by Ángel Bello Cortés, Partner, Fragomen LLP, Dublin office
Ireland’s employment-based immigration system, established in 2003, has evolved considerably over the past 22 years to become an internationally respected framework. Today, both global and local companies rely on it to address ongoing skill shortages across industries.
The system has now become much more sophisticated, given that the global landscape in which it operates has also grown increasingly complex. As a result, immigration compliance and meaningful, strategic engagement with the system are now essential for Irish employers.
2025 Open consultation on review of the occupations lists for Employment Permits
The Department of Enterprise, Tourism and Employment (DETE) continues to regularly assess the Irish labour market to determine where further interventions are needed, particularly through the Employment Permits system.
In this context, DETE has launched its 2025 consultation process, inviting submissions from stakeholders on potential updates to the Critical Skills Occupations List and the Ineligible Occupations List. This is the first consultation of its kind since 2023. The consultation also seeks submissions on occupations currently subject to quotas and whether those quotas should be adjusted or removed.
The Critical Skills List identifies professions in short supply in Ireland, while the Ineligible List covers occupations not eligible for permits, usually because they are considered fillable by EEA, Swiss or UK nationals.
Employers currently facing skills shortages, and not yet engaging with the permits system, should consider whether international recruitment might offer a solution. More broadly, all employers are encouraged to contribute. This is a key opportunity to shape how government policy reflects real labour market needs.
Full consultation details are available at enterprise.gov.ie, with a submission deadline of 19 September 2025.
Critical Skills (CSEP) vs General Employment Permit (GEP)
Many employers are likely to advocate for additional roles to be added to the Critical Skills List. Where a listed role requires a relevant degree, a Critical Skills Employment Permit (CSEP) can be issued. For unlisted roles, a CSEP can still be secured if the salary is at least €64,000 and the role is not on the Ineligible List. A minimum two-year contract is required.
The CSEP is particularly attractive. It enables immediate family reunification and provides access to Stamp 4 status after just two years. Stamp 4 allows the permit holder to work without employer sponsorship, move freely between roles and employers, and is typically viewed more favourably by banks and mortgage lenders. This makes the CSEP a vital tool for attracting and retaining skilled international talent.
In contrast, the General Employment Permit (GEP) offers fewer benefits. Dependants must wait at least 12 months to join the primary permit holder in Ireland, and the path to Stamp 4 typically takes five years.
Some companies may also seek the removal of roles from the Ineligible List. In recent years, a number of occupations, particularly in the construction and transport sectors, have been reclassified to GEP-eligible. Some employers might argue however, that limiting these roles to GEP eligibility can act as a barrier to attracting the right candidates, given the competitive international recruitment market and the lesser benefits of that permit type.
Past consultation on remuneration thresholds for Employment permits
In January 2025, DETE launched a separate consultation (now closed) on minimum remuneration thresholds for Employment Permits, and the outcome is still awaited. Under current legislation, the Minister for Enterprise is required to review these salary thresholds annually, taking into account the latest data on average weekly earnings published by the Central Statistics Office. Employers should be mindful that updated thresholds could be introduced in the coming months, and plan accordingly. Unfortunately, no timeline has yet been provided for when the results of this consultation will be released.
Navigating the system and ensuring compliance
Like many other employment-based immigration frameworks elsewhere, the Irish system has naturally become more complex over time as the world, and our ways of working, continue to evolve. Securing an Employment Permit is only the first step. Depending on nationality, an entry visa might also be required (handled by the Department of Justice rather than DETE).
Once in Ireland further obligations apply, such as registering with immigration authorities and obtaining an IRP card, and notifying Departments of any changes to role, salary, work location, or even home address.
Tracking expiry dates is also critical. Missing a renewal deadline or applying to renew too close to the expiry date could result in the loss of the right to work, exposing the employer to a compliance breach and disrupting operations.
This complexity is, perhaps unexpectedly, further compounded by growing digitisation. Most immigration processes are now conducted through government portals, requiring careful coordination between employer, employee and immigration agent (if present). Chatbots and automated responses have also arrived. Further, certain government functions have also been outsourced to private service providers, such as the collection of visa application documents on behalf of Irish consulates in specific countries. While these systems, technology and structures aim to streamline processes, technical issues and other new challenges arise, adding to the demands placed on HR and TA teams. This shift has brought some efficiencies, but it has also introduced new technical and procedural hurdles.
The case for reassessing how immigration is managed in the business
Many HR and TA teams (and on occasion, hiring managers) still manage Irish immigration matters internally and often do so with a high degree of competence. However, the increasing complexity and nuances of the system mean that even experienced teams may face challenges, including unexpected delays, refusals, sudden changes of government policy, missed deadlines, right-to-work breaches or other compliance issues. In the best-case scenario, this disrupts operations. In the worst case, it also creates legal and reputational risks.
Given that immigration has become an increasingly important part of Ireland’s workforce planning, now is an appropriate time for employers to reexamine whether their current approach still serves business needs effectively. This might involve:
• Strengthening internal resources with additional capacity and expertise and/or
• Partnering with external specialists so that internal teams can focus on strategic priorities, while ensuring that immigration is handled with the expertise and attention it requires.
Whichever path is taken, the key is ensuring that immigration processes are managed in a way that reduces risk and minimises disruption to the business. With growing regulatory and operational complexity, leaving internal teams to navigate the system without sufficient support might no longer be sustainable in many cases.
Conclusion
Ireland’s employment-based immigration system offers a powerful mechanism to address skills shortages. But to benefit from it, employers must move beyond passive engagement and embrace a strategic, compliant, and proactive approach. Whether through participation in the 2025 consultation process or re-evaluating internal immigration processes, now is the time for Irish employers to lead in shaping the workforce of tomorrow.
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.
