The situation
The Spanish Large Companies Unit now checks whether foreign workers applying for Intracompany (ICT) Permits receive employment conditions and salary packages in line with collective bargaining agreements, local labor laws and local workers in similar job positions.
A closer look
- Salary check. The Large Companies Unit now checks whether each salary element meets the local standard. Foreign workers’ home base salary, salary on assignment and benefits and/or allowances both in money and in kind amounts are all separately reviewed. Previously, the salary package was reviewed as a whole, counting all amounts together.
- Process. The Large Companies Unit will primarily review information on employment conditions and the compensation package stated in the home employment contract and assignment letter.
Impact
Both home employers and host sponsoring companies may be required to include more supporting information in their ICT Permit applications than they had previously provided and may need to reorganize foreign workers’ compensation packages to meet local requirements, if the package did not already comply. Specifically, companies must clearly list individual elements of the compensation package in employment contracts and assignment letters.
Background
Spanish authorities have increased their scrutiny of EU ICT Permit and national ICT Permit applications on several points in recent months, including higher salary thresholds and seniority and work experience.
The salaries listed in collective bargaining agreements are generally not high when compared with market salary rates for expert job roles. Authorities are more concerned with guaranteeing similar employment conditions for foreign and local workers in similar roles.
Looking ahead
Fragomen expects Spanish authorities to continue their strict approach to professional immigration.
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].
Explore more at Fragomen
Blog post
Partner Jack Kim discusses how Canada’s increasingly selective and complex immigration system is affecting talent access, retention and long-term workforce planning for employers.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit explores what the recommendations mean, what’s still uncertain and what employers should be watching next
Blog post
In this blog, Senior Manager Katharina Vorländer explains when employers need an A1 certificate for employees traveling or working temporarily within Europe, the application process and how timely planning can help manage social security compliance risks.
Awards
Fragomen and UK team members are ranked in the “Immigration: High Net Worth Individuals – UK-wide” category of the Chambers High Net Worth 2026 Guide.
Blog post
In this blog, Director Ana Bessa Santos explores what Swiss authorities expect from employers when assessing work permit applications—including why a well-developed business plan, realistic growth projections and evidence of a genuine operational presence are critical to supporting both initial applications and future permit renewals.
Media mentions
Partner Louise Haycock discussed the Migration Advisory Committee’s Temporary Shortage List recommendations and the need for clear workforce plans and transitional arrangements.
Media mentions
Media mentions
Senior Manager Katharina Vorländer explains how employers and clients can reduce legal risks during cross-border employee assignments in Germany.
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
Blog post
Partner Jack Kim discusses how Canada’s increasingly selective and complex immigration system is affecting talent access, retention and long-term workforce planning for employers.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit explores what the recommendations mean, what’s still uncertain and what employers should be watching next
Blog post
In this blog, Senior Manager Katharina Vorländer explains when employers need an A1 certificate for employees traveling or working temporarily within Europe, the application process and how timely planning can help manage social security compliance risks.
Awards
Fragomen and UK team members are ranked in the “Immigration: High Net Worth Individuals – UK-wide” category of the Chambers High Net Worth 2026 Guide.
Blog post
In this blog, Director Ana Bessa Santos explores what Swiss authorities expect from employers when assessing work permit applications—including why a well-developed business plan, realistic growth projections and evidence of a genuine operational presence are critical to supporting both initial applications and future permit renewals.
Media mentions
Partner Louise Haycock discussed the Migration Advisory Committee’s Temporary Shortage List recommendations and the need for clear workforce plans and transitional arrangements.
Media mentions
Media mentions
Senior Manager Katharina Vorländer explains how employers and clients can reduce legal risks during cross-border employee assignments in Germany.
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
