IMPACT – HIGH

Ireland has adopted new COVID-19 travel and immigration policies, including a new exemption to quarantine rules.

  • Under a Statutory Instrument that took effect Feb. 3, the government has exempted a limited number of essential workers from Ireland’s mandatory 14-day quarantine.
  • The Statutory Instrument also mandates that travel advisors take appropriate action to notify travelers of Ireland’s travel rules.
  • The Department of Enterprise, Trade and Employment (DETE) has adopted new measures for employment permit applicants from visa-required countries.

Exemptions to 14-day quarantine. Ireland requires most arrivals from abroad to quarantine for 14 days at the address listed on their Passenger Locator Form. The Feb. 3 statutory instrument provides exemptions to the 14-day quarantine for individuals traveling to Ireland to carry out essential repair, maintenance, construction or safety assurance of:

  • Critical transport infrastructure.
  • Critical utility infrastructure.
  • Manufacturing services.
  • Information services.
  • Communications services.

The exemption is not available to travelers from “Category 2” countries. Category 2 countries currently include: Angola, Austria, Botswana, Brazil, Burundi, Cape Verde, Democratic Republic of the Congo, Eswatini (Swaziland), Lesotho, Malawi, Mauritius, Mozambique, Namibia, Rwanda, Seychelles, Republic of South Africa, Tanzania, United Arab Emirates, Zambia, and Zimbabwe. All other countries are in Category 1.

Obligations on travel organizers. The Statutory Instrument states that any company or facilitator of travel into Ireland must take appropriate action to notify travelers of applicable COVID-19 travel restrictions. It places an obligation on travel organizers to refuse to organize, effect or facilitate the travel of individuals to Ireland if they have not satisfactorily met all requirements.

Employment permit applicants from visa-required countries. The DETE continues to process applications for employment permits. However, given current restrictions, it may not be possible for individuals from visa-required countries to travel to Ireland, unless the individual qualifies for entry under priority/emergency situations.

As such, the DETE has begun a process of contacting all employment permit applicants (employers and employees) who hold passports from visa-required countries. These applicants will be asked if they would like to:

  • Proceed with the employment permit application because the role is on the priority/emergency list;
  • Hold their application in the queue for processing at a later date, once the temporary COVID-19 arrangements have been rescinded; or
  • Withdraw the application with a full refund.

Employment permit applicants from visa-free countries. Employment permit applications for nationals from countries that do not require a visa will continue to be processed.

Travelers are encouraged to review the current policies before traveling to Ireland. Employers should note that if an employee is not subject to the exemption described above, they may need to quarantine for 14 days upon arrival.

Analysis & Comments: The Irish government continues to take steps to mitigate the spread of new variants of the COVID-19 virus. Employers should consider that this might cause delays to intended start dates of their potential employees, if the employment cannot be carried out from home. The response to COVID-19 continues to develop, and Deloitte will provide additional updates as information becomes available. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

The Department of Justice and Equality has announced that it will temporarily cease accepting new visa and preclearance applications. These measures are designed to support COVID-19 restrictions on movement, including into and out of Ireland.

Key Points:

  • The change came into effect from close of business on Jan. 29. The situation will remain under review in the coming weeks.
  • The temporary measures mean that visa applicants will not be able to complete their entry visa application process. Any application made online will remain valid until such time as restrictions are lifted.
  • Everyone, regardless of their nationality or visa/preclearance status, or where they started from, who cannot provide proof of an essential purpose to travel to or within Ireland, is strongly advised not to travel to Ireland at this time.
  • Individuals who do travel to Ireland should ensure that they hold a negative/“not detected” PCR COVID-19 test result. The test must be taken no more than 72 hours before arrival to Ireland; travelers must also adhere to the relevant self-isolation period. Anyone who fails to do so is liable for fines and criminal sanctions.

Priority/emergency cases will continue to be processed. These include the following:

  • Workers or self-employed persons exercising critical occupations including healthcare workers, frontier and posted workers as well as seasonal workers as referred to in the guidelines concerning the exercise of the free movement of workers during the COVID-19 outbreak.
  • Transport workers or transport service providers, including drivers of freight vehicles carrying goods for use in Ireland.
  • Patients traveling for imperative medical reasons.
  • Pupils, students and trainees who travel abroad on a daily basis and third-country nationals traveling for the purpose of 3rd level study.
  • Persons traveling for imperative family or business reasons.
  • Diplomats, staff of international organizations and people invited by international organizations whose physical presence is required for the well-functioning of these organizations, military personnel and police officers, and humanitarian aid workers and civil protection personnel in the exercise of their functions.
  • Passengers in transit.
  • Seafarers.
  • Journalists, when performing their duties.

If an application falls into one of the above categories, the applicant can apply online in the usual way. Once the online application is completed, individuals should follow the instructions given on the summary page as to where they should submit applications.

As of midnight on Jan. 27, in addition to countries that were visa-required prior to that date, passport holders of the following countries are now also required to apply for an entry visa or transit visa, as appropriate, before traveling to Ireland:

  • Argentina.
  • Bolivia.
  • Brazil.
  • Chile.
  • Colombia (transit visa now required – already subject to entry visa requirements).
  • Ecuador (transit visa now required – already subject to entry visa requirements).
  • Guyana.
  • Paraguay.
  • Peru (transit visa now required – already subject to entry visa requirements).
  • South Africa.
  • Suriname (transit visa now required – already subject to entry visa requirements).
  • Uruguay.

Analysis & Comments: The Irish government has made this decision as part of their efforts to mitigate the spread of the new variant of COVID-19. Employers should consider that this may cause delays to intended start dates of their potential employees, if the employment cannot be carried out from home. If you have employees or potential new hires who may be impacted by these changes, please contact the Deloitte immigration team to assist.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

Under a change that took effect Jan. 16, all passengers arriving into Ireland are required to have a negative/“not detected” result from a pre-departure COVID-19 PCR test carried out no more than 72 hours before arrival in Ireland.

Arrivals from Great Britain and South Africa will continue to require a negative/“not detected” result from a pre-departure COVID-19 PCR test and must continue to isolate for 14 days in Ireland, even if they take a second test after arrival.

Key Points:

  • The change took effect on Saturday, Jan. 16. The policy for travelers entering Ireland from Great Britain and South Africa has been in effect since Jan. 9.
  • The requirements apply to all travelers arriving in Ireland, regardless of nationality.
  • Passengers may be asked to present evidence of their negative/“not detected” result before boarding their airplane or ferry, and will be required to produce this evidence to Immigration officers on arrival at points of entry to Ireland.
  • Passengers who arrive in an Irish airport or sea port without evidence of a negative/“not detected” COVID-19 PCR test result will have committed an offense and may be subject to prosecution, punishable by a fine not exceeding €2,500, imprisonment for a term not exceeding six months, or both.
  • All travelers coming from a red or grey list country, as defined by the EU traffic light system, and all other locations outside of Europe, must continue to restrict their movements for 14 days after arriving in Ireland.
  • All travelers coming from a green or orange country  will not be required to restrict their movements on arrival but must adhere to the local public health guidance.
  • Travelers from Great Britain and South Africa must continue to isolate for 14 days, even if they take a second test after arrival.
  • Exemptions are limited to international transport workers, including hauliers, pilots and aviation crew, masters and maritime crew, and members of An Garda Síochána in the course of their duties.
  • Children under six will also be exempt.
  • Passengers who arrive in Ireland solely for the purpose of travelling onward to another country and who do not leave the airport are also not required to provide evidence of a test.
  • If a citizen has a genuine humanitarian emergency requiring urgent travel, they should contact the nearest Embassy or Consulate immediately for advice and consular assistance before commencing their journey.

Analysis & Comments: The Irish government has made this decision as part of their efforts to mitigate the spread of the new variant of COVID-19. Employers should consider that this change may cause delays to intended start dates of their potential employees, if the employment cannot be carried out from home. All travelers arriving to Ireland must also continue to complete a Passenger Locator Form prior to arriving at port of entry in Ireland. If you have employees or potential new hires who may be impacted by the changes described, please contact the Deloitte immigration team to assist.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Ireland has implemented new residence processes for non-EEA family members of U.K. nationals following the end of the Brexit transition period on Dec. 31, 2020.

What does the change mean? Before the end of the Brexit transition period, eligible non-EEA family members of U.K. nationals could avail themselves of EU Treaty Rights in Ireland. That is no longer an option with the end of the Brexit transition period. U.K. nationals can sponsor their family member to live in Ireland, however. Depending on the nationality of the non-EEA family member, they will be required to apply through either the preclearance or visa scheme before entering Ireland.

  • Implementation time frame: The change that took effect at 11 p.m. on Dec. 31 is permanent.
  • Visas/permits affected: Residence permits holders who are non-EEA family members of U.K. nationals.
  • Who is affected: The change affects non-EEA family members of U.K. nationals who come to live in Ireland after Dec. 31, 2020. It does not affect non-EEA family members of U.K. nationals who were living in Ireland before Dec. 31, 2020. These individuals will most likely be considered a beneficiary under the EU-U.K. Withdrawal Agreement. More information is available here.
  • Next steps: U.K. nationals and their non-EEA family members, should check whether they meet the eligibility criteria if they wish to enter Ireland and reside there. If the non-EEA family member is a visa-required national, then they will need to apply for a Join Family Entry Visa outside of Ireland. If successful, they will receive an Irish Entry Visa Endorsement in their passport. If the non-EEA family member is not a visa-required national, then they will need to apply through the preclearance scheme, outside of Ireland. If successful, they will receive a preclearance approval letter. A list of countries that require a visa to enter Ireland can be found here.

Background: Before the end of the Brexit transition period, eligible non-EEA family members of U.K. nationals could receive “Stamp 4 EU Fam” permission to reside in Ireland under EU Treaty Rights. The U.K.’s Brexit transition period ended on Dec. 31, 2020, meaning non-EEA family members of U.K. nationals will no longer be able to avail themselves of EU Treaty rights. However, U.K. nationals will be able to act as a sponsor for their non-EEA family members should the family members wish to live in Ireland and meet the eligible criteria.

Non-EEA family members of U.K. nationals may be eligible to avail of this scheme if they are:

  • A non-EEA, non-Swiss national.
  • Being sponsored by an eligible U.K. national.
  • Ordinarily resident outside of Ireland.
  • Of good character and good standing.
  • In a position to show documentary evidence of their relationship to the U.K. national.
  • Intend to live together permanently with your U.K. family member in Ireland.
  • Have medical insurance from a company authorized by the Health Insurance Authority of Ireland.
  • Fall into one of the following categories:
    • Category One: Spouse, civil partner or de facto partner of the U.K. national.
    • Category Two: A dependent child of the U.K. national, or a dependent child of the U.K. national’s non-EEA spouse, civil partner or de facto partner.
    • Category Three: A dependent parent (aged 66 or older) of the U.K. national or a dependent parent of the U.K. national’s non-EEA spouse, civil partner, or de facto partner.

Both the applications for a Join Family Entry Visa and the preclearance scheme can be made online on the AVATS application system. Following the submission of the online form, applicants will need to file their full applications and supporting documents in line with local Irish Embassy policy. Non-EEA family members of U.K. nationals should not enter Ireland until they have been granted their entry visa or preclearance approval letter.

Analysis & Comments: Deloitte welcomes this update on the immigration process for non-EEA family members of U.K. nationals. Individuals should note that eligibility to apply to the above does not mean that it is automatically assumed that the non-EEA national’s application will be granted under the scheme. If a non-EEA family member of a U.K. national wishes to enter Ireland as a visitor, then the above does not apply. If you have employees or potential new hires who may be impacted by the above changes, please contact the Deloitte immigration team to assist.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? The Irish government has announced that foreign nationals with valid immigration permission that expires between Jan. 21, 2021, and  April 20, 2021, will be granted an automatic extension until April 20, 2021. Officials also closed the Burgh Quay Registration Office on Dec. 24 until further notice.

  • Implementation time frame: This change is set to take effect immediately. No further extensions are anticipated after April 20, 2021. The Burgh Quay Registration Office will remain closed until further notice.
  • Who is affected: All foreign nationals residing in Ireland with valid immigration residency permission (based on employment, studies, dependant family, tourism, etc.) that is due to expire between Jan.21 and April 20.
  • Next steps: Employers should update employees with upcoming Irish Residence Permit expiries. Any individuals who have First Time Registration appointments scheduled at the Burgh Quay Registration Office on or after Dec. 24, 2020, should not attend their appointment. If the appointment falls during the office closures, then it will be prioritized for re-scheduling once the office re-opens. Individuals located in Dublin who need to renew their IRP permission can still do so using the online renewal platform. These applications will continue to be accepted during the closures.

Additional Information: The Irish government has made this decision in line with recent restrictions as part of its response to COVID-19.

In Ireland, all non-EEA nationals must apply for an employment permit to work. For certain nationalities, individuals must then apply for an entry visa to enter Ireland to commence work. Once in Ireland, all non-EEA nationals must apply for an Irish Residence Permit to register their permission and reside. This Irish Residence Permit must be renewed in Ireland when appropriate by the non-EEA national.

This automatic extension comes after the previous five extensions that were implemented last year on March 20, May 13, July 16, Aug. 20 and Sept. 18. Any permission that was renewed by these previous notices and now has a new expiry date between Jan. 21 and April 20, 2021, is automatically renewed by this notice until April 20.

Analysis & Comments: This measure has been introduced to allow foreign nationals additional time to renew their permissions prior to April 20, 2021. This ensures that employees retain their permission under the same conditions during this time. It is important to note that foreign nationals will not receive an updated permission as part of this announcement. If they wish to travel before renewing their residency permission, we would advise contacting our Deloitte immigration team in advance of departing Ireland.

All renewals in the Dublin area are now being processed online only. This system has been available since July 20, 2020. Such applications will continue to be accepted during these closures.

If you have employees or potential new hires who may be impacted by the above changes, please contact the Deloitte immigration team to assist. We continue to update our FAQ for employers, available here.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2021. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change?
Ireland’s Department of Enterprise, Trade and Employment (DETE) has announced that all employment permits issued electronically since March will be printed and issued as hard copies.

What does the change mean?
Because of the COVID-19 pandemic, employment permits have been issued electronically since March. DETE will soon begin printing and mailing hard copy versions of these permits. The original, printed version of the employment permit will be addressed to the permit holder and sent to their employer or agent, who will then be asked to ensure that the employee receives the original permit. A certified copy of the permit will be printed and sent separately to the employer or agent.

  • Implementation time frame: Hard copies will be printed starting on Dec. 14.
  • Visas/permits affected: Employment permits issued electronically since March.
  • Who is affected: Individuals who have a valid employment permit issued since March 2020.
  • Impact on processing times: The DETE will begin to re-issue original, hard copy employment permits soon, but expects that it will take a few months to clear the existing backlog. 

Additional Information: The DETE will continue to issue electronic copies of employment permits for the foreseeable future; no change in this regard has occurred. The recent announcement was only to notify employees, employers and agents that DETE will soon begin to re-issue hard copies of employment permits. Employees and employers do not need to take further action at this stage.

Analysis & Comments:
Deloitte welcomes the reinstatement of the hard-copy permit issuance, because it will allow employees to hold their original, hard copy permits once again. Employers and employees should be sure to keep their original hard-copy documents safe and accessible at all times. DETE has provided a dedicated mailbox for employees and employers should they have any questions in relation to the printing system: EPPrintingqueries@enterprise.gov.ie. If you have employees or potential new hires who may be impacted by the changes above, please contact the Deloitte immigration team to assist.

We continue to update our FAQ for employers, available here.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

 

 

IMPACT – MEDIUM

What is the change? Ireland has adopted the European Union’s COVID-19 traffic lights system for determining entry policies for travelers from Europe.

What does the change mean? Under the system, regions in the EU/EEA and the United Kingdom are categorized as green, orange, red or gray based on their COVID-19 infection level and the availability of data. Individuals traveling to Ireland from green regions, or from Northern Ireland, are not required to restrict movement on arrival. All passenger arriving into Ireland from orange, red and gray regions are requested to restrict their movements for 14 days. This period of restricted movement can end for travelers who receive a negative/not detected result from a PCR test that has been taken a minimum of five days after arrival in Ireland.

  • Implementation time frame: The change took effect Nov. 29.
  • Who is affected: All individuals traveling into Ireland, including Irish citizens, who are arriving from EU/EEA countries or the United Kingdom.
  • Business impact: Employers may have to adjust time lines and start dates for employees traveling from orange, red or gray countries.
  • Next steps: All individuals traveling into Ireland should check the color category assigned to the country from which they are traveling. Travelers can check their country’s categorization by consulting the European Centre for Disease Prevention and Control’s combined indicator map.

Exemptions: The request that travelers restrict movement if traveling from orange, red or gray countries does not apply to:

  • International Transport Workers, including workers in aviation, maritime and road haulage sectors.
  • Travelers with an essential function or need as set out in paragraph 19 of the EU Council Recommendation, including:
    • Passengers traveling for the purposes of an imperative business reason, only while carrying out that essential function.
    • Passengers arriving for imperative family reasons, only while pursuing that imperative reason.
    • Returning passengers, who have carried out an essential function in another region, but who have otherwise restricted their movement while in that region.
  • Passengers arriving from an “orange” region who have received a negative/not detected result from a COVID-19 PCR test taken during the three days before departure to Ireland. Passengers are requested to have supporting evidence of the negative test in their possession.

It is the responsibility of individuals to determine whether their circumstances fall within one of the categories outlined in the EU Council Recommendation.

Analysis & Comments: The Irish government made the decision to adopt the traffic lights map as part of their efforts to mitigate the spread of COVID-19. All travelers arriving to Ireland must continue to complete a Passenger Locator Form prior to arriving at port of entry in Ireland. Employers should consider that the change in policies may cause delays to intended start dates of their potential employees if the employment cannot be carried out from home. If you have employees or potential new hires who may be impacted by the above changes, please contact the Deloitte immigration team to assist. Please check Deloitte’s COVID-19 Digital Map, available here, for information on travel restrictions and immigration changes in other countries.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change?
The Irish Naturalisation and Immigration Services (INIS) has announced that individuals renewing their Immigration Registration Permission (IRP cards) online will no longer need to submit their original passport to the office in order to obtain an immigration stamp from the Burgh Quay Registration Office.

  • Implementation time frame: The change took effect Dec. 2 and is permanent.
  • Visas/permits affected: Immigration Registration Permission (IRP cards).
  • Who is affected: All non-EEA nationals with valid IRP cards.
  • Next steps: Employers should alert their non-EEA national population of the update.

Additional Information:

  • For those living in the Dublin area: All individuals resident in Dublin who need to renew their IRP cards, should do so by using the online IRP renewal service. Additional information is available here. Individuals will need to complete the online application form. They will then receive their IRP card via post to their Irish residential address.
  • For those living outside the Dublin area: All individuals resident in Ireland outside of Dublin who need to renew their IRP cards still need to make an appointment to attend their local Registration Office to renew their permission. They will need to bring their passport to the appointment, but it will not be stamped. Once the application is processed, the Immigration Officer will advise on the receipt of the IRP card.

Analysis & Comments: Deloitte welcomes this change. Previously applicants were required to send their original passport to the department once they had completed the online renewal application. The abolishment of this requirement means that individuals can retain their passport during the renewal process, and continue to use it for other purposes. It also eliminates the reliance on postal services carrying original passports.

When applying for their online IRP renewal, individuals should note that they need to be present in Ireland. Applications cannot be filed whilst individuals are outside of Ireland. Passports will no longer be stamped to indicate the applicants’ permission in Ireland. This means that all non-EEA nationals should ensure to renew their permission in a timely manner prior to their IRP expiry, so as to ensure they do not encounter gaps in their permission.

Applicants should note that if they have been granted a new passport, they will need to attend an appointment in order to renew their IRP card. This applies to all non-EEA nationals living in Ireland. If you have employees or potential new hires who may be impacted by the above changes, please contact the Deloitte immigration team to assist.

Rest of World Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This includes Deloitte Tax LLP in the United States which does not provide legal and/or immigration advice or services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Brexit will come fully into effect on Jan. 1, 2021 when the U.K. leaves the EU after the end of the transition period.

What does the change mean? The Department of Justice has announced that nothing will change for U.K. nationals living in Ireland; they may continue to reside, work and travel in Ireland. Similarly, family members and dependents of U.K. Nationals who are living in Ireland with valid ‘Stamp 4 EU Fam’ permission, will retain their same residency rights. However, they will be required to exchange their current ‘Stamp 4 EU Fam’ Irish Residence Permit (IRP) Card for a new one that will state their residence rights derive from EU Free Movement under the Withdrawal Agreement.

  • Implementation time frame: This change is set to take effect from Jan. 1, 2021. Affected individuals will have until Dec. 31, 2021, to apply for their new IRP card.
  • Who is affected: All non-EEA nationals who are living in Ireland on the basis of their relationship with a U.K. national, and who therefore currently hold ‘Stamp 4 EU Fam’ permission on this basis. If an individual holds this permission, then their IRP card will note ‘Stamp 4 EUFam’ under type of permit. This will only apply to those who have held this permission since Dec. 31, 2020, or before.

Additional Information:

  • For non-EEA nationals living in Ireland: The card exchange program will apply from Jan. 1, 2021, and be administered by the Immigration Service of the Department of Justice for applications nationwide. Applications to exchange the IRP cards will be made through the online renewal system. The online application system will ask individuals to confirm that they have been exercising EU Treaty Rights to reside in the State on or before Dec. 31, 2020, and continue to do so. Individuals will be asked to submit their current valid Irish Residence Permit card. They will then be issued a new IRP card. The deadline to make an online application is Dec. 31, 2021.
  • For U.K. nationals living in Ireland: There will be no change for U.K. nationals who wish to live in Ireland after Dec. 31, 2020. Their rights under the Common Travel Area (CTA) will continue to be protected. For U.K. nationals residing in Ireland, there is no required action, and they will not need to hold any documentation. However, if a U.K national wants documentation, they may request it.
  • For U.K. nationals and their non-EEA family members coming to live in Ireland after Dec. 31, 2020: The IRP exchange scheme explained above, will not apply to those wishing to enter Ireland after Dec. 31, 2020. A new scheme will be introduced for U.K. nationals who come to Ireland after Dec. 31, 2020, and wish to bring their non-EEA family members. Details of this are yet to be confirmed.

Analysis & Comments: Deloitte welcomes this update on the position of non-EEA dependents and family members of U.K. nationals currently in Ireland. The update means that such individuals will retain their rights to live, work and study in Ireland.

Non-EEA dependents and family members of U.K. nationals, will still need to hold a valid, in-date IRP card in order to reside and travel in and out of Ireland. They will also need to exchange their current ‘Stamp 4 EU Fam IRP’ card by 31 December 2021. Employers should reach out to any employees who may be impacted by this change, and ensure that their permission is updates by this date.

The process for non-EEA dependents and family members of U.K. nationals who wish to enter Ireland post Brexit (after Dec. 31, 2020), has not yet been confirmed. Deloitte will assess this process once the details are released.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Preclearance applications now must be completed for anyone wishing to enter Ireland as a volunteer, minister of religion, de facto partner of a Critical Skills Employment Permit (CSEP) holder or a de facto partner of an Irish national.

What does the change mean? Previously, preclearance applications were to be manually completed on paper form and then submitted to the Preclearance Unit. The Department of Justice has announced that all preclearance application forms must now be completed on the online application systems “AVATS.” This means that the process is now a one-step online application process. For visa-reqduired nationals this streamlines the previous two-step process.

  • Implementation time frame: This change is to take effect immediately. However, applications submitted under the previous procedure will be considered until Dec. 31, 2020.
  • Who is affected: Any non-EEA nationals who require preclearance in order to enter Ireland, as listed above. This change will impact both non-visa required and visa required non-EEA nationals. You can find a list of visa-required nationals for Ireland here.

Additional Information:

  • Visa Required Nationals: Visa required nationals will now apply for an Entry Visa under the preclearance scheme online through the “AVATS” system. The application and relevant supporting documents will be sent to the relevant processing office. If approved, visa required nationals will receive an Irish Entry Visa. This means that visa required nationals no longer need to apply through a two procedure (previously a preclearance application was done prior to the entry visa application). Visa required nationals will no longer receive a letter of preclearance. They will just receive an Irish Entry Visa. The application must be made from outside of Ireland and applicants must remain outside the State while their application is being processed.
  • Non-Visa Required Nationals: Non-visa required nationals will need to apply for preclearance online through the “AVATS” system. The application and relevant supporting documents will be sent to the relevant processing office. As was the case previously, non-visa required nationals will receive a letter of preclearance, if their application is successful. This should then be presented to the immigration officer upon entering Ireland. For non-visa required nationals only the application format has changed and moved online. The rest of the process remains similar. The application must be made from outside of Ireland and applicants must remain outside the State while their application is being processed.

Analysis & Comments: Deloitte welcomes this change from a paper to an online application form, which should create a more streamlined application process, particularly for visa required nationals.

Visa required nationals previously had to apply separately for a preclearance approval letter, and once they had obtained this, they could then apply for their Irish Entry Visa. These two processes are now captured under one application process, and the need for a visa required national to hold a preclearance letter has been eliminated. This should result in a speedier and easier application process.

Both visa required and non-visa required nationals should complete the application process outside of Ireland. Even individuals who do not require a visa to enter Ireland should apply outside of the state and not travel to Ireland until they have their preclearance approval letter.

Once in Ireland, individuals will still need to register their permission and receive their Irish Residence Permit (IRP card), in line with standard procedure.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.