The global mobility landscape and upcoming changes

Immigration and mobility remains top of mind for many governments worldwide. The wider picture for global mobility specialists involves navigating the compliance landscape across jurisdictions and / or legal practice areas, set against a backdrop of growing geopolitical uncertainty, increasing cost pressures and evolving mobility models that increase the complexity of legal compliance.

In Ireland, a swathe of policy changes has altered the global mobility landscape. Employers moving talent to Ireland on short, medium or long term arrangements are presently getting to grips with these changes as they apply to the Irish market.

Matheson’s global mobility and immigration specialists across our employment, tax, regulatory, technology and international business groups have extensive experience in navigating the Irish immigration system and delivering business-focused solutions, making it the firm of choice for internationally-focused companies and financial institutions doing business in and from Ireland.

Changes to the minimum annual remuneration (“MAR”) thresholds

An updated roadmap to the gradual increase in the MAR thresholds was introduced by the Government in December 2025. Unlike the previous roadmap introduced in December 2023, these changes were well signposted. They were also less onerous than anticipated, with many MAR thresholds being less than contained in the December 2023 roadmap.

The first increase will take effect on 1 March 2026. Further increases are set to follow into the future with gradual changes through to 2030.

Key policy decisions include:

• a commitment to maintain the exemption from MAR thresholds for critical skill roles subject to the public sector pay deal;
• confirmation that sector specific lower MAR thresholds in respect of General Employment Permits in the healthcare and agri-food sectors will be phased out by 2030; and
• the introduction of a lower MAR threshold for recent non-EEA graduates from third-level institutions in Ireland.

The employers most impacted by these changes have for the most part already factored the impact of these measures into their business plans since the initial December 2023 announcement. Employers navigating this area for the first time should ensure that they have effective planning systems in place and that salaries, hiring budgets and renewals of existing permits are evaluated and considered well ahead of time. Tracking the dates for permit renewals of existing staff and assessing what increases will be required to pass the revised thresholds will help employers navigate these changes.

The following table displays the increases to MAR thresholds for specific employment permits:

 

Ongoing reform of the 50:50 Rule

The “50:50 rule” prevents an employment permit being obtained if it results in more than 50% of the employees in a company being non-EEA, United Kingdom or Swiss nationals. The purpose of rule is to ensure a balanced workforce, but the rule has been subject to scrutiny in sectors suffering from particular workforce shortages. Under the Employment Permits Act 2024 (“2024 Act”), some changes were introduced. Recent commentary indicates that additional reforms are anticipated:

• Changes have been implemented under the 2024 Act to support start-ups looking to establish in Ireland, such as confirming that the rule is not triggered on the first application. This means that future planning will be required by start-ups when seeking to build their employee base in Ireland to ensure continued compliance with the 50:50 rule.
• The Department of Enterprise, Tourism and Employment is conducting a review of the operation of the 50:50 rule in the healthcare sector, having regard to the current skills shortages in this sector.

Managing processing delays

Questions have been raised as to the impact of processing delays on the global mobility landscape. The delays that we have observed do not impact the fundamental characteristics that make Ireland attractive as a destination, but do require close monitoring and management.  New permits are being prioritised, with processing times for certain permits being less than two weeks, a significant improvement from the landscape a number of years ago.

Renewal applications are taking longer, at between 12 – 14 weeks. This can be mitigated by careful planning and monitoring of renewal application times, together with engagement with mobile talent at an early stage. The State has taken steps to mitigate those delays and potential travel disruption / work disruption / payroll difficulties, including the extending the period during which an employee is permitted to remain in the State on the existing conditions of their IRP card from 8 to 12 weeks.

Updates to the Family Reunification Policy

The Department of Justice, Home Affairs and Migration introduced a revised reunification policy in November 2025. This policy revision introduces stricter eligibility and financial requirements.

The global mobility programmes of many international employers are not anticipated to be dramatically affected by the changes, as reunification applications can still be made in respect of the “nuclear family”. However, some cohorts (e.g. dependent adult children over 18 but under 23 who are in full time education) will see their position change.

Certain administrative requirements are likely to have greater impact. For example, higher MAR thresholds are in place for sponsoring some relatives (e.g. €36,660 (net salary) for General Employment Permit holders to sponsor a minor child) and this may factor into the attractiveness of certain roles for international talent, and consequently recruitment and retention policies.

A strong understanding of the detail involved in the new policy will help those managing global mobility programmes manage their global people strategies.

Proposed changes in relation to citizenship

The Minister for Justice, Home Affairs and Migration announced in November 2025 proposals to tighten and clarify citizenship criteria under Irish legislation. Among the key proposals is the introduction of a requirement that citizenship applicants are self-sufficient, and the introduction of clearer guidance on the definition of “good character”, which is an existing statutory requirement for citizenship. In practice, employers seeking to attract talent typically avail of the Irish employment permit regime, rather than the citizenship regime, and it is unlikely that the new proposed rules and changes will impact this.

On the horizon?  

Looking forward to 2026, we envisage that the focus will be on technical changes. April 2026 will mark the one year anniversary of the introduction of the Employment Permits Online System (“EPOS”). EPOS  provides a dedicated portal for the purpose of making immigration applications, with separate user accounts for both employers, employees and agents.

Unsurprisingly, there have been teething troubles with the introduction of the new system. A major issue remains the time taken to set up accounts and navigate the new system – while this could previously be managed through agents who assisted both parties, this is not technically possible on the EPOS, However, a positive development is the ability for employers to manage the system in real time. The day-to-day management of permits (including cancellation and transfer) is significantly more user friendly once an account is established. We expect further improvements as the year progresses.  

Next steps for employers

Ireland’s ability to attract international talent has traditionally been centred on its status as a high growth economy with a pro-immigration strategy and the only native English speaking member state in the European Union. While it is important that these changes are carefully navigated, we do not anticipate that they will materially impact these key positives that distinguish Ireland as a destination of choice for international assignees.

The move of the State to a “roadmap” approach for major immigration changes has helped global mobility teams moving talent to Ireland adapt to global uncertainties. Most of the challenges on the horizon can be faced by global mobility teams that are well positioned with a systematic and well planned approach to global mobility. Understanding the nuances of the announced policy changes and educating key stakeholders will be critical to continue to ensure the smooth movement of talent across borders.

Contact us

For further information please contact our Employment, Pensions and Benefits Group partner,  Rachel Barry, or your usual contact at Matheson,  who are on hand to provide support as needed on all aspects of global mobility.