According to Hanna Geurtsen, deputy head of the Migration Agency's new work permit "special focus area", the list will be based on another list of 152 job titles provided in a memo to the agency from the Swedish Public Employment Service (Arbetsförmedlingen) on June 1st.
"We will have a list, but it will not be 'the list of exemptions'," Geurtsen stressed. "It will instead be part of the underlying information and reasoning that the government can take into consideration if they want to proceed with this proposal."
The list is set to be published by the end of the week, well ahead of the August 1st deadline given by Sweden's then labour and integration minister, Mats Persson, when he requested it in February. In the press release announcing the order, he said that "opportunities for exceptions for professions where there is a shortage" were "of great importance".
The Migration Agency has taken the Arbetsförmedlingen list of 152 job titles and then noted down which job titles have in the past been taken by foreign workers in significant numbers; which, such as the police or the military, require Swedish citizenship; and which have in the past been abused by employers or subject to workforce exploitation.
Arbetsförmedlingen's list in turn whittled down the 429 job titles listed in the Swedish Standard Classification of Occupations (SSYK) system which both pay less than Sweden's median salary and for which employers also have problems recruiting from within Sweden.
Geurtsen stressed that because the government had yet to propose the legislation for a future work permit salary threshold with exceptions, the list presented this week could only be advisory.
Since a government inquiry into the salary threshold and exemptions was published in February 2024, with consultation responses received by May 16th 2024, the government has for more than a year delayed taking the next step, which would be to submit a draft bill to the Council of Legislation.
This means that the date the inquiry envisaged for the higher salary requirement (at least 100 percent of the median salary) and possible exceptions – June 1st – passed without even a draft bill published, let alone one submitted to and voted through by parliament.
"What's important to understand here is that there is currently no legislation which would regulate a salary requirement," Geurtsen told The Local.
"This list cannot come into force. It doesn't have any legal status until they tell us how they want to legislate. They also need to decide who in the future will have the mandate to decide on the list. We don't have that mandate."
In particular, she said, it's important to understand that the exceptions cannot be applied to the current salary threshold, which is set at 80 percent of the median salary, as this is based on different legislation, the försörjningskrav, which concerns the amount the government judges people need to earn to live comfortably.
Alongside the list, the Migration Agency will also explain why the order it was given in February has been challenging to fulfil.
"Our press release will stress the fact that this task was difficult to execute due to lack of general definitions and a lack of methodology," Geurtsen said.
The inquiry report from 2024, she noted, had given no guidance on how to judge what "risk of abuse or workplace exploitation" would be enough to bar a job title from having an exception.
Another complication was that Arbetsförmedlingen was asked to provide its list by June 1st, and the median salary was then updated on June 17th. This meant that the list it provided was out of date only 16 days after it was passed to the Migration Agency.
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