Cross-country comparison
Compare requirements across 24 countries
No government publishes this view: each authority documents its own rules and nothing else. Every row below is a figure taken from the responsible authority's own page, shown with the period it applies to and a link back to the source. Nothing is averaged, scored, or ranked.
Does an employer have to act first?
The question that decides whether a route is open to you at all. In some countries the employer carries a burden of proof or must hold a licence before you can apply; in others you can apply on your own. 17 of the 24 reviewed countries state something on this.
| Country | Requirement | What the authority states | Applies to | Source |
|---|---|---|---|---|
| Australia | The invitation mechanism | You need to be invited to apply for a skilled visa; the expression of interest is not itself a visa application | 2026 | immi.homeaffairs.gov.au/overview |
| Croatia | Blue Card: contract requirement | An employment contract for highly qualified work, for and under the direction of another person, of at least one year, with an entity registered in Croatia | 2026 | mup.gov.hr/stay-and-work-of-highly-qualified-third-country-nationals |
| Croatia | What a Blue Card holder may work at | Only at the jobs the permit was issued for, and only with the employer they entered employment with | 2026 | mup.gov.hr/stay-and-work-of-highly-qualified-third-country-nationals |
| Croatia | Changing employer within the first two years | A new stay and work permit application must be submitted to the competent police administration or station within eight days of the employment with the initial employer ending | 2026 | mup.gov.hr/stay-and-work-of-highly-qualified-third-country-nationals |
| Czechia | Changing employer or position | Changing employer or position, or starting another position with the same or another employer, must be reported to the Ministry of the Interior | 2026 | ipc.gov.cz/employee-card |
| Denmark | Employer requirement | As a general rule, an employment agreement with a company registered in Denmark | 2026 | nyidanmark.dk/Pay-limit-scheme |
| Estonia | Employer precondition | The employer obtains a permit from the Estonian Unemployment Insurance Fund to recruit a foreign national for the position | 2026 | politsei.ee/residence-permit-for-employment |
| France | What the employer is spared | Across the talent sub-cards the employer does not have to apply for a work authorisation and is exempt from the tax on employing a foreign national | verified 1 June 2026 | service-public.fr/F16922 |
| Ireland | Job offer duration | A two-year job offer in respect of the eligible occupation | 2026 | enterprise.gov.ie/critical-skills-employment-permit |
| Ireland | Labour Market Needs Test | Not required | 2026 | enterprise.gov.ie/critical-skills-employment-permit |
| Japan | Documents depend on the employer's category | They differ by the employer's category, one to four; for categories one and two other materials are in principle not needed | 2026 | moj.go.jp/gijinkoku |
| Latvia | Vacancy waiting period | A third-country national may be employed only if the vacancy has been free for at least ten working days, and it must be registered on the State Employment Agency's CV and vacancy portal | 2026 | pmlp.gov.lv/employment-foreigners |
| Latvia | Scope of the employer's responsibility | The employer is fully responsible for the foreigner's employment including wage restrictions, the stay including place of residence and health care, and any removal costs | 2026 | pmlp.gov.lv/employment-foreigners |
| Luxembourg | Blue Card: labour market test | Highly qualified workers are not subject to the labour market test, but the employer must still declare the vacancy to ADEM | 2026 | guichet.public.lu/salarie-hautement-qualifie |
| Malta | Who files the application | A third-country national cannot apply directly; the prospective employer applies online on their behalf | 2026 | identita.gov.mt/who-is-eligible |
| Malta | Requirements on the employer | A company registered and operating in Malta, and registered with Jobsplus | 2026 | identita.gov.mt/who-is-eligible |
| Malta | What the permit is tied to | Specific to the employer and the designation applied for; a change in either renders the permit null and void irrespective of the validity date shown, and a new application is needed | 2026 | identita.gov.mt/change-of-designation-or-employer |
| Netherlands | Sponsor requirement | An employment contract with an employer or research institution in the Netherlands that is a sponsor recognised by the IND | 2026 | ind.nl/highly-skilled-migrant |
| New Zealand | Employer and position requirement | A job offer from, or current employment with, an accredited employer; the position must be permanent or fixed-term for at least 12 months | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| Singapore | Employer advertising obligation | The employer must advertise on MyCareersFuture and consider all candidates fairly | 2026 | mom.gov.sg/key-facts |
| Sweden | Employer insurance obligation | By the start of employment the employer must have health, life, industrial injuries, and occupational pension insurance in place | 2026 | migrationsverket.se/employees |
| Switzerland | Employer's burden of proof | The employer must prove there is no suitable person to fill the vacancy from Switzerland or from an EU/EFTA state | 2026 | sem.admin.ch/nicht-eu_efta-angehoerige |
| United Kingdom | Sponsorship requirement | You must work for a UK employer approved by the Home Office and hold a Certificate of Sponsorship from that employer | 2026 | gov.uk/skilled-worker-visa |
| United Kingdom | Changing employer | You cannot change job or employer unless you apply to update your visa | 2026 | gov.uk/what-you-can-and-cannot-do |
Salary and funds thresholds
Thresholds are set on different schedules — annually, twice a year, or on a date announced years ahead — and several are multipliers rather than fixed amounts. Each row states the period its figure applies to. 14 of the 24 reviewed countries state something on this.
| Country | Requirement | What the authority states | Applies to | Source |
|---|---|---|---|---|
| Austria | Shortage occupations: pay requirement | The employer must pay the minimum stipulated by law, regulation or collective agreement; the page states no single minimum salary figure | 2026 | migration.gv.at/skilled-workers-in-shortage-occupations |
| Belgium | Salary thresholds | Set separately by each Region; the federal pages checked here state no salary figures, so they must be confirmed with the Region where the work takes place | 2026 | employment.belgium.be/foreign-workers |
| Canada | Proof of funds, single applicant | CAD 15,263; CAD 19,001 for two people and CAD 23,360 for three, plus CAD 4,112 for each additional person. These are the amounts IRCC published on 7 July 2025 and they are updated annually | IRCC table published 2025-07-07 | canada.ca/proof-funds |
| Canada | Which programs require proof of funds | Required for the Federal Skilled Worker and Federal Skilled Trades programs; not required for the Canadian Experience Class; waived if authorized to work in Canada with a valid job offer, with an explanatory letter uploaded instead | 2026 | canada.ca/proof-funds |
| Czechia | Blue Card: salary requirement | At least 1.5 times the average gross annual salary in Czechia; the page states no figure, so it must be worked out against the average in force when applying | 2026 | ipc.gov.cz/blue-card |
| Denmark | Minimum annual salary | DKK 552,000; the amount is regulated every year on 1 January | 2026 | nyidanmark.dk/Pay-limit-scheme |
| Estonia | How the salary threshold is calculated | At least Estonia's average gross salary, with a coefficient applied by employment category, for example 1.0, 1.24 and 1.5 | 2026 | politsei.ee/residence-permit-for-employment |
| France | Qualified employee card: salary threshold | Gross annual pay of at least EUR 39,582, shared by all three tracks — diploma, innovative company and intra-group assignment | verified 1 June 2026 | service-public.fr/F16922 |
| Germany | EU Blue Card general salary threshold | €50,700 gross per year (adjusted annually) | 2026 | arbeitsagentur.de/blue-card |
| Germany | EU Blue Card reduced threshold (shortage occupations and career starters) | €45,934.20 gross per year, and Federal Employment Agency approval is required | 2026 | arbeitsagentur.de/blue-card |
| Germany | Opportunity card proof of funds | €1,091 per month, covering the entire stay | 2026 | arbeitsagentur.de/opportunity-card |
| Ireland | Threshold: restricted strategically important occupations | €40,904 a year, with a relevant degree qualification or higher required | 2026 | enterprise.gov.ie/critical-skills-employment-permit |
| Ireland | Threshold: recently obtained qualification | €36,848 a year where the qualification was obtained within the 12 months before the application | 2026 | enterprise.gov.ie/critical-skills-employment-permit |
| Ireland | Threshold: all other occupations | €68,911 a year; at this level a degree is not required provided the necessary level of experience is held | 2026 | enterprise.gov.ie/critical-skills-employment-permit |
| Luxembourg | Blue Card: annual salary threshold | At least the amount set by Grand-Ducal regulation, quoted on the page as EUR 65,652; the amount is fixed by regulation and revised, and the page states no year | Year not stated on the page; confirm the current amount | guichet.public.lu/salarie-hautement-qualifie |
| Netherlands | Monthly salary threshold: aged 30 and over | €5,942.00 gross per month, excluding holiday allowance | 1 July to 31 December 2026 | ind.nl/required-amounts-income-requirements |
| Netherlands | Monthly salary threshold: under 30 | €4,357.00 gross per month, excluding holiday allowance | 1 July to 31 December 2026 | ind.nl/required-amounts-income-requirements |
| Singapore | Qualifying salary: all sectors except financial services (current) | From S$5,600 a month, increasing progressively with age from 23, up to S$10,700 at age 45 and above | New applications before 1 Jan 2027 and renewals expiring before 1 Jan 2028 | mom.gov.sg/eligibility |
| Singapore | Qualifying salary: financial services (current) | From S$6,200 a month, increasing progressively with age from 23, up to S$11,800 at age 45 and above | New applications before 1 Jan 2027 and renewals expiring before 1 Jan 2028 | mom.gov.sg/eligibility |
| Singapore | Qualifying salary: all sectors except financial services (new rates) | From S$6,000 a month, up to S$11,500 at age 45 and above | New applications from 1 Jan 2027; renewals from 1 Jan 2028 | mom.gov.sg/eligibility |
| Singapore | Qualifying salary: financial services (new rates) | From S$6,600 a month, up to S$12,700 at age 45 and above | New applications from 1 Jan 2027; renewals from 1 Jan 2028 | mom.gov.sg/eligibility |
| Sweden | Salary requirement | At least 90 per cent of the median salary in Sweden at the time of the application | from 1 June 2026 | migrationsverket.se/salary-requirements-for-a-work-permit |
| Sweden | Salary requirement for exempted groups | 75 per cent of the median, currently SEK 28,725 | from 16 June 2026 | migrationsverket.se/salary-requirements-for-a-work-permit |
| United Kingdom | General salary threshold | £41,700 per year, or the going rate for the occupation, whichever is higher | 2026 | gov.uk/your-job |
| United Kingdom | Lower salary threshold | £33,400 per year where the usual requirements do not apply and the work is not in healthcare or education | 2026 | gov.uk/your-job |
Points systems
Four of the countries reviewed here score applicants. The scales are not comparable to one another: a pass mark of 70 in one system is not stricter than 55 in another, because the maximums and weightings differ. 5 of the 24 reviewed countries state something on this.
| Country | Requirement | What the authority states | Applies to | Source |
|---|---|---|---|---|
| Austria | Very Highly Qualified: qualification points | A four-year higher education degree scores 20; a MINT-subject degree 30; a PhD or habilitation 40 | 2026 | migration.gv.at/very-highly-qualified-workers |
| Austria | Very Highly Qualified: senior management salary points | €50,000–60,000 scores 20; €60,000–70,000 scores 25; above €70,000 scores 30 | 2026 | migration.gv.at/very-highly-qualified-workers |
| Austria | Very Highly Qualified: age points | Under 35 scores 20; under 40 scores 15; under 45 scores 10, to a maximum of 20 | 2026 | migration.gv.at/very-highly-qualified-workers |
| Austria | Very Highly Qualified: language points | German or English at A1 scores 5 and at A2 scores 10, to a maximum of 10 | 2026 | migration.gv.at/very-highly-qualified-workers |
| Austria | Shortage occupations: qualification points | Completed vocational education or training in the shortage occupation scores 30, the maximum for that criterion | 2026 | migration.gv.at/skilled-workers-in-shortage-occupations |
| Austria | Shortage occupations: language points | German scores 5 at A1, 10 at A2, 15 at B1; English scores 5 at A2 and 10 at B1; a further 5 points where English is the company's predominant language, to a maximum of 25 | 2026 | migration.gv.at/skilled-workers-in-shortage-occupations |
| Austria | Shortage occupations: age points | Under 30 scores 15; under 40 scores 10; under 50 scores 5, to a maximum of 15 | 2026 | migration.gv.at/skilled-workers-in-shortage-occupations |
| Germany | Opportunity card minimum points | Six points; those already counted as skilled workers need no points | 2026 | arbeitsagentur.de/opportunity-card |
| Japan | The three categories of the points system | Highly Skilled Professional 1(a) advanced academic research, 1(b) advanced specialised and technical activities, and 1(c) advanced business management, with separate criteria for changing to category 2 | As at March 2026 | moj.go.jp/newimmiact_3_evaluate_index |
| Japan | The points system's scoring items and pass mark | Set out in ministerial ordinance tables and PDFs; the HTML pages checked do not list them, so the official tables must be consulted directly | 2026 | moj.go.jp/newimmiact_3_evaluate_index |
| Japan | University ranking bonus points | A list of universities attracting bonus points based on world rankings exists; the authority notes it was compiled from rankings as at January 2026 and that the three current world rankings must also be checked when applying | List as at January 2026 | moj.go.jp/newimmiact_3_evaluate_index |
| New Zealand | Skilled Migrant Category points needed | Six skilled resident points | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| New Zealand | Occupational registration points | 3 to 6 points depending on the years of training required, from two to six years | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| New Zealand | Qualification points | 5 to 6 points for New Zealand qualifications; 4 to 6 for international qualifications, which require an International Qualification Assessment; a non-degree qualification at level 7 or below cannot be claimed | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| New Zealand | Income points | 3 to 6 points based on multiples of the Skilled Migrant Category income threshold | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| New Zealand | New Zealand work experience points | Up to 3 additional points for one to two years of skilled New Zealand work experience | 2026 | immigration.govt.nz/skilled-migrant-category-resident-visa |
| Singapore | COMPASS passing score | 40 points | 2026 | mom.gov.sg/eligibility |
| Singapore | COMPASS: salary (C1) and qualifications (C2) | 0 to 20 points each; for qualifications, a top-tier degree scores 20, another degree 10, and none 0 | 2026 | mom.gov.sg/eligibility |
| Singapore | COMPASS: the two employer-determined criteria (C3, C4) | Diversity scores 0 to 20 on your nationality's share among the firm's professionals, managers and executives; support for local employment scores 0 to 20 on the firm's local PMET share relative to its sector | 2026 | mom.gov.sg/eligibility |
| Singapore | COMPASS: skills bonus (C5) | 10 to 20 points for positions on the Shortage Occupation List | 2026 | mom.gov.sg/eligibility |
| Singapore | COMPASS exemptions | A fixed monthly salary of at least S$22,500, intra-corporate transferee status, or roles lasting one month or less | 2026 | mom.gov.sg/eligibility |
How long the permit runs
How long a first permit lasts, and what it is tied to. Several are bounded by the employment contract rather than a fixed term. 16 of the 24 reviewed countries state something on this.
| Country | Requirement | What the authority states | Applies to | Source |
|---|---|---|---|---|
| Croatia | Stay categories | Short-term stay of up to 90 days in any 180-day period in the Schengen area; temporary stay of up to a year; permanent stay and long-term residence indefinitely | 2026 | mup.gov.hr/stay-and-work |
| Czechia | Employee Card: duration | A maximum of two years, extendable repeatedly, each time for a maximum of two years | 2026 | ipc.gov.cz/employee-card |
| Czechia | Blue Card: contract length | At least one year when applying from abroad; at least six months for an extension | 2026 | ipc.gov.cz/blue-card |
| Czechia | Blue Card: validity | Three months longer than the work contract, up to a maximum of three years | 2026 | ipc.gov.cz/blue-card |
| Denmark | Permit length: employment of four years or more | Normally valid for four years | 2026 | nyidanmark.dk/Pay-limit-scheme |
| Denmark | Permit length: employment under four years | Valid for the employment period, plus an automatic six-month job-seeking extension | 2026 | nyidanmark.dk/Pay-limit-scheme |
| Estonia | Permit length | Issued for up to five years, then extendable for up to ten years at a time | 2026 | politsei.ee/residence-permit-for-employment |
| France | When the card itself is required | A talent residence card must be applied for where the intended stay is at least one year; for a shorter stay a long-stay visa serving as a residence permit marked "talent" is sufficient | verified 1 June 2026 | service-public.fr/F16922 |
| Germany | EU Blue Card minimum contract length | Employment contract or binding job offer of at least six months | 2026 | bamf.de/blauekarteeu |
| Germany | EU Blue Card validity | Four years as a matter of principle; if the contract is shorter, the contract duration plus three months | 2026 | bamf.de/blauekarteeu |
| Germany | Opportunity card validity and permitted work | Up to one year as a job-search card, then up to two years as a follow-up card; secondary work averaging at most 20 hours per week, and trial employment of at most two weeks at a time | 2026 | arbeitsagentur.de/opportunity-card |
| Hungary | Permit validity | The Hungarian Card runs up to three years and may be extended for three more; the residence permit for the purpose of employment runs up to two years and may be extended by one, but never beyond three years from first issuance | 2026 | oif.gov.hu/residence-permit-for-hungarian-card |
| Iceland | Post-study job-seeking period | A student residence permit may be renewed for up to 18 months to seek employment; previously this was up to three years | from 8 July 2026 | island.is/new-residence-and-work-permit-rules-take-effect |
| Iceland | Specialist permit for doctoral graduates | A doctoral graduate in Iceland may renew a specialist residence permit for up to 12 months to seek employment based on their specialist expertise, and no work permit is required to obtain it | from 8 July 2026 | island.is/new-residence-and-work-permit-rules-take-effect |
| Iceland | The new short-term residence permit | For stays of more than 90 days but no longer than 180 days, to visit a close family member or to visit Iceland as an artist, scientist or athlete | from 8 July 2026 | island.is/new-residence-and-work-permit-rules-take-effect |
| Japan | Period of stay | Five years, three years, one year or three months, decided in the examination | 2026 | moj.go.jp/gijinkoku |
| Luxembourg | First permit: length and scope | A maximum of one year; for one profession only and within a single sector, though with all employers in it | 2026 | guichet.public.lu/salarie-pays-tiers |
| Luxembourg | Blue Card: contract length | An employment contract of at least six months for highly qualified work | 2026 | guichet.public.lu/salarie-hautement-qualifie |
| Luxembourg | Blue Card: first permit validity | Four years, or the duration of the contract plus three months where the contract runs less than four years | 2026 | guichet.public.lu/salarie-hautement-qualifie |
| Malta | What the permit is and how long it runs | A temporary permit authorising legal residence and employment in Malta for a defined period of over six months, renewable; the single application procedure incorporates both an employment licence and a residence permit | 2026 | identita.gov.mt/single-permit |
| Netherlands | Permit length | Valid for the same period as the contract or job, up to a maximum of five years | 2026 | ind.nl/highly-skilled-migrant |
| New Zealand | Accredited Employer Work Visa length | Up to five years based on the job offered; the maximum continuous stay is five years for most jobs, or three years if the job is ANZSCO skill level 4 or 5 | 2026 | immigration.govt.nz/accredited-employer-work-visa |
| Singapore | Pass length and dependants | Up to two years on first issue and up to three years on renewal; passes are available for eligible family members | 2026 | mom.gov.sg/key-facts |
| Sweden | Permit length | A maximum of two years, and not longer than the term of the employment contract | 2026 | migrationsverket.se/employees |
| Sweden | Passport validity ceiling | A permit is never granted for longer than the passport is valid | 2026 | migrationsverket.se/employees |
| United Kingdom | Visa length | Up to five years before it must be extended | 2026 | gov.uk/skilled-worker-visa |
Language requirements
Where a language level is a stated condition rather than a points factor. 5 of the 24 reviewed countries state something on this.
| Country | Requirement | What the authority states | Applies to | Source |
|---|---|---|---|---|
| Australia | Competent English: nationality exemption | A citizen of, and holding a valid passport issued by, Canada, New Zealand, the Republic of Ireland, the United Kingdom or the United States | 2026 | immi.homeaffairs.gov.au/competent-english |
| Australia | Competent English: how recent the test must be | Achieved in the three years before the visa application | 2026 | immi.homeaffairs.gov.au/competent-english |
| Australia | Competent English: IELTS scores | At least 6 in each of the four components, Academic or General Training; One Skill Retake results are accepted for eligible visas | Tests approved from 7 August 2025 | immi.homeaffairs.gov.au/competent-english |
| Australia | Competent English: other approved tests | CELPIP General at least 7 in each of the four components; Cambridge C1 Advanced at least 163 listening, 163 reading, 170 writing and 179 speaking | Tests approved from 7 August 2025 | immi.homeaffairs.gov.au/competent-english |
| Canada | Federal Skilled Worker language requirement | CLB or NCLC 7 in all four abilities in the first official language; if a second official language is counted, CLB or NCLC 5 in all four | 2026 | canada.ca/language-testing |
| Canada | Canadian Experience Class language requirement | CLB or NCLC 7 for TEER 0 or 1; CLB or NCLC 5 for TEER 2 or 3 | 2026 | canada.ca/language-testing |
| Canada | Federal Skilled Trades language requirement | CLB or NCLC 5 for speaking and listening, CLB or NCLC 4 for reading and writing | 2026 | canada.ca/language-testing |
| Estonia | Language requirement after five years | Since 15 July 2018, someone who has lived in Estonia for five years and applies to extend or for a new residence permit for employment must pass the Estonian language exam at level A2 | from 15 July 2018 | politsei.ee/residence-permit-for-employment |
| Germany | Opportunity card language requirement | German at least A1, or English at least B2 | 2026 | arbeitsagentur.de/opportunity-card |
| United Kingdom | English requirement | Reading, writing, speaking and understanding at CEFR level B2; some nationalities are exempt, as are certain regulated medical professions that have passed an accepted assessment | 2026 | gov.uk/knowledge-of-english |
General educational information only, not personalized immigration or legal advice, and not a prediction of any outcome. Requirements change; confirm them with the responsible authority before acting.