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CROSS-BORDER WORKERS

Cross-border workers: Who is able to live in Sweden and work in Denmark?

Working in Denmark is an attractive proposition for many residents of Skåne at the moment due to the strength of the Danish kroner against the Swedish kronor. But who is actually able to live in one country and work in the other?

Cross-border workers: Who is able to live in Sweden and work in Denmark?
A Danish and Swedish flag side by side in Skåne, southern Sweden. Photo: Johan Nilsson/TT

Prices in Swedish kronor and Danish kroner tend to be more or less the same in each country, so a coffee that sets you back about 30 kroner in Denmark, would, for example tend to be about 30 kronor in Sweden. 

At the time of writing, 100 Danish kroner were worth 139 Swedish kronor. This means someone earning 30,000 Danish kroner in Denmark is earning considerably more in real terms than they would earning the same salary in Swedish kronor.

Indeed, this is a major draw for many in southern Sweden, who hope to be able to access the labour market in both countries.

As a rule someone living in Sweden and earning a salary in Denmark can get around 30 percent extra in take-home pay. 

However, Denmark’s work permit rules mean that this option isn’t available to everyone, so make sure you understand the rules if you’re planning to relocate.

Nordic citizens

Citizens of Denmark, Sweden, Norway, Iceland and Finland are able to enter, live and work in Denmark freely, meaning that they are able to live in Sweden and work in Denmark with no need for visas, permits or proof of income or studies.

Family members of Nordic citizens living in Denmark are able to work in the country, but this does not extend to family members of Nordic citizens living in Sweden who wish to work on the Danish side of the border.

EU/EEA citizens

EU/EEA citizens do not need a work permit to work in Denmark, meaning that they are also able to live in Sweden and work in Denmark. However, you may need to show some extra paperwork at the Tax Agency when registering your residency in Sweden.

There are a number of different criteria EU/EEA citizens can fulfil in order to be registered in the Swedish population register and receive a personal number. These include studying, working, seeking work, having sufficient means to support yourself and moving to be with a family member who already has uppehållsrätt – the right to reside in Sweden under EU law.

If you are not yet registered as resident in Sweden, but are planning on living in Sweden and working in Denmark, note that having a job in another country does not give you the right to reside in Sweden as a worker under EU law (uppehållsrätt).

But that doesn’t mean it’s not impossible to work in Denmark and qualify for uppehållsrätt in Sweden. Instead for qualifying as a worker, you may need to prove that you have sufficient means to support yourself in Sweden when you register your residency with the Swedish Tax Agency.

The Tax Agency do not state an exact amount for how much money you must have in order to prove that you can support yourself, but do state on their website that you need to have “enough money so you can live and support yourself in Sweden for at least a year”.

You can prove this by showing copies of your bank statements, and may also be able to show a foreign job contract lasting at least a year which would fulfil the Tax Agency’s requirements, but check with the agency directly to find out what applies in your situation.

British citizens with uppehållsstatus in Sweden

British citizens with post-Brexit residence status or uppehållsstatus in Sweden are not able to live in Sweden and work in Denmark without applying for a work permit, unless they were already working as a cross-border worker before December 31st, 2021. 

Those who were working as cross-border workers before this date should have applied for a grænsearbejderdokument or ‘border worker document’ from Danish authorities before the December 31st deadline, which protects their right to work in Denmark and live in Sweden.

Brits who do not hold uppehållstatus or a grænsearbejderdokument are not able to work in Denmark and live in Sweden, unless they fulfil the requirements for a ‘third country’ Danish work permit and Swedish residence permit, below.

‘Third country’ citizens

If you’re a so-called ‘third country’ citizen – a non-EU, non Nordic citizen – planning on working in Denmark, you will need a work permit for Denmark, regardless of whether you are planning on living in Denmark or Sweden.

If you already hold a Swedish non-EU residence permit or uppehållstillstånd, this does not automatically give you the right to work in Denmark.

As a rule, non-EU citizens wanting to apply for work permits in Denmark will usually need to have an offer of a full-time job with a yearly salary of at least 448,000 Danish kroner (roughly 625,000 Swedish kronor), or a job listed on Denmark’s Positive List, a list of professions suffering from a shortage of qualified professionals in order to qualify.

There are exceptions for some professions, such as researchers, PhD students and farm workers – check nyidanmark.dk for full details.

However, you will also need a residence permit for Sweden, if you wish to work as a cross-border worker. Third country citizens can apply for residence permits in Sweden for work, studies, or to move to Sweden to live with someone who already has the right to live in Sweden.

Swedish residence permits for work or studies cannot be granted on the basis of a job in another country, but if you have a residence permit on family reunification grounds, and also qualify for a work permit in Denmark, then you can work in Denmark and live in Sweden.

If you hold a Swedish work permit, you may lose the right to live in Sweden if you stop working in Sweden and start working in Denmark, as you no longer fulfil the requirements of your Swedish residence permit. Make sure you check with the Swedish Migration Agency before you start working on the other side of the border to make sure you will still be able to live in Sweden legally.

The above information was correct to the best of our knowledge at the time of publication. Please be aware that we are not a government authority and cannot issue any guarantees about whether or not you will be able to live in Sweden and work in Denmark as a cross-border worker.

We advise readers to also consult the official information on websites such as nyidanmark.dk – the Danish portal for foreign nationals wishing to work in Denmark – as well as the Swedish Tax Agency and Swedish Migration Agency before planning to work as a cross-border worker, or if you are unsure of what applies in your situation.

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WORKING IN DENMARK

How Danish work permit rules are keeping out skilled foreigners living in Sweden

Denmark’s Pay Limit Scheme prevents highly qualified foreign nationals in Sweden’s Skåne region, which neighbours Copenhagen, from taking jobs amid a skilled labour shortage.

How Danish work permit rules are keeping out skilled foreigners living in Sweden

Yue Jie, who goes by the preferred name Sean, has a graduate degree in Strategic Communication from Lund University. Sean told The Local he has been unable to accept a job offer with a Danish company due to Denmark’s work permit rules for citizens of so-called ‘third countries’ —  meaning non-EU or EEA countries.

Although it is possible for Swedish residents to work in Copenhagen without a work permit, this is only available to EU or Nordic citizens.

READ ALSO: Cross-border workers: Who is able to live in Sweden and work in Denmark?

Meanwhile, the number of job vacancies in Denmark remains at one of the highest levels for years, with many sectors affected and companies reporting a lack of labour, including skilled workers.

Figures published by national agency Statistics Denmark last month show that unemployment fell to 72,000 persons between February and March, the lowest level since June 2008. Such a small labour pool means companies find it hard to recruit specialised staff.

Denmark and Sweden work together on some areas in an effort to promote cross-border working in the Øresund region which spans the two countries, but this does not stretch to work and residence permits for non-EU nationals.

READ ALSO: Are international workers the answer to Denmark’s labour shortage?

“Originally from Singapore, I’m finishing my Master’s degree studies at Lund University over in Sweden and I’m currently on the search for jobs as I am due to complete my studies,” Yue told The Local.

“For the last month and a half, I’ve been sending job applications both in Copenhagen and in Malmö as these are the two biggest cities within my geographical vicinity,” he said.

“I’ve been in contact with at least two companies in Copenhagen for job applications and interviews, and at least one of them has even offered me a contract for a summer or part-time job this summer. This means that there is, at this point, nothing stopping me from simply crossing the Öresund Bridge from Skåne to Copenhagen anytime for work,” he said.

“The only issue here is that company requires a CPR number in order to pay out my salary, and a CPR number for non-EU nationals cannot be given without a work permit. Another company that recently interviewed with, the recruiter wants to hire me but she could not based on the requirements of the Danish work permit for non-EU (nationals),” he explained.

“I have the knowledge, skills and competencies, and can easily come to the office with a train commute from Sweden, but they cannot offer me employment based on this requirement alone,” he said.

Although non-EU nationals can apply for work permits in Denmark via a number of pathways, Yue said that the only one under which he can potentially fulfil approval criteria is the Pay Limit Scheme or Beløbsordningen in Danish.

The Pay Limit Scheme sets a minimum salary which businesses must pay skilled non-EU nationals in order for the employee to qualify for a Danish work permit. It is currently set at a minimum annual wage of 448,000 kroner.

The Confederation of Danish Industry (Dansk Industri, DI), a business and employers’ interest organisation representing around 19,000 companies in Denmark, told The Local it wanted to see the minimum wage required under the Pay Limit Scheme reduced, and was lobbying to achieve that objective.

“We at DI are working to reduce the current salary threshold on the Pay Limit Scheme from the present 448,000 kroner to 360,000 kroner,” the organisation’s senior political consultant Søren Kjærsgaard Høfler, who specialises in global mobility, said in a written comment.

“We are doing this with particular focus on attracting skilled international workers from outside of the EU and EEA,” he said.

The Pay Limit Scheme has recently been the subject of political discussions due to Denmark’s labour shortage and the need to attract more international workers. 

READ ALSO: How can you get a work permit in Denmark if you are not an EU national?

Under current rules, a work permit can be granted under the Pay Limit Scheme for applicants offered salaries of at least 448,000 kroner a year. No specific educational background or a job within a specific professional field is required.

The government earlier this year proposed that the annual salary requirement be lowered to 375,000 kroner over a two-year period, to allow more international workers into Denmark on the scheme.

DI’s global mobility consultant told The Local that the organisation’s work to smooth the path for foreign recruitment in Denmark was focused on retaining international students from Danish universities. Nevertheless, a reduction of the Pay Limit Scheme’s minimum salary requirement could also benefit other foreign skilled workers.

“Traditionally, we have at DI focused on the options for residence and work for international students who have completed their studies in Denmark. We have made some progress here and we think this is beneficial for Danish companies,” Høfler said.

“We therefore want to make our own education system attractive and relevant for students who are thinking about staying in Denmark after finishing their studies,” he said.

“When studies are not undertaken in Denmark, we fall back on the existing business schemes [used to grant work permits for non-EU and EEA nationals, ed.], which includes the Pay Limit Scheme, which currently requires (a salary of) 448,000 kroner. DI is working to reduce this threshold, which might help in the case in question,” he said when asked about the impact of the scheme on job hopefuls not already in Denmark.

A non-EU national who previously worked in Denmark, but left due to issues caused in part by the Pay Limit Scheme, told The Local her experience made her feel “very frustrated”.

“In early 2019, I was let go from my job in Denmark. I consulted with my union at the time about my chances of finding a job and was told that it would be tough but possible. Thus, I moved to a visa for job-seekers [which allows non-EU nationals to remain in the country for six months to find work, ed.] and began looking for a new job,” said the ex-Denmark resident, who preferred to remain anonymous. The Local is aware of the person’s identity.

Whilst searching for a new job in Denmark, she passed interview stage with an organisation before being rejected. “Later, I learned that the position’s compensation was lower than the Pay Limit Scheme and for that reason (the company) didn’t offer it to me, knowing that I would not be able to take it anyway,” she said.

“I realised that I was stuck because I was not qualified for a position that would pay me enough, while the position that I was qualified for would not pay me enough. I believed the root cause was that my profile (Southeast Asian, educated outside of Europe, humanities major, no Master’s degree, non-Danish speaker, three years of working experience at the time) was not strong enough to procure a job that would satisfy the Pay Limit Scheme,” she said.

“At the time I was very frustrated, especially because if it weren’t me but someone from inside the European Union, they would have been able to get the position (with the company that interviewed me) and continue staying in Denmark. Thus I felt the fact that I was not able to get the position due to my background was unfair,” she said.

“I (also) felt that my life as a single foreigner in Denmark was unstable because the rules governing the Pay Scheme Limit could be changed in the future,” she also noted.

Yue, a communications professional specialised in sales and business development, told The Local that the Pay Limit Scheme was his only hope of being able to work for a Danish company.

“I’m a communications professional, so there is essentially only one category which I can apply under – the Pay Limit Scheme,” Yue told The Local.

“The recruiter that I interviewed told me that the salary for the entry-level position I applied for has a salary below this requirement, thus they cannot hire me,” he said.

The Singaporean told The Local that he wanted “to highlight my situation as a current resident already in Sweden and the nature of such migration/immigration issues within Denmark.”

“If there are any Danish employers out there or international companies in Denmark who are willing to hire me because they recognise that I can be a valuable employee to their organisation, I’m willing to speak with them,” he said.

Sean Yue can be contacted via LinkedIn.

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