by Ángel Bello Cortés, Partner, Fragomen LLP, Dublin office
Two major updates impacting Ireland’s employment-based immigration system have been released recently by the Department of Enterprise, Tourism and Employment (DETE), and Immigration Service Delivery (ISD), an arm of the Department of Justice, Home Affairs and Migration. Both updates were issued in close succession.
These are highly significant developments for employers. This article analyses the key changes introduced by these updates and offers practical recommendations.
DETE: Changes to Minimum Annual Remuneration (MAR) thresholds in respect of Employment Permit (EP) holders:
Effective date:
The changes will come into effect on 1st March 2026, assuming Regulations are passed prior to that date.
The changes:
The Department of Enterprise, Tourism and Employment (DETE) has confirmed increases to Minimum Annual Remuneration (MAR) Thresholds for Employment Permits and published a Roadmap setting out further phased increases to the remuneration thresholds for all Employment Permit categories.
Effective 1st March 2026, the increases of MAR for initial and renewal permit applications (where applicable) are as follows:
- Critical Skills Employment Permit (CSEP) with a relevant degree: EUR 40,904 (up from EUR 38,000)
- CSEP without a relevant degree: EUR 68,911 (up from EUR 64,000)
- Intra-Company Transfer (ICT) Permits: EUR 49,523 (up from EUR 46,000)
- Standard General Employment Permit (GEP): EUR 36,605 (up from EUR 34,000)
- GEPs for certain sectors (e.g., meat processors, horticultural workers, healthcare assistants, home carers): EUR 32,691 (up from EUR 30,000)
- Recent third level graduates (Irish institutions) for GEPs: EUR 34,009 (new category)
- Recent third level graduates (generally) for CSEPs: EUR 36,848 (new category)
- Exemptions: Certain roles subject to the public service pay agreement are exempt from these increases and will be subject instead to the public service pay agreement pay scales. This will also apply to community and voluntary organizations whose pay scales are linked to the public sector pay deal.
It is important to note that the roadmap envisages further phased increases through to 2030, and the intention is for the lower MAR in respect of certain sectors (meat processors, horticultural workers, healthcare assistants, home carers) to ultimately align with the standard MAR for General Employment Permits by 2030.
Further, all these figures are based on a 39-hour week. For longer weeks, the figures will need to increase proportionally. For shorter working weeks, the minimum MAR that applies to 39-hour weeks will still need to be met.
A welcome aspect of these reforms is the reintroduction of a lower MAR for recent graduates from any recognised third-level institution applying for CSEPs, a route that had been removed in 2023. In addition, a new reduced MAR has been introduced for graduates of Irish third-level institutions applying for GEPs. These changes reflect strong and sustained advocacy from employers and higher-education institutions, recognising that graduates are typically at the early stage of their professional careers and that entry-level roles often come with lower salary levels.
Background:
The MAR thresholds had remained largely unchanged for many years prior to 2023, which arguably led to a growing misalignment with average earnings nationwide. In December 2023, the DETE triggered the first set of MAR increases in quite some time, effective in January 2024, with additional increases set for 2025 and 2026. Following this announcement and the January 2024 MAR increases (introduced with very limited notice in late December 2023, as many will remember!), the next planned increases for 2025 were paused to allow for review of the government’s roadmap and its impact on users of the Employment Permits system.
In September 2024 the Employment Permits Act 2024 was enacted, introducing a statutory requirement for the Minister to conduct an annual review of the Minimum Annual Remuneration (MAR) thresholds. Under the Act, MAR levels must be increased where average weekly earnings in Ireland, as published by the Central Statistics Office (CSO), have risen. A public consultation was subsequently launched in January 2025, inviting submissions from industry and other stakeholders on the proposed MAR roadmap. More than 150 submissions were received.
The MAR increases taking effect on 1st March 2026 represent the first formal MAR review conducted under the new statutory obligation introduced by the 2024 Act, incorporating the feedback submitted during the January 2025 consultation on the MAR roadmap. Going forward, comparable reviews, and likely further increases (unless the CSO data indicates otherwise), will now occur on an annual basis.
Recommendations:
Employers should urgently review the remuneration packages of all existing staff holding General Employment Permits and ICT Employment Permits, as the new thresholds may affect the ability to renew these permits. Budgeting and compensation planning may need to be reassessed more holistically.
For new hires, employers sponsoring third-country nationals for roles that previously sat close to the MAR threshold should assess whether the revised MAR can be met, noting that this may present challenges for lower-paid positions.
As outlined above, MAR reviews will now take place annually, with further increases likely unless CSO data indicates otherwise. Internal compliance frameworks and workforce planning strategies should be updated to reflect these ongoing changes and the broader roadmap through 2030. Employers should closely monitor future MAR adjustments and incorporate these into long-term workforce planning.
ISD/Department of Justice, Home Affairs and Migration: Changes to Family Reunification Policy:
Family Reunification rules govern the ability of a foreign national to sponsor eligible family members to join them in Ireland. The rules around this area are dictated by the Department of Justice, Home Affairs and Migration, and in particular Immigration Service Delivery (ISD).
Effective date:
The new family reunification rules came into effect on the 26th November 2025.
The changes:
Multiple changes on family reunification rules have taken place, including tougher financial thresholds for certain sponsors, much stricter eligibility thresholds for dependent adult children, and new accommodation requirements.
- General Employment Permit(GEP) holder sponsors: they must now demonstrate a net pay of EUR 36,660 per year to sponsor a single child. This figure will increase with each subsequent child. Other changes include revisions to the rules on necessary supporting financial documents. In practical terms, this means that a GEP holder just above the 2026 MAR threshold (EUR 36,605 gross) will not meet the financial criteria required to sponsor their children to join them in Ireland. The existing requirement for the GEP holder to have completed 12 months of residence in Ireland before submitting a dependent application also remains in place.
- Critical Skills Employment Permit (CSEP) and Intra-Company Transfer (ICT) sponsors: No financial thresholds will apply to these categories for the purposes of sponsoring nuclear family members to join them in Ireland (unchanged). The policy confirms that these sponsors “fall into a category whose migration to Ireland is promoted as part of Government policy.” These sponsors however must continue to meet the terms of their permission in order to maintain their own and their family’s entitlement to reside here and evidence of this must be provided by the sponsor at the time of the renewal of permission.
- More restrictive rules for dependent adult children: Dependent adult children (18+) seeking to immediately join their sponsor in Ireland on the grounds of family reunification must now establish they are wholly dependent on the care of their parent or parents in Ireland due to a serious medical or psychological condition that makes independent life unsustainable. In addition, sponsor’s minimum annual gross salary requirements (which also apply to other adult dependents, e.g., elderly parents) have been introduced. Previously, dependent children in full time education could potentially join their family in Ireland up to age 23 and no medical/psychological dependency was required. Under the new rules, adult dependent children may not be able to join immediately as dependents, and very high sponsor salary thresholds must be met. Some families might need to consider independent alternative immigration pathways in Ireland for their adult children, such as student permissions.
- Suitable accommodation requirement: Family reunification sponsors must now demonstrate that suitable accommodation is available for dependent family members, although details of what is considered suitable have not yet been announced. Previously this was only required for dependent elderly relatives.
- Work rights for over 16 dependents: Dependent children of certain permit holders are now granted work rights upon reaching 16 years of age without the need to obtain a separate Employment Permit. This welcome development, which sees affected individuals being registered on a Stamp 1G permission (with a right to work) as opposed to a Stamp 3 permission, only applies where the child is a dependent of a Critical Skills Employment Permit, General Employment Permit, ICT Permit holder, or a Researcher on a Hosting Agreement.
Analysis and recommendations:
The Department has noted that these family reunification reforms aim to align Ireland’s migration policies with other EU Member States, with a view to potentially adopting the EU’s Family Reunification Directive at a later stage. A key driver of these changes appears to be the government’s concern that sponsors might bring family members to Ireland and ultimately these dependents might need to rely on State support. This rationale is somewhat unexpected, given that the permissions typically given to dependents of Employment Permit holders do not in practice give an immediate entitlement to social welfare payments.
CSEP and ICT holders remain largely unaffected by these changes except in relation to the treatment of adult children. In contrast, GEP holders, who for quite some time have advocated for a relaxation of the family reunification policy, will continue to face significant challenges in bringing their nuclear family members to Ireland. This might hinder employers’ ability to attract international talent into roles that do not qualify for CSEP permits. The sectors most likely to feel this impact are private healthcare (including healthcare assistants and home carers), construction (particularly tradespeople), and certain technician roles in the IT sector. Given the limited availability of EEA labour for these roles, clearly evidenced by the volume of GEPs granted, these changes may create additional recruitment pressures in sectors already experiencing workforce shortages. How this aligns with Ireland’s broader, and ambitious, healthcare, infrastructure and housing targets remains to be seen.
The policy confirms that CSEP and ICT sponsors “fall into a category whose migration to Ireland is promoted as part of Government policy.” The natural corollary is that the migration of individuals who qualify only for GEPs might not be necessarily promoted as part of Government policy – an inference that can be reasonably drawn in light of this new family reunification policy. This results in a clear policy misalignment: while the policy distinguishes CSEP and ICT holders as categories whose migration is (rightly) actively promoted, the GEP framework itself also exists precisely because the State, when granting a GEP, has accepted that no suitably qualified EEA candidate is available for that role. These differing policy signals might create uncertainty for employers.
Future calls for submissions on occupations to be added to the Critical Skills List should be treated as a priority by employers experiencing recruitment or retention challenges in “GEP only”- eligible roles stemming from these recent family reunification changes. That said, any expansion of the Critical Skills List to include such roles may have limited impact unless the existing “degree requirement” is reviewed, as this continues to exclude many skilled occupations in sectors where formal academic qualifications are not the norm, such as skilled trades.
About the author
Ángel Bello Cortés is a Partner in the Fragomen LLP Dublin office and oversees a large team of immigration professionals which assists a diverse client base comprised of multinational corporations, local and global SMEs, start-ups and private clients.
Ángel has 20 years of professional experience in Irish immigration and citizenship matters. He is admitted as a Solicitor in Ireland and uses his deep understanding of the Irish immigration system to provide strategic advice to companies in the establishment, maintenance and enhancement of their Irish operations from an immigration perspective. This has included crisis management and planning during Brexit, COVID-19 and the Ukraine crisis. He has also provided advice to international organizations and State bodies.
Ángel and his team help clients solve both routine and complex, broader challenges. Ángel and his team pride themselves on being able to serve as an extension of the clients’ in-house global mobility, immigration and HR teams.
