This chapter reviews the eligibility criteria for labour migration pathways based on empirical data on the policy settings of 41 OECD and EU countries. The analysis is structured around three sets of eligibility criteria: worker characteristics (education, skills, age, nationality), employment offer characteristics (sector, occupation, salary), and employer characteristics. The chapter focusses on the comparative application of criteria and evaluates the design choices and trade‑offs when combining and calibrating them.
Admitting Labour Migrants
Making Migration Management Work
Abstract
Setting eligibility criteria and thresholds is one of the most direct ways in which governments design their labour migration architecture. These levers provide the formal framework through which authorities determine whether a foreign worker is eligible for admission through a specific pathway. By defining these parameters, governments exercise their prerogative to regulate labour market access in line with their policy objectives.
Criteria can be applied at three levels: to the migrant worker, based on their individual characteristics (education, skills, age, nationality, etc.); to the job or contract offered, based on its characteristics (occupation, sector, salary, etc.); and to the employer offering the position to the migrant worker, based on the characteristics of the firm.
This chapter examines these requirements using empirical data on the policy settings of 41 OECD and EU countries and 220 pathways. It focusses on how criteria and thresholds are applied to workers, jobs and employers across countries, and evaluates the design choices and trade‑offs governments face when combining and calibrating these criteria. For each migration pathway, eligibility criteria act as the primary filter for selection (see Table 2.1).
Main eligibility criteria by element assessed
Source: OECD Secretariat analysis of labour migration pathways.
Other instruments come into play once these basic criteria have been satisfied. Some determine admission, such as Labour Market Tests (LMT, covered in Chapter 3), Shortage Occupation Lists (SOL, covered in Chapter 4) or numerical quotas (covered in Chapter 5). Others govern how the admission process is conducted, such as recognised employer schemes (chapter 7) and administrative priority schemes (Chapter 6).
In particular, this chapter focusses on education and qualification thresholds, salary thresholds and occupational requirements, as these are the most commonly used eligibility criteria. To explore them in greater depth, the chapter looks closely at skilled migration pathways, which account for more than 80 of the 220 pathways reviewed and rely on these criteria most extensively.
Educational thresholds represent a primary criterion for determining the eligibility of a labour migrant. They define the minimum formal academic or vocational credentials required for admission through a specific migration pathway, or the conditions under which education may be substituted by professional experience. In the absence of direct evidence regarding a worker’s performance, formal qualifications function as a signalling mechanism, allowing employers and authorities to assess a candidate’s suitability for a specific role and their alignment with a given migration channel.
Educational thresholds are present in approximately half of the 89 skilled pathways analysed in this study, though their regulatory application varies by skill level. For professional and highly skilled routes, academic attainment typically serves as a baseline for eligibility, using formal degrees as a verifiable proxy for expertise. Conversely, non-professional and vocational pathways often prioritise functional competency. While they may lack formal educational mandates, they frequently require proof of prior experience or the formal recognition of foreign qualifications to ensure occupational relevance.
Figure 2.1 maps these thresholds along two dimensions: the level of educational attainment required (vertical axis) and the recognition requirements (horizontal axis). This mapping illustrates how countries balance formal education requirements against the standards used to assess them. In the case of regulated professions, formal recognition is essential; for non-regulated professions, the recognition requirements vary.
A pathway may require formal assessment from a body in the destination country, ranging from an assessment of equivalence to full recognition. These processes sit at different points on a spectrum. At the non-binding end, academic equivalence assessment – sometimes referred to as “nostrification” – maps a foreign qualification to domestic higher education levels, producing an expert opinion that carries no direct legal value for employment purposes. It generally constitutes the first stage of the recognition process. At the legally binding end, full recognition formally acknowledges that a foreign qualification is equivalent to a domestic degree or vocational training diploma; where regulated by law, this acknowledgement has binding legal consequences – as is typically the case for regulated professions and certain protected titles. For non-regulated professions, requirements fall between these two poles and vary across countries and pathways.
Level of educational attainment required and recognition required
Source: OECD Secretariat.
The lower left corner of Figure 2.1 shows the pathways that do not require any minimum level of education. This is the case for most seasonal employment pathways, as well as a number of general work permits which have no minimum education threshold (Table 2.2). These include certain general pathways which are open to workers regardless of their education or qualification level, whether low, medium or high.
Several European countries have work permit pathways which do not have education or skills requirements (e.g. Bulgaria, Estonia, Finland, France, Italy, Poland, Portugal, the Slovak Republic, Spain, Sweden and Romania). The general work permit channels in these countries, which are the main pathways for labour migrants, impose no specific educational or skills requirement. Non-professional pathways in Korea, the trainee pathway in Japan, and general work visa pathways in Latin American OECD countries (e.g. Colombia’s M-permit) are also examples. In these countries, other instruments are more determinant of admission (LMT and numerical limits, for example). Workers must only prove they are qualified or possess relevant skills for a specific job offer. Assessment of suitability is delegated to the employer.
The multitude of pathways does not mean that applicants with no education or qualifications can be easily recruited. A frequent condition is that, even when there is no general education or qualification requirement, the worker must still have education or skills in line with the requirements of the job. Where a pathway is limited to certain occupations that require a minimum level of education, the effect is to exclude workers without education or qualifications. More significantly, many of the pathways listed apply a labour market test (see Chapter 3), which may in practice result in the refusals of applications for jobs with no skills requirements. In other cases, a salary threshold, discussed in more detail below, may be imposed as a contractual condition, and few workers without qualifications are likely to find jobs paying above it.
Some of the pathways listed in Table 2.2 are, in practice, primarily used for employment in higher qualified jobs. Australia’s Skills in Demand pathway, Canada’s high-wage stream under the Temporary Foreign Worker Program, and New Zealand’s Accredited Employer Work Visa, for example, exclude most workers with low education or qualifications. Canada’s International Mobility Program (IMP), by contrast, includes many categories exempt from the labour market test that do not rely on wage thresholds, but instead focus on economic, cultural and social benefits.
Non-seasonal pathways where candidates without minimum education can potentially be eligible, by criteria
Note: Czechia’s Employee Card has no skills or education requirement, but the allocation of processing capacity through the Qualified Worker Programme means that occupations not in ISCO group 8 or above are unlikely to see workers admitted.
Source: OECD Secretariat analysis.
“Mid-skill” pathways require vocational training or another non-academic formal qualification obtained through a programme of defined duration – typically one to three years. In most cases, these pathways look for direct occupational relevance to the job offer and may require minimum years of experience. In some cases, they may require the applicant to undergo a recognition of foreign qualifications process to prove the training is equivalent to similar training offered in the host country. Some examples of this model include Germany’s “Skilled Worker with vocational training” permit, Austria’s “Skilled Worker in Shortage Occupations” Red-White‑Red Card, and Norway’s Skilled Worker permit. Sometimes these pathways are linked to shortage occupation lists (SOL) that facilitate the equivalence and admission process based on labour market gaps (See Chapter 4 for a detailed review of SOL). Even in the absence of education or qualification requirements, the pathway may still contain a skills assessment process to ensure ability to perform the job. One example of this, where custom skills tests apply to each occupation, is Japan’s Specified Skilled Worker programme. Within the programme, some of the jobs require very basic skills thresholds – such as in certain agricultural positions – and are accessible to workers without any education or qualifications. Others, such as aviation mechanics, fall squarely in the domain of mid-skill and technical positions.
Regulated occupations, in the upper right of Figure 2.1, introduce a distinct and often stringent layer of requirements across labour migration pathways. In these cases, access to employment is contingent not only on holding a job offer or meeting skill criteria, but also on obtaining authorisation or a licence to practise under host‑country professional regulations. These restrictions are most common in health, education, and certain technical trades, where migration authorities defer eligibility assessments to sectoral regulators. Regulated occupation requirements are aimed at protecting professional standards, as well as the resident labour force, and significantly shape who can access labour migration pathways into regulated professions.
Recognition of foreign qualifications can be a lengthy process, representing a significant disincentive for workers and employers considering vocational pathways. To address this, some OECD countries have introduced provisions allowing migrants to enter and begin working while recognition is still underway, rather than requiring the full process to conclude before admission. This includes, for example, Austria, Germany and Denmark (see Box 2.1).
Germany’s 2024 reform of the Skilled Immigration Act introduced an “entry and employment under a recognition partnership” route, allowing migrants to undergo the recognition procedure after arrival while working in the profession, typically at a lower level, subject to Federal Employment Agency approval. Denmark has similarly introduced measures allowing qualified healthcare professionals from non-EU/EEA countries to begin working sooner while authorisation is underway. Austria allows nurses and nursing assistants undergoing the recognition (nostrification) process to work in health and long-term care positions at the level below their actual qualification or, in the case of nursing assistants, under supervision and guidance.
While such provisions can reduce barriers for both employers and migrants, they involve trade‑offs: workers typically may face temporary occupational downgrading in both tasks and pay, and the process can be lengthy without guaranteeing a successful outcome. Expanding these models therefore requires careful design and transparency with migrants about likely outcomes.
Note: International Migration Outlook 2026 (forthcoming) for a discussion of conditional admission in long-term care work pathways.
Requirements for qualified and highly qualified pathways typically mandate minimum education (at least a bachelor’s, but often at least a master’s, degree), shown on the right axis in Figure 2.1. By setting a clear threshold, these schemes use academic credentials as a verifiable proxy for skills. Despite this rigidity, the review of pathways shows that formal recognition of foreign qualifications is less commonly required in this category than in the categories for vocational pathways. Instead, governments often require only that the degree be recognised in the issuing country or delegate the assessment of the degree’s quality and suitability to the employer. Some jurisdictions use a minimum three‑year duration for university degrees as a standard benchmark to align foreign qualifications with domestic academic requirements, a model exemplified by the 2009 EU Blue Card.
Researcher pathways usually have strict educational attainment requirements. Generally, applicants must demonstrate at least a master’s-level qualification, although in some cases a doctorate is required. This threshold is generally verified by the hosting research institution or university, which authorities trust to assess the validity of the degree. The convergence across EU jurisdictions in this category is a result of the EU Students and Researchers Directive, adopted in 2016, which defines a researcher as “a third-country national who holds a doctoral degree or an appropriate higher education qualification which gives that third-country national access to doctoral programmes”. (European Parliament and Council of the European Union, 2016[3]). Design choices in researcher pathways outside the EU vary considerably on eligibility thresholds, mobility rights, and the rights of accompanying family (See Box 2.2). The researcher pathways share, however, one feature: they define eligibility based on the body offering the researcher a position (the employer or host institution).
The 2016 Students and Researchers Directive has produced a high degree of convergence across EU Member States on researchers’ admission conditions, including institution-based sponsorship, intra-EU mobility rights, and opportunities to look for a job or set up a business for a period of up to nine months after the completion of the research period. Comparable pathways exist across other OECD countries, though their design varies considerably. These differences are relevant for understanding how researcher admission frameworks interact with broader talent attraction objectives.
United States. The J‑1 Research Scholar visa operates through a sponsorship model requiring a host institution designated by the State Department. The visa carries a maximum duration of five years, with no intra-country mobility without a new sponsor. It does not count towards permanent residence eligibility. They may bring spouses and dependents, (J‑2), who may in turn request employment authorisation in order to have full labour market access. When the J‑1 visa expires, the researcher must qualify for another visa in order to remain (a 30‑day grace period is granted), although in-country adjustment of status is allowed if the application is filed before the grace period ends. Certain researchers must depart for two years, however, before being eligible for change of status.
United Kingdom. The Global Talent route covers academia and research but requires endorsement as “Exceptional Talent” or “Exceptional Promise” by a designated body. Researchers who are not endorsed in these categories use the standard Skilled Worker route, which lacks researcher-specific features.
Japan. Japan’s researcher pathway requires affiliation (contract or appointment) with any public or private legal entity in Japan capable of contracting research work, to perform appropriately remunerated research activities. It applies a notably flexible educational threshold relative to the classification of “researcher” in other OECD countries: a university degree is the minimum requirement, and this can be substituted by ten years of relevant professional experience. Family members must separately request employment authorisation rather than receiving it automatically.
Korea. Korea’s E‑3 visa channels researchers through institutional sponsorship; eligible sponsors include universities, government-funded research institutes, and officially certified corporate‑affiliated R&D institutes. It allows researchers to change visa status within Korea. Family members of E‑3 visa holders, as in Japan and the United States, must separately request employment authorisation.
One clear feature shared by all these pathways is reference to the characteristics of the host institution and the absence of a salary threshold. Across these systems, design choices around eligibility thresholds, mobility, family rights, opportunities to change visa status, and pathways to long-term residence vary substantially.
Source: OECD Secretariat
Not all education and skills eligibility requirements are assessed according to those held by the worker. Authorities may sometimes use the education and skills requirements of the occupation. In the United Kingdom, for example, a salary threshold is applied, coupled with the Regulated Qualifications Framework (RQF) requirement for the occupation. The pre‑2021 system set the threshold at degree‑level occupations (RQF 6), the 2021 reform lowered this to A-level equivalent roles (RQF 3), and a further reform in 2025 moved it back towards degree‑level jobs. Across these changes, salary thresholds have remained the principal eligibility filter in the absence of an LMT. The RQF measures the level of knowledge and skills, although it is not strictly related to the years of study; RQF 6 corresponds to a bachelor’s degree in most cases but also encompasses vocational, technical and work-based skills. In this case, it is assumed that the worker meets the occupational education requirements.
A different approach is taken in the 2021 EU Blue Card directive, which allows “higher professional skills” to substitute for higher education qualifications. These skills must be demonstrated through at least five years of relevant professional experience, or three years for ICT occupations, acquired within the previous seven years. EU Member States may require a formal evaluation of experience or accept the employer’s job offer as sufficient proof of assessment. The Netherlands, for example, assesses correspondence of experience to EQF level 6, comparing the content of the work, the level of responsibility and the complexity of tasks with those of jobs requiring tertiary-level qualifications.
Educational thresholds provide a simple administrative indicator, relatively easy to document, assess and verify, that a worker’s qualifications align with labour market needs. However, they remain an imperfect proxy for practical expertise and specific skills. Degree requirements simplify the decision-making process for high-skill pathways but may be ill-suited for technical or emerging sectors where employers seek expertise acquired through experience rather than traditional university pathways. Consequently, these thresholds may end up combined with complementary criteria, such as salary and professional experience, to provide authorities with a holistic view of a worker’s skills and avoid excessive restrictiveness.
Age is another eligibility criterion to which the worker can be subject. Minors below age 18 are generally excluded, although Spain allow seasonal workers and work permit recipients to be age 16 and above; Mexico allows seasonal workers age 16 and above, with those 16‑17 requiring a judge order with parental consent. Other higher minimum age includes Korea’s seasonal programme – age 19 and above – and Australia’s PALM programme, which has a minimum age of 21. Within Canada’s Seasonal Agricultural Worker Program (SAWP), participating countries agree to a minimum age limit of at least 18 years of age for workers.
Few pathways have a maximum age limit. Korea’s non-professional temporary channel, for example, has a maximum age of 38. Israel generally does not approve “expert” permits to persons over age 60. Age limits are more common in selection systems. Germany, Austria, Japan and New Zealand also reward age in combination with education or professional experience through the points-based visas. Austria’s Red-White‑Red Card has a points system which awards points according to age, diminishing up to age 50; points for younger candidates are also added in Germany’s Opportunity Card. Australia has an age ceiling of 45 for its permanent immigration economic pathways, and Canada’s points system penalises older workers, but neither country has an age limit for temporary work pathways. Germany imposes a higher salary threshold for workers who are 45 years of age or older. Switzerland considers the age of the applicant when evaluating their ability.
Nationality is a consideration in 29 pathways. Some of these specify the nationalities in legislation. Others, more commonly, restrict use of the pathway to nationals of countries which have bilateral agreements (for example, Japan, Korea and Israel). Seasonal worker programmes may also have nationality requirements, and it is also, by definition, a feature in most cross-border work schemes. Table 2.3 summarises the list of countries, pathways and nationality requirements identified in this review. For example, the United States has specific pathways within its skilled migration programme for nationals of countries with which it has trade agreements. Slovenia has a pathway for Serbians and Bosnians. Australia and New Zealand have pathways for nationals of Pacific nations.
In other cases, the pathways assign nationalities on a unilateral basis, separate from any agreements with the origin country. For example, Germany has two distinct pathways limited to specific nationalities: one is dedicated to nationals of Western Balkans countries and is subject to a quota, while the other stream is open to nationals of Australia, Israel, Japan, Canada, New Zealand, Korea, the United Kingdom, and the United States, and is quota-free. Both are subject, however, to a labour market test. Poland has a provision for declaration by employers to hire nationals of Ukraine, Armenia, Georgia and Moldova, as well as Belarus and Russian Federation (the latter suspended). Mexico has residence and work permit pathways for nationals of certain border countries. The United States seasonal agricultural pathway is open only to nationals of countries where the overstay rate is below a certain level; this eligibility list can vary from year to year. Nationality may also be a consideration in the allocation of numerical limits for admission; this is not inherent to the channel, and is covered in more detail in Chapter 5. For example, Italy may decide to allow only certain nationalities in its annual flow decrees, but is not bound to do so.
Source: OECD Secretariat.
Many pathways that have nationality requirements are linked to bilateral labour agreements, which regulate labour migration between two countries by establishing specific rights and obligations. Box 2.3 discusses the role of BLAs in managing the admission of labour migrants.
A number of OECD countries have developed bilateral and multilateral frameworks specifically designed to facilitate international recruitment and admission. These arrangements go beyond standard migration agreements by embedding recruitment support, pre‑departure preparation, and in some cases training, into the migration pathway itself: 24 of the 41 countries surveyed participate in some form of bilateral or multilateral labour recruitment programme, though the depth, scope, and institutional design vary considerably. Bilateral labour agreements (BLAs) are one such arrangement, negotiated between two countries to set the terms – including eligibility requirements – under which nationals of one may access labour migration pathways in the other, and can shape which candidates come forward and are ultimately admitted.
Bilateral and multilateral recruitment frameworks in OECD countries broadly fall into three categories: BLAs with recruitment and facilitation provisions; skills mobility partnerships, such as EU Talent Partnerships, which combine legal pathways with pre‑departure training and job placement; and managed mobility schemes targeting specific regions or sectors. What distinguishes the most substantive of these arrangements – across all three categories – is their direct link to the admission decision: eligibility is shaped so that participation itself, through candidate selection, pre‑departure training, or government-to-government matching, is part of what determines who is admitted, rather than something employers and workers navigate independently afterwards.
The most developed BLAs go beyond establishing a legal basis for labour migration and eligibility criteria. They typically combine: pre‑screening and candidate selection in the origin country, narrowing eligibility to those most likely to succeed; pre‑departure preparation (language training, skills assessment, orientation); streamlined or dedicated admission channels for covered workers; and, in some cases, post-arrival support including return and circular mobility provisions.
Several examples illustrate this operational depth. Bulgaria’s agreements with Moldova, Armenia, and Georgia allow employers to recruit directly through the Employment Agency without separate work permit requirements, with recruitment co‑ordinated between national employment services. Israel’s agreements with Sri Lanka, India, Thailand, and the Philippines involve co‑ordinated government-to-government recruitment for caregivers and agricultural workers, with explicit provisions on selection, placement, arrival, and return. Japan’s Economic Partnership Agreement provisions with Indonesia, the Philippines, and Viet Nam establish structured eligibility pathways for care workers, with JICWELS as sole co‑ordinator matching candidates to accepting facilities.
Spain’s GECCO programme manages collective hiring of seasonal workers – mainly in agriculture and hospitality – directly in the country of origin, primarily with Morocco, Senegal, Mauritania, and several Latin American countries; employer associations co‑ordinate candidate selection with partner country employment services and manage logistics including housing and transport. Within GECCO, the WAFIRA programme adds an eligibility dimension for seasonal women workers in Morocco, supporting entrepreneurship upon return.
The PACER Plus Agreement and its Arrangement on Labour Mobility similarly frame labour mobility as shared economic benefit between Australia, New Zealand, and Pacific Island countries. Australia’s PALM scheme sets eligibility for employers to hire workers from nine Pacific countries and Timor-Leste where local labour is insufficient, particularly in agriculture and food processing. New Zealand’s complementary framework focusses on strengthening existing schemes, qualification recognition, and vocational training in Pacific Island countries.
By contrast, many bilateral agreements set eligibility only at the level of the legal framework – establishing which nationals may access a given labour migration pathway – without building in the recruitment infrastructure that shapes who actually applies or succeeds. Croatia, Greece, Portugal, and Luxembourg all have such agreements in place, but they stop at this legal basis, leaving candidate selection, preparation, and matching outside the scope of the agreement itself.
Separate from any technical and professional skills, an additional requirement that may be placed on the worker is language ability. Most temporary labour migration pathways covered in this analysis do not have a language requirement. English-speaking countries are where language requirements are most frequently found (See Table 2.4). Australia, New Zealand and the United Kingdom require a minimum level of English proficiency across most of their pathways. Pathways for non-professional workers in Japan and Korea include some basic language requirements. Japan requires SSW Level 1 applicants to pass a Japanese language test (A2 level), and Korea’s EPS non-professional pathway requires basic knowledge of the Korean language, using a test developed specifically for this pathway. While not a strict eligibility criterion, several countries award points for local language proficiency through their point-based systems, including Austria, Germany, Korea, Japan, New Zealand, and the United Kingdom. Austria also awards points for language skills in English, French, Spanish, and several other European languages.
Language proficiency requirement in selected temporary labour migration pathways
Source: OECD Secretariat.
Alongside the education and skills of the worker, one of the main eligibility criteria used in pathways are salary thresholds (OECD, 2014[4]). Salary thresholds are widely used to govern labour migration in OECD countries, notably for skilled streams. Around 80% of the 89 skilled temporary labour migration pathways analysed for this study apply some variation of a salary requirement or floor. Salary thresholds can be the main policy lever to govern labour migration admissions in certain systems, such as Sweden, where no formal LMT, SOL, or quota applies. It may also be the means for defining skilled workers. For example, Finland’s specialist permit does not mandate a specific degree; instead, it requires that the worker possesses expertise – acquired through education or experience – that the employer values sufficiently to reflect in a high salary. In practice, this makes the salary the operative threshold, with educational attainment playing no independent filtering role. Similarly, when introducing a new single immigration regime in 2021, the United Kingdom dropped its longstanding LMT requirement for skilled migrants, making salary thresholds the primary tool in determining admission – although the occupation skills requirement remains as an additional threshold.
Similar to qualification thresholds, salary requirements vary in stringency. Beyond the universal requirement to meet the minimum wage, the salary may have to meet the specific minimum wage foreseen in a collective bargaining agreement for the relevant occupation and sector. Australia, Canada, the United States, and the United Kingdom rely on the prevailing wage or going rate for the occupation, which is set based on the average wage paid to similarly employed workers in a specific occupation or region.
Median salaries are also used as a gauging tool, with salary thresholds set as a percentage of the median salary in a country or in a specific occupation. The objective is to anchor the threshold directly to labour market conditions – ensuring that the salary offered is commensurate with the position claimed and that employers do not undercut local wages through international recruitment. Among the pathways reviewed, only Canada (TFWP), New Zealand, and Sweden use this model. Sweden is the only EU country to do so, having introduced a median wage benchmark in 2023. Initially set at 80% of the national median salary, the threshold was subsequently raised to 90%, with a reduced rate of 75% applying exclusively to designated shortage occupations. This applies in addition to Sweden’s existing requirement that salaries meet the level set by collective agreements or common practice in the relevant profession or industry.
In Europe, salary thresholds are commonly established as a multiplier of the average gross salary. The EU Blue Card, for example, sets the range in which countries can establish salary thresholds. The first version of the Directive set the threshold at 1.5 times the average salary, with possible exceptions for shortage occupations; the recast Directive granted more flexibility – from 1 times, to 1.6 times, the average salary, with 0.8 times for certain categories. This flexibility explains why multipliers range, from the gross annual salary in Romania and Slovenia (0.8 time this benchmark for recent graduates and certain shortage sectors) to 1.6 times this amount in Greece, Sweden and Poland. Comparing the impact of these salary thresholds across countries, however, is not simple. In countries with narrow salary distribution, a smaller percentage of workers earn more than the threshold, making it more restrictive. In countries with a broader distribution of salaries, a larger share of workers earns more than the multiplier (OECD/European Union, 2016[5]). Further, countries with a large share of lower-qualified workers with lower wages are more likely to see higher-qualified workers earn above the Blue Card threshold, while countries where the workforce has a high share of qualified workers are likely to see fewer qualified workers earning above the threshold. This means that the EU Blue Card may be more accessible in certain countries than others, which is a key policy factor to consider for a pathway that facilitates EU-wide mobility for holders.
In some OECD countries, rather than relying on a single national floor, salary thresholds are tied to occupational codes, setting minimum wages based on the prevailing salary for a specific job. The United Kingdom’s Skilled Worker pathway exemplifies this model. It utilises Standard Occupational Classification (SOC) codes to establish a “going rate” that a job offer must exceed to qualify. Türkiye’s work permit applies a tiered salary threshold system that differentiates between senior executives, engineers and architects, managers, jobs requiring expertise and mastery and domestic work, applying progressively lower multipliers of the gross minimum wage at the time of application.
The widespread adoption of salary thresholds reflects the relative simplicity of this policy lever, and the fact that can complement or substitute other tools used to verify occupational skill level while protecting local wage standards.
However, occupation-specific thresholds also face challenges. They require detailed and regularly updated data on the labour market that may not always be available or that could have lags. They are also prone to classification errors or manipulation, with employers purposefully utilising codes with lower salary requirements. They can thus require more detailed assessments; if authorities must verify job descriptions and contracts, this may increase processing times. In some cases, salary thresholds may require post-enforcement verification, to make sure that employers are paying foreign workers the wages they declared in the application. The Netherlands introduced a stricter requirement for its Knowledge Migrant Scheme in 2026, asking sponsors to save proof of receipt – and not just payslips – of salary payments to foreign workers. Finland has an automatic and real-time risk identification system which crosses Incomes Register payroll data and social insurance data with minimum income requirements for the relevant work permit category to flag cases of insufficient remuneration.
Recent graduates may be disproportionately penalised by salary thresholds. Certain OECD countries have opted for tiered salary thresholds to compensate for this, allowing young people or recent graduates to qualify. The EU Blue Card, the Netherlands’ Knowledge Migrant Scheme, and the United Kingdom’s Skilled Worker pathways are examples of this approach, with lower salary thresholds for workers who have recently obtained a tertiary degree or are below a certain age. One concern with a lower wage threshold for young people is that they employers will fire them when they age into the higher threshold or decline to hire people just above the age threshold; an evaluation of the Dutch experience suggests that this was not occurring, even with an almost 40% increase in the threshold upon turning age 30 (OECD, 2016[6]).
Salary thresholds can also be combined with other admission policy levers like the LMT or SOL. Belgium, Ireland and Israel exempt employers from the LMT requirement in their general employment permits if they offer salary above a certain threshold. The logic here is that if the employer is willing to pay a salary significantly above the market rate, domestic recruitment is likely not an option. Ireland, for example, exempts its LMT requirement on the General Employment permit if the minimum annual remuneration for the role is EUR 68 911 (2026), almost double the standard administrative salary threshold (EUR 36 605); both are set based on consultation, but not strictly calculated on the average salary.
Another type of requirement that countries can use to judge eligibility are sectoral or occupational requirements. Their main objective is to delineate the types of vacancies foreign workers can occupy, based on where labour market gaps have been identified or where talent attraction is seen as desirable.
There are several different ways of applying occupational requirements. Some OECD countries apply them by level of responsibility, facilitating pathways for executive, managerial, and specialist roles. The logic here is that the high level of these positions – normally matched by high salaries, even if no salary threshold is imposed – usually reflect skills or talent that cannot be easily recruited domestically. Employer discretion in defining who is at this “executive‑managerial” level plays an important role. Australia’s Skills in Demand visa, for example, has a specialist skills stream that channels managers and professionals based on occupational code, giving educational requirements a less central role. Switzerland also limits its L and B permits to managers, specialists and other qualified roles. The Belgian region of Flanders, and Costa Rica, both have managerial/executive streams through their temporary residence and work permits.
Countries can also offer occupation-specific pathways for professions in high demand, such as engineers or medical professionals, with often very specific educational and recognition requirements. Japan’s framework for admission of skilled workers is built around separate pathways according to broad occupation groupings – engineers, specialists in the humanities, among others. France, Ireland, Korea, and the United Kingdom have specific pathways for medical and pharmacy professionals, nurses, and health workers. Korea and Japan have specialised pathways for educational professionals. The EU Blue Card, as noted, established more flexible requirements for ICT professionals, allowing them to substitute formal qualifications by demonstrating professional experience in the field.
Other countries establish occupational requirements based on occupation lists (covered in detail in Chapter 5). These lists can be used to facilitate, restrict or define the scope of a labour migration pathway. Shortage occupation lists are used to identify occupations experiencing labour shortages where labour migration is judged an acceptable response. Austria’s RWR Card for skilled workers in shortage occupations, Flanders’ bottleneck occupations/medium skilled permit, Australia’s Core Skills Stream (Skills in Demand Visa) are all examples that use an SOL to establish eligibility. In these pathways, it is necessary to have a job offer in an occupation on the list in order to even be considered for admission.
Negative lists, on the other hand, identify occupations that are excluded from certain pathways (Table 2.5). They normally include sectors or occupations that are protected or for which there is sufficient supply in the resident labour force. Costa Rica’s List of non-recommended occupations, Ireland’s Ineligible Occupations List, Hungary’s Banned Occupations List, and Türkiye’s Professions Reserved for Citizens are examples of negative lists used in OECD countries. These lists identify occupations where recruitment is altogether denied. In other cases, there may be occupations which are not allowed for certain pathways as exceptions to a general labour market access. This is the case in Korea, where employment under the F‑4 visa (for non-citizens of Korean descent) is prohibited for many specified elementary occupations and for those considered as violating public morals (OECD, 2019[7]). Poland introduced, in 2025, the possibility for each of 340 regional authorities to create a list of “protected professions” where third-country nationals may not be recruited through labour migration pathways. New Zealand uses lists to raise the threshold for eligibility for permanent residence.
Negative Occupation Lists in OECD countries, 2026
Source: OECD Secretariat.
Another notable category is sector eligibility. In a number of OECD countries, labour migration pathways are tied to specific sectors of activity. Sector eligibility is generally – but not always – applied to pathways where qualifications and education requirements are low or minimal.
Israel, Japan and Korea are the OECD countries where temporary labour migration pathways for workers who are not highly qualified are largely sector-based. These countries allot work permits in their principal pathways only for employment in specific sectors. In Israel, sector restrictions were introduced in the 1990s following a sharp increase in the number of foreign workers, to limit authorisation to three sectors: live‑in care, construction and agriculture. The latter two were subject to numerical limits. The sector approach was linked to a model of employment through sector-specific manpower and placement agencies, rather than direct employment. The number of sectors allowed has increased in recent years to include the hospitality sector, nursing homes and manufacturing, although the three main sectors remain the same.
Korea also takes a sector model, especially for its main non-professional pathway, the Employment Permit System (E‑9 visa). Only certain sectors are allowed to use the EPS, primarily manufacturing, agriculture and fisheries, and construction. Starting in 2023, shipbuilding has been added. The sector restrictions are coupled with numerical limits and conditions on eligibility for firms.
Japan’s Specified Skilled Worker programme began in 2019 with 12 industries or sectors (Manufacturing, agriculture and fisheries, construction, food service and food processing, etc.). The pathway is structured around skills which correspond to specific roles within the sector.
Sector-specific pathways are also predominant in seasonal labour migration pathways, where admission is tightly tied to clearly defined economic activities and time‑bound labour needs. Across OECD countries, seasonal schemes are limited to agriculture, horticulture, forestry, fishing, and tourism‑related services. The core sector for seasonal work is agriculture, although tourism is frequently also covered. France, Spain, Poland, Romania, Slovenia, and the United Kingdom restrict seasonal permits to agriculture and hospitality. Year-round agricultural work is usually excluded; for example, Norway applies a functional test to ensure that the job is genuinely seasonal, explicitly excluding routine farm work or maintenance tasks that occur year‑round.
Outside Europe, similar patterns emerge: Canada’s SAWP and primary agriculture streams are limited to a detailed list of activities and select occupations under the National Occupational Classification (NOC) system; Australia’s PALM scheme primarily focusses on agriculture related food processing (meat, seafood, fruit and vegetable processing), aged care, hospitality and tourism sectors. There is a current pilot into early childhood education and care (ECEC). The United States H‑2A visa limits access to temporary agricultural employment linked to specific production cycles.
In addition to imposing eligibility criteria on the worker and on the job, many pathways also consider the eligibility of the employer itself. Employers may be held to minimum standards in terms of capital requirements, turnover, the duration the organisation has been in operation, or number of employees – to reflect its genuineness and capacity to ensure stable employment and meet payment requirements. Compliance history is usually part of eligibility – especially to verify the absence of recent cases of violation of labour or immigration law.
Beyond these considerations, there can be restrictions on eligibility according to the sector of activity, described above, limiting the possibility of recruitment through labour migration pathways to firms operating in certain authorised sectors.
Specific eligibility criteria for international recruitment may take into account the share of resident employees of the employer. A number of pathways examined impose employer‑level caps, numerical limits that restrict the proportion or number of foreign workers an individual employer may hire (Table 2.6). Unlike system‑wide or programme‑specific ceilings, these caps, used in nine OECD countries, regulate whether, and how many, workers can be hired by specific firms, influencing how foreign labour is distributed across firms and sectors rather than how many workers enter overall. Their main function is to prevent concentration of migrant workers within companies, ensure that employers continue to invest in recruiting and retaining local staff, and reduce vulnerabilities associated with heavy reliance on foreign labour. These thresholds operate at the firm level and are sometimes differentiated by sector, firm size, skill category, or local labour market conditions. As a result, employer‑level caps are often used in areas where there is strong and persistent employer demand for lower or mid‑skilled roles, and where regulators aim to balance flexibility for employers with safeguards for the labour market. Some caps refer to all foreign workers, or non-EU/EEA workers in EU countries, while others, such as Canada’s, only take into account foreign workers holding temporary work permits.
Employer-level caps are relatively infrequent in EU countries, with only Bulgaria, Croatia and Ireland imposing them. They are more prominent in Latin American OECD Members such as Chile and Mexico, where controls focus on maintaining balanced workforce composition rather than setting system-level ceilings. Chile applies a 15% cap on the share of foreign employees for firms with more than 25 workers, with exemptions for foreign nationals who have stronger integration ties or specialised skills, illustrating how employer caps can be paired with social and economic considerations. Mexico enforces a 10% limit for foreign workers in technical and professional occupations, while Türkiye applies a 5:1 rule, requiring employers to hire five national workers for every foreign worker, with exceptions for foreign‑invested, high‑tech, strategically important firms, and persons under temporary protection. Canada’s Temporary Foreign Worker Program (low‑wage stream) limits most employers to 10% low-wage TFWP positions per worksite, with a higher 20% ceiling in shortage‑affected sectors, while exempting agriculture and caregiving roles where local recruitment challenges are systemic. Canada has also included a temporary exemption, where provinces and territories can opt-in to measures that enable employers with rural work sites to hire low-wage workers beyond the 10% limit.
Employer-level numerical limits in select OECD countries
Source: OECD Secretariat.
Korea implements several types of firm eligibility conditions. The E‑9 visa is allowed only for employment in SMEs, within certain sectors. Company‑level quotas apply across several visa categories, including E‑7 Specialty Workers, E‑9, E‑8 Seasonal, and H‑2, often limiting foreign hiring to 20% of the domestic workforce and adjusting thresholds by firm size, insurance contributions, and sector.
Exceptions across countries can be obtained, for specific firms, especially those related to foreign direct investment and operating in innovative sectors.
In most pathways, the employer must be a single firm where the worker is directly employed. Intermediaries and employment agencies are not allowed to recruit through the labour migration pathway. A number of pathways, however, allow manpower firms, intermediaries or placement agencies to be the employer. This is the case in Israel, in the construction and agricultural sectors, to address the need for mobility of workers among sites and multiple workplaces. It is also the case in a number of seasonal agricultural programmes, where co‑operatives and agricultural collectives are allowed to be the employer, in order to place and move workers among farms of different sizes and manage the crop and harvest cycles. In Spain and Italy, for example, agricultural co‑operatives are allowed to be the employer.
Across the pathways analysed, educational, salary, and occupational requirements are rarely applied in isolation. Instead, most labour migration systems rely on combinations of these criteria to jointly govern access to specific pathways and calibrate their level of selectivity. Educational thresholds are often used to signal baseline skill levels, salary thresholds to proxy labour market value and prevent undercutting of wages, and occupational or sectoral requirements to steer admissions toward priority jobs or shortages. Table 2.7 presents 89 labour migration pathways aimed at highly skilled workers across OECD and EU countries. While data were collected for about 220 pathways at all skill levels, Table 2.7 focusses on highly skilled pathways – those that countries designate specifically for skilled professionals, managers, and executives – because these are typically subject to the widest combination of eligibility requirements, making them the most suitable basis for examining how educational, salary, and occupational criteria interact. General skill permits, which cater to a broad range of workers without specific skill or occupational targeting, are excluded from this table but covered throughout the report. Annex Figure 2.A.1. in the Annex of this chapter provides a detailed review of each threshold by pathway, with specific salary thresholds.
Note: Pathways considered “for highly skilled workers” exclude pathways primarily used for general labour migration schemes unless these are the main admission pathway for highly skilled workers.
Source: OECD Secretariat.
Overall, salary thresholds are the most prevalent eligibility criterion, followed by occupational and educational requirements. Of the pathways shown in Table 2.7, 66 (74%) impose a salary threshold, compared with 60 (75%) that include an occupational requirement and 58 (65%) that require some form of educational qualification.
In these 89 pathways for higher skilled migrants, eligibility criteria are most often combined rather than applied in isolation (Figure 2.2). 39 pathways (43%) simultaneously require an educational threshold, a salary threshold, and an occupational requirement, indicating the tendency to combine these requirements, particularly in highly skilled admission channels. By contrast, 10 pathways (11%) rely on salary thresholds alone, without formal educational or occupational restrictions; these are concentrated in employer‑driven or flexible high‑skill schemes (e.g. pay‑limit or fast‑track models).
Salary, occupation and education requirements in 89 skilled migration pathways
Note: See Table 2.7 for pathways.
Source: OECD Secretariat.
Educational requirements are rarely the sole eligibility criterion. Only a small minority of pathways omit salary thresholds while retaining educational criteria, reflecting the widespread use of wages as a complementary filter. Occupational requirements also show substantial variation: while they are present in nearly three‑quarters of pathways overall, they are notably less common among certain implementations of the EU Blue Card and general employment permits, where education and salary are used as the primary filters. This partly reflects a classification question: the EU Blue Card requires “highly qualified employment” as a condition, which some Member States interpret and implement as an explicit occupational restriction (for example, restricting to occupations classified in certain occupational codes) while others treat it as a skill-level proxy.
Across EU countries in the table, salary thresholds are almost universal for highly skilled pathways, including the EU Blue Card and national high-skilled permits. However, occupational requirements vary significantly. Several Member States apply the EU Blue Card without explicit occupational restrictions (e.g. Germany, Italy, Spain, Sweden, Latvia, Lithuania, Romania), relying instead on education and salary as proxies for skill. In contrast, countries such as Belgium, Austria, Portugal, Poland, Hungary, and Slovenia consistently combine salary thresholds with explicit occupational or skill‑level definitions, either through defining “highly qualified employment” or shortage‑based lists.
Countries that maintain several parallel national high skilled pathways – such as France, Belgium (Flanders), the Netherlands, Portugal, Hungary, and Japan – tend to include explicit occupational requirements alongside salary thresholds. This is especially evident in schemes targeting managers, specialists, researchers, or innovation‑related roles. In these systems, occupational specificity is used not only to define eligibility but also to segment the high‑skill intake across multiple pathways.
In countries such as Australia, Canada, the United Kingdom, New Zealand, and Israel, occupational requirements are widespread, but formal educational thresholds are more frequently relaxed or differentiated. For example, Australia’s Skills in Demand and regional visas, Canada’s Global Talent Stream, and the UK Skilled Worker framework rely on occupation lists and salary benchmarks, allowing education to be substituted with experience in some cases. This contrasts with many EU systems, where formal degrees remain more central.
Japan and Korea have some of the strongest occupational gating among the pathways analysed. Nearly all high‑skill and specialist pathways are tied to specific professional categories or legally defined activities, even when salary or educational requirements are absent. This reflects institutional labour market structures where migration status is closely aligned with specific job functions.
Where general or single permits impose no limits on occupations (e.g. Estonia, Sweden, Italy), stricter targeting tends to re‑appear in parallel specialist, shortage, or sector‑specific schemes. This indicates that occupational requirements are often reallocated across pathways, rather than abandoned altogether.
Denmark, Sweden, and Estonia stand out for their wage‑centric approach, with multiple pathways that impose salary thresholds but no educational or occupational requirements (e.g. Denmark’s Pay Limit schemes, Sweden’s Employee permit, Estonia’s specialist and startup routes). Finland and Norway, by contrast, combine all three requirements more frequently, particularly for specialist and skilled worker permits. This suggests a divide between systems that treat wages as the primary signalling mechanism and those that still rely on formal skill or occupation definitions.
Overall, the data confirms that eligibility design is cumulative. Most of the pathways covered in Table 2.7 combine at least two requirements, and nearly half apply all three, reinforcing the role of layered admission rules in calibrating selectivity. This pattern underscores why comparisons across pathways must account for the joint effect of multiple thresholds rather than focussing on any single criterion in isolation. Box 2.3 analyses the case of the EU Blue Card and how its eligibility criteria may be competing with other pathways.
The EU Blue Card was designed to be the premier instrument for attracting high-skilled talent to the European Union, offering intra-EU mobility, easier family reunification and access to EU long-term resident status as some of its main benefits. National permits may still be offered, although they do not provide the same long-term benefits. To examine the extent to which national permits may be acting as functional substitutes or competitors in terms of the threshold for eligibility, it is necessary to compare salary, education and occupation requirements.
Most Member States offering national schemes have lower salary thresholds, broader occupational definitions, or more flexible education requirements than those established for the EU Blue Card. Table 2.8 compares which pathway has lower thresholds or more attainable eligibility requirements. Of the 23 OECD countries and candidates that have adopted the Blue Card, only Bulgaria and Greece lack a separate national permit designed for highly skilled workers. In 14 of the remaining 21 countries, the national pathways have national permits with more flexible or lower thresholds than the Blue Card.
This creates a layered admission system. The Blue Card serves a segment of top-earning professionals, while national permits accommodate a broader range of skilled workers. Rather than replacing national systems, the Blue Card remains one of several options. High thresholds may be one factor limiting its use, by unintentionally shifting demand toward national permits. In filing applications, the employer or worker may favour national permits if there are fewer criteria, even if in principle the job and worker could meet the stricter Blue Card criteria. In other cases, such as Luxembourg, where most applications are for jobs where salary and qualifications meet the Blue Card threshold, the Blue Card becomes the default permit. Other factors such as relative processing time, labour market test exemptions, and general awareness of the scheme, could also impact its request among applicants.
Comparison of eligibility criteria in select EU OECD countries
Note: For a detailed overview on how educational, salary, occupation and experience requirements compare for the Blue Card across EU countries, please see Annex 2.A.
Source: OECD Secretariat
Each country reviewed has a patchwork of basic eligibility criteria for admission of labour migrants. Several countries exclude labour migrants from occupations without formal educational or skill requirements, except through seasonal work programmes. However, the absence of explicit educational thresholds does not guarantee access to workers without formal qualifications, as occupational restrictions or matching rules may still apply.
Characteristics of the job offer – especially occupation and salary – appear to be the main eligibility criteria. This is not surprising, since the review in this chapter covers temporary labour migration channels, where immediate labour market demand takes precedence over human capital considerations. Language requirements in these channels are generally associated with the ability to perform the job, as are education and – where relevant – the need for recognition of qualifications.
The exclusion of occupations and sectors from eligibility does not mean there are no labour needs in these occupations or sectors. Most OECD countries have continuous policy discussion around skills thresholds, salary thresholds and approved and negative occupation lists, which are in continuous evolution and adjustment. Defining where labour migration is appropriate, and limiting admission along these lines, is behind the eligibility criteria. These same criteria can affect demand for international recruitment, as employers plan workforce policy around the possibility of filling positions – or not – through migration.
Sectoral requirements are most pronounced in seasonal and lower‑skill pathways, where access is confined to a narrow set of activities – predominantly agriculture, tourism, fisheries, and related industries – and where authorities can apply checks to ensure the temporary and task‑specific nature of employment.
A basic difference across the pathways is whether the eligibility criteria regarding skills and education represent evidentiary thresholds – elements which can be provided to authorities as proof of satisfying criteria – or whether the suitability of the skills and education is left largely to the discretionary judgment of the employer. Pathways where eligibility is based on the educational attainment or proof of skills of the worker represent the first approach. Pathways where no specific proof of educational attainment or proof of skills is requested of the worker represent the second approach. In the second approach, however, there is still a requirement to possess skills, with the employer judging that the worker has an adequate skill level. Clear evidentiary thresholds are central to the EU Blue Card, for example, which requires proof of education or experience, while many of the other high-skilled pathways covered in this chapter assume that the employer is hiring a migrant worker who meets the requirements of the position.
Eligibility criteria are generally not imposed in isolation, but in combination. Across 89 high-skilled pathways examined, 46% combine education, salary, and occupational requirements simultaneously. In these cases, the consideration is that no single criterion can sufficiently proxy skill and productivity while still providing adequate protection of the resident labour market. Within the EU, eligibility criteria for high-skilled labour migration are shaped by a layered architecture of EU-level frameworks – primarily the EU Blue Card – and national instruments.
While educational requirements remain widely used for researchers and high-skilled professionals, many pathways allow professional experience to substitute for formal degrees, especially in technical fields such as ICT. When recognition of qualifications for regulated professions is required, conditional or partial admission models – where workers may enter while recognition is still underway – are starting to appear, to address the often long times for recognition and the frequent need for in-work experience to complete the recognition process successfully.
Salary thresholds are present in 82% of the high-skilled pathways analysed, but much less common in pathways for occupations at lower skill levels. Calibration challenges have led to tiered thresholds across professions, seniority, age and duration since graduation, complicating design.
Most countries do not have occupation-specific pathways, although some exist for managers and executives, or for healthcare professionals. A number of OECD countries establish lists of authorised occupations – either allowed or disallowed. The logic of shortage occupation lists, related to the determination of occupations for eligibility for admission, is discussed further in Chapter 4.
Overlapping eligibility filters interact, as reflected in uptake patterns. For highly qualified migrants offered high-skilled employment, there are often more than one pathway. Significant differences in threshold calibration may provide employers with a choice between options, and to default to the simplest option – the one with the lowest evidentiary requirement – regardless of the conditions associated with the pathway. The relationship between the EU Blue Card and national high-skilled permits across EU Member States provides an example. The recast Blue Card Directive provides a common floor – setting educational, salary, and occupational eligibility requirements for highly qualified employment – but national high-skilled pathways coexist alongside it, sometimes with more lower thresholds or requirements. As shown in Table 2.8, in 14 of 21 Member States reviewed, national pathways have more easily attainable eligibility requirements than the Blue Card. The 2026 Recommendation on Attracting Talent acknowledges this fragmentation and encourages Member States to ensure that their national frameworks are coherent with and complementary to EU instruments.
The eligibility criteria covered in this chapter determine the baseline possibility for admission of a labour migrant. In the chapters that follow, the tools examined – the labour market test, shortage occupation lists, and numerical limits – operate on top of the eligibility channel to determine which candidates are selected and in what numbers.
References
[2] Atanassov, R. et al. (2023), Verlorene Pflegefachkräfte: Wann die „Auflage“ einer Ausgleichsmaßnahme das Anerkennungsverfahren ausbremst und wie Abbrüche vermieden werden können, Bundesinstitut für Berufsbildung (BIBB), Bonn, https://res.bibb.de/vet-repository_781373.
[3] European Parliament and Council of the European Union (2016), Directive (EU) 2016/801 of the European Parliament and of the Council of 11 May 2016 on the conditions of entry and residence of third-country nationals for the purposes of research, studies, training, voluntary service, pupil exchange schemes or educational projects and au pairing (recast), Official Journal of the European Union,.
[1] Ministry of the Interior and H. (Denmark) (2025), Information on a New Legislative Amendment with Impact on the Migration of Health Care Workers in Denmark, Indenrigs- og Sundhedsministeriet, Copenhagen, https://um.dk/media/0ysl5omb/handout-on-autorisation-of-nurses-from-third-countries-in-denmark.pdf.
[7] OECD (2019), Recruiting Immigrant Workers: Korea 2019, Recruiting Immigrant Workers, OECD Publishing, Paris, https://doi.org/10.1787/9789264307872-en.
[6] OECD (2016), Recruiting Immigrant Workers: The Netherlands 2016, Recruiting Immigrant Workers, OECD Publishing, Paris, https://doi.org/10.1787/9789264259249-en.
[4] OECD (2014), International Migration Outlook 2014, OECD Publishing, Paris, https://doi.org/10.1787/migr_outlook-2014-en (accessed on 3 March 2026).
[5] OECD/European Union (2016), Recruiting Immigrant Workers: Europe 2016, Recruiting Immigrant Workers, OECD Publishing, Paris, https://doi.org/10.1787/9789264257290-en.
Source: OECD Secretariat.