permit for Salaried Workers applicants. 
  • Qualified workers: EUR 2,642.32 gross per month, up from EUR 2,570.39 gross per month. This category applies to EU, European Economic Area and Swiss nationals; EU Intracompany Transferee (ICT) Permit applicants; and graduate Work Permit for Salaried Workers applicants. 
  • Unaffected categories. EU Blue Card applications are subject to a separate threshold, which is not annually updated.
  • Compliance. The new rate applies to pending and new applications, as well as current permit holders. 
  • Market conform salary. EU ICT Permit applicants must receive a salary similar to a local employee in the same position, if higher. 
  • Benefits and allowances. Benefits and allowances may be included if specified in the assignment letter or employment contract, processed through payroll for payment into the foreign national’s bank account, not paid in kind, paid at regular intervals throughout the assignment period (excluding one-off payments), guaranteed and fixed (excluding performance-based bonuses).
  • Currency. Employers are required to guarantee the salary in EUR regardless of payroll location and/or exchange rate fluctuations.

 

Netherlands

Minimum salary levels in the Netherlands increased by 3% on January 1, 2021, as below.  

  • Short-term work permit: EUR 5,132.16 gross/month, up from EUR 4,981 gross/month. Under the short-term highly skilled migrant work permit, for applicants under 30 EUR 3,762.72 gross/month will suffice, up from EUR 3,652 gross/month. Additionally, short-term highly skilled migrant work permit applicants must receive a home base salary at or above Dutch minimum wage (indexed twice a year). 

  • EU Intra-Company Transfer (ICT) Permit, applicants over 30: salary comparable to local workers in a similar position, or at least EUR 4,752 gross/month, up from EUR 4,612 gross/month.  

  • EU Intra-Company Transfer (ICT) Permit, applicants under 30: salary comparable to local workers in a similar position, or at least EUR 3,484 gross/month, up from EUR 3,381 gross/month.  

  • Highly Skilled Migrants, applicants over 30: EUR 4,752 gross/month, up from EUR 4,612 gross/month. 

  • Highly Skilled Migrants, applicants under 30: EUR 3,484 gross/month, up from EUR 3,381 gross/month. 

  • Graduates and job search permit holders, changing status to a Highly Skilled Migrant permit: EUR 2,497 gross/month, up from EUR 2,423 gross/month.  

  • Blue Card: EUR 5,568 gross/month, up from EUR 5,403 gross/month.

Other relevant considerations include:

  • Compliance. The new amounts do not apply to current permit holders. Renewal applicants and individuals changing status must however meet updated salary requirements when filing the renewal or change of status application.  

  • Pending applications. The new thresholds apply to applications filed in 2021. Applications filed in 2020 may continue to meet the 2020 salary requirements.  

  • Benefits/allowances. Benefits and allowances can be included for long-term permit applications, provided that they are fixed and guaranteed; mentioned or specified in the assignment letter or employment contract; received in money, not in kind; and paid on a monthly basis. Holiday allowance; value of payment in kind; and non-regular pay elements such as overtime allowances and performance bonuses may not be included. For short-term intra-company transfer work permit applications, benefits and allowance cannot be included.  

  • Audits. Frequent applications exactly on the threshold may trigger questions and audits. 

  • Currency. Employers are required to guarantee that the salary meets the threshold in EUR, regardless of payroll location and/or exchange rate fluctuations. For EU ICT Permit Trainee applications, amounts must be indicated in approximate EUR amounts in the assignment letter. ​ 

 

Poland

UPDATE: Effective February 9, 2021, the minimum salary level for EU Blue Card applicants increased to PLN 7,751.21 gross/month, up 5.1 percent from PLN 7,378 gross/month. This salary level amounts to 150% of the average national salary as announced quarterly by the Central Statistical office. Employers need not increase salaries of current permit holders, or for applications submitted in 2020.  

Effective January 1, 2021, the national minimum wage applicable to local hires in Poland increased by 7.7% to PLN 2,800 gross per month, up from PLN 2,600 gross per month. For work based on a civil contract (e.g. for temporary projects), the minimum salary increased by 7.6% to PLN 18.3 gross per hour, up from PLN 17 gross per hour.

  • Unaffected categories. These threshold changes only impact locally hired staff. Intracompany transfer and EU Blue Card applicants are subject to a separate threshold.  
  • Market conform salary. The salary must be similar to that of other employees performing similar jobs at the sponsoring employer.
  • Sufficient funds. The salary must be sufficient to support the foreign national and any dependents during his/her stay.
  • Compliance. In case of threshold changes, the new thresholds apply to current permit holders, pending applications, and new or renewal applications. Employers must increase foreign workers' salaries to comply with the new rules if required
  • Benefits and allowances. Benefits and allowances may not be included in the minimum salary calculation for local hires.
  • Currency. Foreign nationals must be on local payroll and paid in PLN.​

 

Portugal

Effective January 1, 2021, the national minimum wage in Portugal increased by 4.7% to EUR 665 per month calculated over 14 payments, up from EUR 635 per month.

  • Additional funds for dependents. Applicants should additionally receive EUR 332.50 per month for an accompanying spouse or child over 18 (50% of the minimum salary); and an additional EUR 199.50 per month per accompanying child under 18 (30% of the minimum salary), calculated over 14 payments.
  • Affected permit types. The salary threshold increases affect the Temporary Stay Visa and Residence Visa for Local Hires; but do not affect the Residence Visa for Highly Qualified Staff and the EU Blue Card.
  • Compliance. The threshold must be met by both current permit holders and new applicants.
  • Benefits and allowances. If staying on home contract, the cost of living and housing allowances can be included in the calculation, provided that these allowances are transferred to the foreign national’s bank account, paid monthly, taxable, processed via payroll, guaranteed and fixed.
  • Salary reductions. Salary cannot be prorated except in the first and last month of employment or assignment.
  • Currency. The employer must guarantee that salary payments meet the threshold in EUR regardless of payroll location or currency fluctuations.

 

Romania

UPDATE: Effective March 12, the average gross salary for 2021 is set at RON 5,380, down 0.9% from the previous threshold. Consequently, EU Blue Card’s holders (i.e., highly skilled work permit applicants) must now receive a salary of at least RON 10,760 gross per month. The new threshold applies to current permit holders, pending and new applications. 

Effective January 13, 2021, Romania's salary level for non-graduate roles increased by 3.1% to RON 2,300 gross per month, up from RON 2,230. The graduate salary requirement of RON 2,350 gross per month remains unchanged. 

  • Affected categories. EU Intra-Company Transferee (ICT) Work Permit for Short-Term Mobility, Work and Residence Permit for Local Hires. The general EU ICT Permit and EU Blue Card are subject to a separate salary threshold. 
  • Compliance. If the salary threshold is indexed, employers must increase foreign workers' salaries for new applications, pending applications and current permit holders.
  • Additional funds for dependents. Local hires should additionally receive once the applicable minimum salary rate per accompanying dependent. In general, the salary must be sufficient to sustain the foreign national for the entire duration of stay.
  • Benefits and allowances. Benefits and allowances may only be included if they are specified in the assignment letter; guaranteed and fixed; and not paid in kind. Holiday allowance cannot be included.
  • Currency. Employers must guarantee that the threshold is met in RON, regardless of contract and payroll location.

 

Serbia

Effective January 1, 2021, the national minimum wage increased by 6.6% to RSD 183.93 net per hour, up from RSD 172.54 net per hour.

  • Affected categories. The minimum salary level applies to locally hired foreign nationals. 
  • Monthly variation. The salary required per month fluctuates, depending on the number of working hours that month (ranging from 160 working hours in February to 184 working hours in January). 
  • Benefits and allowances. Benefits and allowances may not be included in the salary calculation.
  • Compliance. The new threshold applies to new applications, pending applications, and current permit holders.

 

Slovakia

The national minimum wage increased to EUR 623 per month, up 7.4% from EUR 520.

  • Affected categories. The increase affects EU nationals and Single Permit for local hires applicants. EU ICT Permit applicants are not subject to minimum salary requirements as they remain on home payroll. EU Blue Card applicants should receive at least 1.5 times the average industry wage.
  • Compliance. In case of threshold changes, the new amounts apply to pending and new applications and current permit holders.
  • Benefits and allowances. Benefits and allowances cannot be included in the minimum salary calculation.
  • Sufficient means. All foreign nationals must have sufficient financial means of support, i.e. must have funds available at the level of the minimum living allowance per month (amounts indexed annually in July; threshold varies based on the number of dependents). ​

 

Slovenia

The national minimum wage increased to EUR 1,024 gross per month on January 31, 2021, up 8.9% from EUR 940.58 gross per month. 

  • Market salary rate. Foreign nationals must receive a salary comparable to a local worker in the same position, per the applicable collective bargaining agreement. 
  • Compliance. If the threshold changes, the new thresholds apply to current permit holders, pending and initial applications.
  • Benefits and allowances. Benefits and allowances cannot be included in the minimum salary calculation.
  • Currency. Employers must guarantee compliance with the salary level in EUR regardless of payroll location. For local hires, employers must pay the salary in EUR.

 

Turkey

Effective January 1, 2021, the minimum monthly wage increased to TRY 3,577,50 per month, up 21% from TRY 2,943 per month in 2020. The exchange rate at the time of publication of this information is TRY 1 = USD .14. Salaries for foreign workers, which are linked to the minimum wage, are affected as follows:

  • High-level managers and pilots. TRY 23,253.75 (6.5 times minimum wage)
  • Department managers, engineers, architects. TRY 14,310 (four times minimum wage)
  • Employees with expertise, teachers. TRY 10,732.50 (three times minimum wage)
  • General staff, e.g. sales officers and low-level marketing officers. TRY 5,366.35 (1.5 times minimum wage.

Other relevant considerations include:

  • Existing employees. Employers of foreign nationals currently under a work permit need not increase foreign nationals’ salaries.
  • Initial and renewal applications. Employers of foreign nationals seeking to obtain or renew a work permit on or after January 1, 2021 must increase foreign nationals’ salaries to comply with the new rule. Work permit applications that do not meet the minimum salary will be refused.
  • Pending applications. Employers of foreign nationals with pending work permit applications as of January 1, 2021 need to increase foreign nationals’ salaries upon Ministry of Labor’s request.
  • Benefits and allowances. As before, benefits and allowances may not be included in the minimum salary calculation.
  • Safe margin. As before, Fragomen recommends slightly rounding the salary up, to maintain a safe margin above the threshold.
  • Permit duration. As before, employers are required to guarantee the salary throughout the validity of the work permit.

 

Ukraine

The minimum salary level increased to UAH 60,000 per month (10x the UAH 6,000 minimum wage), up 27% from UAH 47,230 gross per month.

  • Exempt categories. As before, the following categories of applicant are exempt from this threshold: graduates of top-100 universities, per specified international rankings; information technology professionals employed by software development companies; workers in creative professions, creating copyright objects; founders, shareholders, and/or ultimate beneficiary owners of companies.
  • Highly paid professionals. Applicants earning a monthly gross salary of at least UAH 300,000, as well as the exempt categories listed above, are eligible for a three-year permit instead of the standard one-year permit.
  • Compliance. The new salary levels apply to current permit holders, pending, and new applications.​
  • Benefits and allowances. Benefits and allowances cannot be included in the minimum salary calculation.
  • Currency. Employers are required to guarantee the salary in UAH regardless of payroll location and/or exchange rate fluctuations.
  • Further increase in December. Effective December 1, 2021, the minimum salary will increase to UAH 6,500