This article is part of a series on upcoming legal changes in 2026. See our other articles on UK immigration, employment law in Ireland, employment law in Great Britain and employment law in Northern Ireland.

New minimum annual remuneration thresholds from 1 March 2026

In December 2025, the Department of Enterprise, Tourism and Employment (DETE) announced a roadmap to implement changes to the minimum annual remuneration (MAR) thresholds for employment permits.

From 1 March 2026, MAR thresholds for all key employment permit types will increase. These increases will be accompanied by graduate-specific bands and the introduction of an indexation model which will see further increases through to 2030 (and beyond) to keep pace with average earnings.

Effective from 1 March 2026, MAR thresholds will increase as follows for the employment permits below: 

Lower MAR thresholds for recent non-EEA graduates from third level institutions in Ireland who have graduated within the previous 12 months will also be introduced.

From 1 March 2026 the starting minimum annual remuneration thresholds for recent graduates will be:

From 2027 to 2030, MAR thresholds will be subject to annual indexation whereby the Minister will review MAR thresholds for employment permits having regard to the changes in average weekly earnings made available from the Central Statistics Office (CSO). 

Following its review, if the Minister is satisfied that there has been an increase in average weekly earnings as calculated by the CSO, the Minister must increase the MAR thresholds by the same percentage or more. 

Sub-standard MAR thresholds in healthcare and agri-food sectors will narrow over time until they align with MAR thresholds for all other sectors. 

For further insight, check out our recent article here.

Improvements to Employment Permits Online

April 2025 saw the introduction by the DETE of the new Employment Permits Online (EPO) system which promised to streamline the submission, processing and issuance of employment permits, offering enhanced functionality and security to benefit employers, employees, and agents alike. 

Eight months on from its introduction, the new system has largely impressed but users do continue to experience challenges. These have impacted employment permit application processing times, user experience and potentially, Ireland’s reputation as a responsive and employer-friendly destination for global talent. 

As with the launch of any new system, teething problems will exist. Therefore, we expect further improvements and enhancements to be made to the EPO system in 2026, potentially with additional functionality for users. 

Higher employment permits compliance activity

A compliance‑first posture is now becoming embedded in Irish business immigration, reinforced by the introduction of the Employment Permits Act 2024, the EPO system and the continued digitalisation and modernisation of application and customer contact portals. 

While there are continuing issues with the EPO system, improvements in the efficiency and administration of the employment permit system through EPO means employers are more readily able to ensure compliance with certain aspects of employment permit legislation. 

Consequently, the DETE has started to pivot toward a stricter line of enforcement when it comes to implementation and application of employment permit rules and legislation, a trend we may continue to experience into 2026. 

In 2025, DETE more closely scrutinised employment documentation submitted with employment permit applications, ensuring offers of employment were permanent and that prohibited clawback provisions were removed from terms and conditions of employment. 

In 2026, compliance will remain a priority for the DETE and we may begin to see, though inspections or otherwise a review of whether personal and occupation information is being kept up-to-date on the new EPO system. 

The Employment Permits Act 2024 aimed to improve the status and employment opportunities of employment permit holders and reduce accidental non-compliance with employment permits legislation. This was done by removing the requirement to notify the DETE if the permit holder is promoted, receives an uplift in salary or is subject to an internal transfer within the employer company, provided the permit holder will be using the same skills and the employment remains eligible for an employment permit. 

Despite this notification obligation being removed, the new EPO system allows the employer, the employment permit holder or a respective agent to easily and quickly update and amend the following information on their issued employment permit: 

• Job title;
• Salary;
• Working hours; and
• Employee locations, including adding additional locations. 

While there is no obligation to update an employment permit holder’s job title or salary when they will be using the same skills and the employment remains eligible for an employment permit, a change to working hours or employment location may have a material impact. 

A change in working hours may affect whether the employment permit holder continues to meet the MAR threshold for an employment permit as all MAR thresholds are based on a 39-hour working week. 

Further, all employment permits are location-specific, and the employment permit holder may only work for their employer, from the location(s) specified on their employment permit. Therefore, if an employment permit holder has recently relocated to take up employment in Ireland after being granted an employment permit, they may need to update the DETE with their work from home location if they are permitted to work from home and have secured more permanent long-term accommodation. Similarly, an update will be needed if there is an office move or if the employee moves home. 

Now that this information can be updated more easily, the DETE (and, by extension, inspectors of the Workplace Relations Commission) may take a harder view if this information is not up-to-date on the EPO system. 

While revocation of an employment permit is unlikely, the DETE may scrutinise existing and future employment permit applications submitted for that employer. 

Practically, employers may consider carrying out internal audits and data hygiene exercises to ensure all employment information for their employment permit holders is accurately reflected on the EPO system, especially if there has been an office move or if employment permit holders have recently relocated, received an uplift in salary, or a promotion changing their job title. 

Extension of IRP renewal concession

As the Immigration Service Delivery (ISD) continues to experience a very large volume of applications for Irish Residence Permit (IRP) card renewals, applications are now taking up to 10 weeks to process. As a result of these long processing times, at the end of 2025 the ISD extended the long‑standing 8‑week concession to 12 weeks.

The 12-week concession is only available when an application has been made by the employee or their agent to renew their IRP card prior to its expiry. Accordingly, to ensure an employee continues to hold right to work in Ireland on an expired IRP card, employers should continue to ask its employees to provide it with proof that they have applied to renew their IRP card, including when changing their permit type.

Impact of revised family reunification policy

The Department of Justice, Home Affairs and Migration’s (DOJHAM) revised family reunification policy took effect on 26 November 2025, overhauling Ireland’s family reunification rules for non-EEA nationals living in Ireland. As we move into 2026, we will start to see the impact of this new policy as it introduces higher income thresholds for certain sponsors, stricter eligibility requirements for adult dependents and new accommodation requirements for sponsors. 

Here are the key effects for employment-based sponsors: 

• General employment permit (GEP) holder sponsors (Category C) may sponsor a spouse, civil partner or de-facto partner for family reunification if they earned a gross income €30,000 or more in the previous year. However, if the couple have a child, the GEP holder sponsor must now demonstrate they earned net annual pay of €36,660 (€44,300 indicative gross salary equivalent in 2025) in the previous year to sponsor a single minor child (in addition to their partner). Further, the financial thresholds increase incrementally with each additional child to be sponsored.
  This change is impractical.
  For example, a GEP holder earning €42,000 gross per year will satisfy the MAR threshold to be eligible for a GEP and will be eligible to sponsor a partner for family reunification. However, they won’t meet the financial threshold to be eligible to sponsor a child as their pay is less than €44,300 gross/€36,660 net. In contrast, a critical skills employment permit (CESP) holder earning €42,000 gross per year could sponsor their partner and child(ren) for immediate family reunification.
   
• CSEP and intra-company transfer employment permit (ICT) holders (Category B) continue to face no financial threshold for nuclear family reunification sponsorship, however they must evidence ongoing compliance with their own permission at renewal.
   
• The existing requirement for the GEP holder to have completed 12 months of residence in Ireland before submitting a family reunification application also remains in place. Unlike for GEP holders, family reunification for CSEP and ICT holders may take place before any earnings are accrued and the sponsor may be accompanied by their nuclear family on entry into Ireland.
   
• Dependent minor children of CSEP, GEP, ICT, or Researcher (Hosting Agreement) holders, who have applied for and been granted family reunification will now be registered on Stamp 1G permission on reaching the age of 16. This will displace prior Stamp 3 restrictions and allow them to take up employment in Ireland, easing entry into part-time and seasonal work.
  As an exceptional measure, eligible dependent minor children with a Stamp 3 endorsed on their current in-date IRP card have had their permission to remain in the State varied to the same conditions as Stamp 1G. They do not need to make a new application to change their current permission from Stamp 3 to Stamp 1G or acquire a new IRP card. They may provide prospective employers with the following letter in conjunction with their current IRP card endorsed with a Stamp 3, which explains this temporary administrative arrangement.
   
• The new family reunification policy clarifies that only unmarried minor children under the age of 18 will be considered as part of the sponsor’s nuclear family. The previous family reunification policy extended this category to a maximum age of 23 where the child was in full-time education and remained dependent on a parent sponsor. This extension has been removed, meaning that adult children in full-time education must now pursue permission in their own right if they wish to live, study or work in Ireland.
   
• An application for family reunification may only be made by a dependent adult child over the age of 18 where that child is dependent on the care of their parent due to serious medical or psychological conditions. While the adult child in such circumstances is not automatically considered to be part of the nuclear family, there is provision to sponsor that child where dependency is established. The degree of dependency must be such as to render independent living at a subsistence level by the family member in his/her home country impossible if the financial and social support of the parent were not maintained.
  Alongside these stricter requirements, the financial thresholds for seeking family reunification with an adult dependent child are higher. Now a sponsor must earn a gross annual salary of €92,789 to sponsor one adult dependent, with higher incremental thresholds for each additional dependent, due to the potential burden on Ireland’s state services.
   
• Sponsors will need to evidence that ‘suitable accommodation’ is available for dependent family members. Final details on this requirement are pending and expected to be clarified in 2026.

CSEP and ICT sponsors remain largely unaffected by these changes, except in relation to the treatment of adult children. 

In contrast, there is likely to be a material impact on recruitment and retention for sectors heavily reliant on employing GEP holders (healthcare, agriculture, construction, transport, logistics and other sectors facing labour shortages in skilled and semi-skilled roles) given the divergence between MAR thresholds for employment permits and net income thresholds for sponsoring family members for family reunification. 

Given the impact this may have upon the recruitment and retention of GEP holders, employers may wish to consider making submissions for the inclusion of occupations on the critical skills occupations list during a future public consultation process reviewing the occupations lists. By inclusion on the critical skills occupations list, certain occupations will become eligible for a CSEP and eligible to sponsor family members for immediate family reunification without the requirement to accrue earnings or meet net financial thresholds (as their migration to Ireland is promoted as part of Government policy). 

However, inclusion of certain roles on the critical skills occupations list may have limited effect given the higher MAR thresholds to be eligible to obtain a CSEP and which are higher than industry norms and the additional requirement to possess a relevant third level degree, where formal academic qualifications are not a requirement for such role e.g. skilled trades.

Review of occupations lists

A public consultation process reviewing the critical skills occupations list and ineligible list of occupations for employment permits closed in September 2025.

This was an opportunity for employers, industry groups, and professionals to provide feedback on occupations they believe:

• Should be eligible for an employment permit;
• Should be added to the critical skills occupations list; or
• Should be subject to quotas or have their quotas increased.

To-date, only new employment permit quotas to support meat processing and dairy sectors have been announced with a further 1,000 employment permits made available for meat processing operatives and 850 employment permits for dairy farm assistants.

No other changes have been announced to the occupations lists, yet. But we may see some further changes to the occupations lists announced in early 2026. 

Phased introduction of a single permit application procedure

Proposals for the development of a single application procedure for employment permits and visas were agreed in principle by the Irish Government in 2022. An Inter Departmental Working Group was then established to develop an implementation plan for consideration by Government. 

To-date, no report has been published by the Group but in the current programme for government, the current Irish Government has pledged to merge the visa and employment permit system into one user-friendly single application procedure supported by a new ICT system. 

Nonetheless, the introduction of a single application procedure will be welcome considering it is not uncommon for the DETE to issue someone with an employment permit, only for the DOJHAM to later refuse an employment visa for that same individual. It is expected that the implementation of the system will be completed over a phased basis, likely over a few years and it would be welcome if 2026 was year one for that process.

Further details on naturalisation eligibility changes

In November 2025 Minister Jim O’Callaghan received government approval to amend Irish legislation, proposing to tighten and clarify citizenship criteria.

The timing of any legislative changes is yet to be announced as the legislative heads are being developed, with further detail anticipated through 2026. However, the Minister has signalled these amendments will clearly define what constitutes ‘good character’, one of the statutory conditions to qualify for Irish citizenship.

To-date, satisfying the good character requirement has generally meant having a clean criminal record assessed via an applicant’s self-declaration, a National Vetting Bureau check and/or a report by An Garda Síochána (where applicable), with the Minister maintaining absolute discretion to refuse an application provided a clear rationale for the refusal is provided to the applicant.

The Minister proposes to clarify the application process for applicants and the decision-making process for officials to ensure there is clear guidance on the application of the good character requirement. This should avoid inconsistencies in the assessment of applications and, in turn, reduce the potential for judicial review proceedings challenging the administrative practice leading to refusals on character grounds.

Conclusion

Ireland remains committed to attracting skills and talent while preserving immigration compliance and system integrity. The employers who will navigate 2026 most effectively will be those who link strategic workforce planning with compliance, whilst also potentially offering pragmatic family support to meet new earnings thresholds.

Employers must plan for what 2026 will bring. We can help with an assessment of how your business may be impacted by recent and upcoming developments, including making recommendations; training options to ensure compliance with your duties and an understanding of the Irish immigration landscape; mock right to work audits; and providing useful guides and resources.