Lithuania: New Restrictions for Foreign Workers, Additional Obligations for Employers

Temporary residence permit requirement.

• Foreign nationals in Lithuania under a visa-exempt regime, a national or Schengen visa, or a residence permit issued by another country must now obtain a Lithuanian temporary residence permit if they want to work. Previously, this was not required.
• Along with other limited exceptions, this new policy does not apply to nationals of Australia, Canada, Japan, New Zealand, South Korea, the United Kingdom, and the United States.
• Foreign nationals who arrived in Lithuania prior to July 1, 2024 may continue working without first obtaining a temporary residence permit for the length of their legal stay.

Employers will find it harder to employ certain foreign workers, with new administrative requirements and associated costs, and additional onboarding stages – namely, the sourcing of a temporary residence permit.

Stricter education and work experience requirements to receive lower minimum salary threshold.

• Non-highly qualified foreign workers who do not possess both a) an adequate education qualification for the relevant role and b) at least one year of relevant work experience in the last three years must now be paid a salary at least equal to the average monthly gross salary for the previous calendar year. Such workers who do satisfy both criteria may be paid the minimum wage.
• Previously, non-highly qualified foreign workers could be paid the minimum wage in all circumstances.
• Non-highly qualified foreign workers are those foreign workers other than EU Blue Card holders, Qualified Activities Residence Permit Holders, and relevant ICT Permit holders.

These reforms will make it harder for employers to afford employing certain foreign workers, reducing the capacity of employers to resolve labor shortages.

Maximum number of employers. Foreign nationals can now only work for a maximum of four employers at one time; whereas previously they could work for an unlimited number of employers in a multi-employer contract.

This law seeks to protect foreign nationals working in multi-employer contracts,  ensuring employers participating in these contracts take responsibility for the employees.

Stricter change-of-employer rules. 

• Non-highly qualified foreign workers can now only change employers after six months of obtaining a temporary residence permit; whereas previously, they were not subject to any time limits on changing employers. 
• Highly qualified foreign workers (for instance, EU Blue Card holders, Qualified Activities Residence Permit Holders, and Intracompany Transferee Permit holders) can continue to change employers immediately upon arrival.

Although the more restrictive change-of-employer policy is likely to increase at least short-term retention of talent for employers, it also makes Lithuania less attractive for foreign workers, and may reduce long-term retention of foreign talent. 

EU Blue Card Holders and multiple job functions. EU Blue Card holders can now carry out an additional job function separate from the one for which they were originally hired. 

This will allow EU Blue Card employees to take on additional responsibility without having to change their job roles, giving employers greater flexibility to resolve talent management challenges – especially on an ad hoc or urgent basis.