The Swedish Migration Agency’s work permit checks – a major risk of errors and abuse
(RiR 2026:5)
Summary
The Swedish National Audit Office has examined whether the Swedish Migration Agency’s checks in work permit cases effectively detect and prevent errors and abuse. The overall conclusion is that there are numerous inefficiencies in the Swedish Migration Agency’s checks in work permit cases that risk causing heightened labour exploitation, unfair competition and work-related crime. For example, the Swedish Migration Agency grants work permits to employers that it has previously deemed unscrupulous, without any enhanced investigation having been conducted in the new applications. In addition, because of inadequate ex-post controls of ongoing work permits, those associated with errors and abuse go undetected.
To improve checks to detect errors and abuse, the Swedish Migration Agency needs to remedy deficiencies in procedures, system support, communication and sampling. One of a number of ways to remedy the shortcomings is by the Government granting the Swedish Migration Agency better means for storing data about employers and representatives.
Checks in the application process are inadequate
The Swedish Migration Agency’s checks in the work permit application process are inadequate for ensuring that conditions for granting the application are fulfilled and that the information in the application is reliable. Work permits are granted to employers that the Swedish Migration Agency has previously deemed unscrupulous, without enhanced checks having been performed in new applications. This failure to perform enhanced checks in cases where there is a high risk of unscrupulous employers is due to deficiencies in system support, information sharing and procedures. Because of shortcomings in system support and information sharing, information about unscrupulous employers is not always apparent or readily available to case officers. For example, there is no comprehensive information on unscrupulous employers or representatives. In addition, case officers are only able to see employers’ previous rejections as far back as 18 months. These system support deficiencies are due to legal barriers to the Swedish Migration Agency storing and compiling personal data concerning employers and representatives.
These legal barriers also limit the possibility of developing risk profiles based on employer data. Risk profiles could have improved precision in checks and helped to identify when enhanced checks are needed. The Swedish Migration Agency only considers whether the employer operates in a high-risk sector or is a newly started business when classifying cases as requiring major investigative resources.
The Swedish Migration Agency’s procedures are unclear in terms of when and how enhanced checks are needed. Despite a high risk of false information in applications, there is little use of verbal investigations – which the Swedish National Audit Office considers to be an effective tool for detecting fraud in cases containing clear risk indicators. In the absence of collective agreements and trade union statements, checks do not suffice either to ensure that insurance coverage is in place and that wages are in line with collective agreements or industry practice.
Ex-post controls are limited and ineffective
The Swedish National Audit Office considers that the sampling for ex-post controls lacks precision. The Swedish Migration Agency’s sampling method is based primarily on high-risk sectors, potentially causing other important risk indicators to be missed. The agency has not ensured good conditions for monitoring ex-post controls, which impairs precision when sampling for them. Besides, effectiveness in ex-post controls is impeded by the Swedish Migration Agency not ensuring that case officers have direct access to the Swedish Tax Agency’s income register. The Swedish Migration Agency’s interpretation – that they may not request specific documents from employers – and the agency’s lack of legal means for conducting workplace inspections as necessary, limit its ability to validate actual employment conditions in ex-post controls. Furthermore, there is a risk that information received from regional centres for the prevention of work-related crime will not reach case officers in the operational activities due to inadequate procedures for sharing information at the agency. These shortcomings can lead to serious consequences in the form of work permits being granted to employers with criminal intentions.
Recommendations
To the Government
- Grant the Swedish Migration Agency extended possibilities for storing information about employers and representatives in order to create better means for effective controls.
- Better enable the Swedish Migration Agency to validate fulfilment of work permit conditions, for example by being able to request specific documents during ex-post controls and, if necessary, conducting inspections at employers’ premises.
To the Swedish Migration Agency
- Use more risk indicators when classifying cases as requiring major investigative resources, and in sampling for ex-post controls. Once legal conditions are granted for storing data on employers and representatives, risk profiles should be developed on the basis of relevant information to improve precision in checks.
- Develop processing approaches to ensure that cases with a higher risk of error or fraud are adequately investigated and that information submitted in applications is validated, for example through verbal investigations.
- Develop means for effective follow-up, for example by introducing random ex-post controls.
- Ensure that case officers, for all cases, have direct access to the Swedish Tax Agency’s income data in the processing system and relevant company information.
- Ensure well-functioning exchange of information and collaboration within and between control units and permit units.
- Develop processing approaches for applications concerning companies without collective agreements with a focus on (1) investigations of insurance coverage, and (2) verifying that salaries are in line with collective agreements or industry practice.