Employers facing new insurance documentation requirement

IMPACT – MEDIUM

What is the change? The Swedish Migration Agency has begun requiring copies of insurance certificates going back six to seven years as part of the work permit extension process.

What does the change mean? Employers submitting work permit extension applications or fresh work permit applications for employees who previously worked in Sweden must include copies of insurance certificates to establish that employees had health, life and occupational accident insurance at all times when working in Sweden.

• Implementation time frame: Immediate and ongoing.
• Visas/permits affected: Work permits.
• Who is affected: Employers submitting applications for work permit extensions or new work permits if the employee has worked in Sweden in the past.
• Impact on processing times: The change and other new documentation requirements have led to delays in the work permit extension process.
• Business impact: The insurance requirement will create additional work for applicants, who now have to provide copies of insurance certificates going back six to seven years.

Background: The change is the result of a 2015 court decision. Under the ruling, Swedish authorities applications must be satisfied that employees seeking work permit extensions received proper pay and insurance coverage for every month they were employed in Sweden on their initial work permit. The same is true for employees seeking a fresh work permit if the employee has worked in Sweden in the past. Until recently, authorities accepted a letter from an employer stating that the employee had insurance as sufficient evidence of past insurance coverage. Beginning June 2, however, the Migration Agency began requiring copies of insurance certificates, creating more work for employers filing work permit extension applications.

BAL Analysis: The most recent change and other new requirements have created delays in the work permit renewal process, as employers now have more work to do when filing applications and authorities have more to check when processing them. Applicants should prepare for longer processing times and be prepared to supply additional documentation. Businesses may need to adjust start dates or timelines to account for the increased processing times.

This alert has been provided by the BAL Global Practice group and our network provider located in Sweden. For additional information, please contact your BAL attorney.

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