Important Updates
Important Updates
January 6, 2026 | CanadaCosmina Morariu Named Managing Partner of Fragomen’s Canadian Practice
January 7, 2026 | New Zealand, IndiaIndia/New Zealand: Free Trade Agreement Will Provide New Zealand Increased Access to Talent from India
January 7, 2026 | 🌐Minimum Salary Changes Announced
January 6, 2026 | Japan, United States2025年12月 アメリカ移民法ダイジェスト
January 6, 2026 | BrazilBrazil: New Humanitarian Visa Framework Introduced, Replacing Country-Specific Programs
January 6, 2026 | CanadaCosmina Morariu Named Managing Partner of Fragomen’s Canadian Practice
January 7, 2026 | New Zealand, IndiaIndia/New Zealand: Free Trade Agreement Will Provide New Zealand Increased Access to Talent from India
January 7, 2026 | 🌐Minimum Salary Changes Announced
January 6, 2026 | Japan, United States2025年12月 アメリカ移民法ダイジェスト
January 6, 2026 | BrazilBrazil: New Humanitarian Visa Framework Introduced, Replacing Country-Specific Programs
January 6, 2026 | CanadaCosmina Morariu Named Managing Partner of Fragomen’s Canadian Practice
Subscribe
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
    Navigating Immigration Under the Second Trump AdministrationFragomen Consulting EuropeImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView 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

  • Navigating Immigration Under the Second Trump Administration
  • Fragomen Consulting Europe
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • 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
  • Insights

New Occupational Limitations and Local Worker Succession Plan Requirements Introduced for Work Authorization Applications

May 31, 2019

insight-news-default

Country / Territory

  • ZambiaZambia

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

  • Foreign nationals seeking to work in Zambia will be allowed to apply for work authorization only for positions appearing on a new critical skills list, under a recently enacted employment act that takes effect on June 1, 2019.
  • The act also introduces new local worker succession plan requirements, under which employers will have to designate a local understudy for each foreign national employee. They must also create a training program to ensure that skills are transferred from the foreign worker to his or her understudy.
  • Employers will be required to provide details of all foreign nationals to the Labour Commission, which will be maintaining a register of expatriate workers in the country.

The situation

In an attempt to tighten immigration rules and protect the local labor market, the Zambian Government has approved the Employment Code Act No. 3 of 2019, which introduces a number of new policies, including: the creation of a critical skills list, new succession plan requirements, the creation of a Skills Advisory Committee, and other new rules.

The Act takes effect on June 1, 2019; however, implementing regulations for some aspects of the new law, such as on how the critical skills list will be developed, have not yet been released.

A closer look

The Employment Code Act No. 3 of 2019 introduces the following:

  • Critical Skills List. Foreign nationals seeking to work in Zambia will be allowed to apply for work authorization only for positions appearing on an official critical skills list. The Act tasks a Skills Advisory Committee with developing the critical skills list, through a consultation process with relevant stakeholders. The list must be published for public comments before implementation. It is unclear when the Committee will be convened for the first time or when the first version of the list will be published.
    • Impact. Depending on what occupations appear on the critical skills list, this change could result in a significant restriction on the types of jobs foreign workers will be permitted to fill in the future. Employers will need to work with their immigration providers to review the critical skills list before applying for work authorization in Zambia.
  • Succession plan. For all work authorization applications, employers will be required to:
    • Designate a local worker to act as an understudy for each foreign worker;
    • Submit a schedule for a training program that outlines how skills will be transferred from the foreign worker to his or her understudy over a two-year period; and
    • Submit annual reports that provide names and other information about all foreign employees to the Labour Commissioner, which will maintain a register of all foreign national employees.
    • Impact. Employers will need to develop strategies for meeting the new succession plan requirements that include: (1) how to find or identify potential understudies; (2) details of their training programs; and (3) ways to account for the extra time necessary to prepare work authorization applications.
  • New prohibitions. The Act also prohibits the following:
    • Allowing a foreign employee to work in a position that he or she is not authorized to perform;
    • Terminating or laying off a Zambian citizen or resident after or as a result of employing a foreign worker; and
    • Using coercion, threats, or other illegal means to induce a foreign national to work without his or her consent.
    • Impact/potential sanctions. Noncompliance with these new rules can lead to an employer’s arrest and criminal charges. If convicted, an employer could be sentenced to significant fines or imprisonment for a term of up to three years, or both.

 

Background

Zambia has previously considered succession plan requirements and training programs (which are common in Africa), but this is the first time the government has been formally implemented such measures.

Looking ahead

The immigration provisions of the Act indicate that the Zambian government is seeking to restrict rules on foreign labor. While it remains to be seen how restrictive the critical skills list will be, employers should expect new challenges if relying on foreign workers for the skills they need for their business.  

Further information on the critical skills list will be provided when it is available.

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

  • ZambiaZambia

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

Fragomen news

2025年12月 アメリカ移民法ダイジェストLearn more

Fragomen news

Cosmina Morariu Named Managing Partner of Fragomen’s Canadian PracticeLearn more

Blog post

Ireland Employment Permits Update: 2026 Salary Threshold Changes for Graduate Hiring

Immigration Manager Alice Heron examines Ireland’s updated employment permit salary thresholds taking effect in March 2026, including the reintroduction of graduate-specific Minimum Annual Remuneration bands and what these changes mean for employers planning graduate recruitment in 2026 and 2027.

Learn more

Fragomen news

Fragomen Announces 2026 Partner Class and Counsel ElevationsLearn more

Media mentions

Bloomberg Law: New H-1B Rule Pushes Employers to Rethink Workforce Options

Partner Jill Bloom explains how the new wage-based H-1B selection rule may influence hiring decisions and prompt employers to reassess workforce planning and explore alternative visa options.

Learn more

Media mentions

Business Insider: Immigration Lawyers Say the H-1B Chaos Is Forcing Tough Business Calls

Partner K. Edward Raleigh discusses how companies are rethinking their H-1B strategies amid evolving policies.

Learn more

Awards

Mitch Wexler Named 2025 Top 25 Immigration Attorney by EB5 Investors Magazine

Senior Counsel Mitch Wexler is recognized by EB5 Investors Magazine as a 2025 Top 25 award recipient, reflecting leadership and long-standing impact in the global investment immigration space.

Learn more

Blog post

US Green Card by Investment | EB-5 and Gold Card Options for Middle Eastern Investors

Partners Isha Atassi and Rahul Soni outline key considerations across the EB-5 Immigrant Investor Program and the US Gold Card, comparing eligibility, investment structures and risk factors for high-net-worth individuals from the Middle East seeking US permanent residence.

Learn more

Media mentions

Franceinfo: États-Unis : bientôt une inspection au peigne fin des réseaux sociaux avant d'entrer sur le territoire

Partner K. Edward Raleigh commented on proposed changes to US entry requirements.

Learn more

Video

The Schengen C Visa: What Non-EU Nationals Need to Know About 90/180-Day Travel

Business Immigration Consultant Marisa Gizzi from Fragomen explains everything about the Schengen C Visa: who needs it, how to apply and key travel tips to stay compliant in the Schengen Area. 

Learn more

Media mentions

Toronto Star: Canada Wants to Bring in 1,000 Researchers and Skilled Workers. Here’s What It Will Take

Partner Rick Lamanna discussed Canada’s $1B plan to attract global researchers.

Learn more

Blog post

Tier 1 Investor Visa Extension Deadline | February 2026 UK Update

Manager Alex Hood, Senior Associate Kimberley Ong and Immigration Paralegal Ataa Rajput explain the final extension and settlement deadlines for UK Tier 1 Investor visa holders and outline who can still qualify and why early action is essential.

Learn more

Fragomen news

2025年12月 アメリカ移民法ダイジェストLearn more

Fragomen news

Cosmina Morariu Named Managing Partner of Fragomen’s Canadian PracticeLearn more

Blog post

Ireland Employment Permits Update: 2026 Salary Threshold Changes for Graduate Hiring

Immigration Manager Alice Heron examines Ireland’s updated employment permit salary thresholds taking effect in March 2026, including the reintroduction of graduate-specific Minimum Annual Remuneration bands and what these changes mean for employers planning graduate recruitment in 2026 and 2027.

Learn more

Fragomen news

Fragomen Announces 2026 Partner Class and Counsel ElevationsLearn more

Media mentions

Bloomberg Law: New H-1B Rule Pushes Employers to Rethink Workforce Options

Partner Jill Bloom explains how the new wage-based H-1B selection rule may influence hiring decisions and prompt employers to reassess workforce planning and explore alternative visa options.

Learn more

Media mentions

Business Insider: Immigration Lawyers Say the H-1B Chaos Is Forcing Tough Business Calls

Partner K. Edward Raleigh discusses how companies are rethinking their H-1B strategies amid evolving policies.

Learn more

Awards

Mitch Wexler Named 2025 Top 25 Immigration Attorney by EB5 Investors Magazine

Senior Counsel Mitch Wexler is recognized by EB5 Investors Magazine as a 2025 Top 25 award recipient, reflecting leadership and long-standing impact in the global investment immigration space.

Learn more

Blog post

US Green Card by Investment | EB-5 and Gold Card Options for Middle Eastern Investors

Partners Isha Atassi and Rahul Soni outline key considerations across the EB-5 Immigrant Investor Program and the US Gold Card, comparing eligibility, investment structures and risk factors for high-net-worth individuals from the Middle East seeking US permanent residence.

Learn more

Media mentions

Franceinfo: États-Unis : bientôt une inspection au peigne fin des réseaux sociaux avant d'entrer sur le territoire

Partner K. Edward Raleigh commented on proposed changes to US entry requirements.

Learn more

Video

The Schengen C Visa: What Non-EU Nationals Need to Know About 90/180-Day Travel

Business Immigration Consultant Marisa Gizzi from Fragomen explains everything about the Schengen C Visa: who needs it, how to apply and key travel tips to stay compliant in the Schengen Area. 

Learn more

Media mentions

Toronto Star: Canada Wants to Bring in 1,000 Researchers and Skilled Workers. Here’s What It Will Take

Partner Rick Lamanna discussed Canada’s $1B plan to attract global researchers.

Learn more

Blog post

Tier 1 Investor Visa Extension Deadline | February 2026 UK Update

Manager Alex Hood, Senior Associate Kimberley Ong and Immigration Paralegal Ataa Rajput explain the final extension and settlement deadlines for UK Tier 1 Investor visa holders and outline who can still qualify and why early action is essential.

Learn more

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
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • 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.