The Single Permit recast: what changed in May 2026, and where it has not landed yet

What was supposed to happen on 21 May 2026

Directive (EU) 2024/1233 is the recast of the 2011 Single Permit Directive, the instrument that lets a third-country national apply once and receive one document covering both work and residence. It was adopted on 24 April 2024, entered into force on 20 May 2024, and Article 18 gave member states until 21 May 2026 to write it into national law.

It is a modest directive with a few provisions that matter a great deal at the level of a single hire: a hard 90-day decision period, the right to apply from inside the country in some cases, a right to change employer, and a defined period of unemployment that does not cost the worker their permit. It deliberately did not create any new legal pathway; member states keep full control over how many workers they admit. Read it as procedural plumbing rather than an opening of doors, and you will read it correctly.

What actually happened in July

The deadline passed and most of the union missed it. On 15 July 2026 the European Commission sent letters of formal notice to seventeen member states for failing to communicate their transposing measures: Belgium, Bulgaria, Germany, France, Cyprus, Latvia, Lithuania, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden. Each had two months to respond.

That is the first stage of infringement proceedings, not a penalty, and it will most likely end with the laws being passed rather than with anyone in court. But for an employer planning a hire in the next two quarters, the practical consequence is immediate and it is worth stating plainly: a directive does not create rights a worker can enforce against a private employer, and until your national legislature has transposed it, the new rules are not what your voivodeship office or your Ausländerbehörde is applying. What you can rely on today is national law as it currently stands.

Two member states are outside this entirely. Ireland and Denmark do not take part in the directive. Norway, being outside the EU, was never in scope, which is worth remembering if your seasonal planning spans both Finland and Norway.

The four changes that matter to an employer

The decision period. Article 5 requires a decision within 90 days of a complete application. That is the headline, and the qualifications on it are in the next section, because they are where expectations break.

Applying from inside the country. Article 4(2) lets a member state take an application from a third-country national who is already legally resident on its territory, rather than requiring them to be abroad. The obvious case is a student finishing a degree and moving into employment without leaving and re-entering, and it removes a step that used to cost a quarter.

Changing employer. Article 11 gives the permit holder the right to change employer. Member states may attach conditions: a notification to the authority, a check of the labour market situation, and a minimum period with the first employer that may not exceed six months. Where a notification is required, the authority has 45 days to verify the conditions or object. For an employer this cuts both ways, and pretending otherwise would be dishonest: the worker you recruited can move to a competitor after the minimum period, and equally you can hire someone already in the country without starting a permit from scratch.

Unemployment. Also Article 11: unemployment on its own is not a ground to withdraw the permit where it does not exceed three months within the permit's validity, or six months once the person has held the single permit for more than two years. A worker whose plant closes has time to find another job rather than a countdown to removal, which matters for retention in the whole sector as much as for the individual.

What the ninety days does not cover

This is the paragraph to read before you promise a start date to a production manager. The 90 days runs from a complete application, and completeness is decided by the authority, not by you. Two of the slowest steps sit outside the clock entirely.

Recognition of professional qualifications is excluded. If the role requires a qualification that has to be recognised nationally, that procedure runs on its own timetable and the 90 days does not absorb it.

The visa is a separate matter. The directive governs the permit decision; the worker still has to obtain the entry visa from the mission in Bangkok afterwards, and consular capacity is its own queue, as the Czech and Finnish examples elsewhere on this site show in detail.

And where the authority does not decide within the 90 days, the directive leaves the consequences to national law. There is no automatic approval. In practice the number to plan against is still the national one plus the consular one, with the 90 days as a ceiling on one segment rather than a promise about the whole journey.

Where each of our markets stands

The table below is the picture as of the Commission's July 2026 infringement package. One caveat on reading it: not receiving a letter means the member state communicated national measures by the deadline, which is not the same as a complete or correct transposition. The Commission assesses that separately and can open proceedings later.

The practical rule for a hire starting in the next six months is the same either way. Build the timeline on the national procedure as it is actually applied today, treat the recast rights as an improvement that arrives when it arrives, and write the contract so it does not depend on a rule your member state has not enacted.

What to do with this now

Three things are worth doing while the transposition catches up.

First, stop treating the permit and the visa as one number. Wherever you are, ask your provider to quote them separately, because that is how the process actually behaves and it is how you find out which half is slipping.

Second, plan for the employer-change right rather than against it. Once it is in force in your country, retention stops being enforced by the permit and starts being enforced by the job. Employers who pay properly, house people decently and charge the worker nothing are the ones who keep their crews under those conditions, and that is the same list that gets permits granted in the first place.

Third, if you are hiring into Poland, Germany or Finland, ask where the transposing bill actually is before you count on anything in this directive. All three are in the July 2026 package. The answer changes your timeline, and it is a fair question to put to any agency that quotes you a schedule.