• Insights

Ireland: New Employment Permit Type, Labour Market Testing Improvements and Change of Employer Rules Forthcoming

July 4, 2024

insight-news-default

Country / Territory

  • IrelandIreland

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • Ireland will introduce a new employment permit for seasonal workers, streamline its labour market testing processes, and modify its ‘change of employer’ rules.
  • These reforms are part of the recently approved Employment Permits Act 2024, which also introduces new notification obligations, among other changes. The practical elements of this Act have not yet taken effect. 
  • When implemented, these reforms are likely to make it easier for employers to attract talent, though may also present administrative challenges in the context of the Irish government’s increased focus on compliance.

The situation

Following approval of the Employment Permits Act 2024, Ireland will introduce a new employment permit for seasonal workers and dependents, streamline Ireland’s labour market testing processes, and modify its ‘change of employer’ rules, among other changes. A timeline for implementation has not yet been provided. 

A closer look

CHANGE IMPACT

Seasonal employment permit. 

    • A new Seasonal Employment Permit for the employment of foreign national seasonal workers by approved seasonal employers will soon be available. Currently, Ireland does not have an equivalent work permit for seasonal workers.  
    • The permit will apply to ‘seasonally recurrent’ work that will occur for specified periods in the year (still to be defined in separate regulations) for between three to seven months. 
    • To be eligible to make such applications, employers will first need to receive government approval.
    • Applications for a Seasonal Employment Permit may be refused if the employer fails to arrange adequate accommodation or health insurance for the employee. 
    • This permit will provide employers with a new pathway to source seasonal talent, which is expected to benefit the horticulture and food production sectors. 
    • Currently, employers are either unable to source seasonal foreign workers or instead must rely upon alternative  immigration pathways, which are often more expensive or administratively challenging.

Digitised labour market testing processing.

Labour market testing in newspapers will no longer be required. Rather, such advertisements will only need to be placed on approved online platforms. Further details about eligible online platforms are to be clarified in future regulations. 

Employer are likely to benefit from more efficient labour market testing processes (as well as reduced costs).

Change of employer processes eased.

      • Amending employer:
        • General Employment Permit or Critical Skills Employment Permit holders will be able to apply to amend their employer, provided that their permit has at least two months validity remaining. Currently, such permit holders cannot amend their employer. Rather, they have to make an entirely new employment permit application. 
        • Seasonal Employment Permit holders will be able to apply to amend their employer, provided that their permit has three weeks validity remaining. 
        • Such requests may be refused if the new role is different from the preceding role, among other reasons. 
      • 12-month rule. The rule that disallows employees from applying for another employment permit until they complete 12 months under the first employment permit, will be modified to be between six to 12 months, depending on regulations (which are yet to be determined).
    • These changes may increase the attractiveness of Ireland for foreign workers, given the greater capacity for permit holders to flex with changing labour market conditions and opportunities.
    • However, as the rules make it easier for foreign workers to change employers, businesses may find themselves facing a weaker negotiation position vis-à-vis foreign staff.

The legislation makes the additional following changes, among others:

  • The government will be able to attach additional conditions to employment permits, like accommodation or education requirements, and other measures to reduce reliance on non-European Economic Area talent.
  • The law creates an official rule for employees to notify the Department of Enterprise, Trade and Employment (DETE) of any change of their home address or email address. 

Background

The primary goal of this act was to consolidate the assortment of multiple related amended acts implemented over a 15-year period. 

Looking ahead

  • More discretion to government. This act allows the Minister of Justice to amend rules using regulations to better respond to changes in the labour market without implementing further legislation. This will aid in the country’s changing in-demand roles and other factors in the labour market.
  • Further steps to implementation. For the Act to take effect, the Minister for Enterprise, Trade and Employment (or a delegated junior minister) will need to sign a commencement order, as well as make regulations to provide for specific rules. A timeline for these steps has not yet been provided by the government. 
  • Recent other reforms. This reform highlights a general trend in Ireland to continue liberalising its employment-based immigration landscape (or scaling back restrictive policies), including its largest ever expansion of the employment permits system; automatically granting work rights to eligible partners of various Irish employment permit holders; stepping back from raising the minimum salary level for healthcare workers; and reinstating a more relaxed eligibility framework for Stamp 4 permissions.

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].

Country / Territory

  • IrelandIreland

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Important Updates
Important Updates
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 5, 2026 | ArgentinaArgentina: Citizenship by Investment Program Details Announced; Applications Expected to Open Before Year-End
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 5, 2026 | ArgentinaArgentina: Citizenship by Investment Program Details Announced; Applications Expected to Open Before Year-End
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
Subscribe

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.