Admitting Labour Migrants

7. How do recognised employer mechanisms work?

Abstract

This chapter focusses on the different forms of recognised employer mechanisms, including trusted and accredited employer systems, that countries utilise to speed up the admission of labour migrants hired by particular categories of employer. It compares the programmes’ eligibility requirements and benefits, as well as the conditions and obligations placed on sponsors. The rules on maintaining and preserving status are also covered.

Recognised, trusted or accredited employer mechanisms (REM) are an admission policy tool to streamline the recruitment of foreign workers through a simplified or more efficient process. Their main objective is to reduce the administrative burden on immigration authorities and employers. They serve as a fast-track channel because authorities review and approve employers in advance. By pre‑verifying that companies adhere to regulatory compliance standards – often higher than the general standards – authorities can speed up the review and approval process.

REM effectively outsource part of the verification process to the employer. Because the government has already verified the firm’s legitimacy, it can skip or simplify intensive checks (e.g. labour market test, qualification checks) for each specific role, allowing businesses to hire faster, and immigration authorities to focus their resources on non-accredited – possibly higher risk – applications.

REM are usually structured around three main elements: eligibility requirements, benefits and obligations of the sponsor status, and programme conditions. Companies are accepted into these programmes based on characteristics such as experience with international recruitment, past compliance record or financial stability. The benefit is usually faster processing, simplified applications or LMT exemptions. Programme characteristics include the complexity and duration of the recognition process, the validity period of the status and the possibility of renewal.

However, REM are used in different ways across OECD countries to speed up admission and meet labour demand. If well-designed, in some cases they can even help strengthen the integrity of the labour migration system. The structure, characteristics and implementation of REM depend on how they are used. This chapter examines the various forms of these schemes and how they influence the decision to admit labour migrants.

How are recognised sponsor mechanisms used?

Across OECD countries, trusted employer schemes are used selectively but strategically. 15 member countries implement them in at least one of their temporary labour migration pathways – almost always high-skilled. Many EU/EEA countries utilise these schemes exclusively for their highly qualified, specialist pathways. For example, Portugal utilises a certification model for its “Tech Visa” and not for its subordinate employment and seasonal worker pathways. Similarly, Denmark’s fast-track scheme is only available for high-salary professions.

Recognised employer schemes are relatively uncommon among EU Member States, with only Denmark, Finland, Hungary, Italy, the Netherlands, and Spain having implemented them for temporary labour migration pathways. Among these, Finland, Italy, the Netherlands, and Spain have extended their arrangements to the EU Blue Card, providing expedited processing and reduced documentation. Hungary is a notable exception: while it operates a preferential employer scheme, this applies exclusively to guest-worker pathways and does not extend to the Blue Card or other high-skilled routes. However, even where Blue Card applications benefit from recognised employer arrangements, these advantages do not uniquely position the Blue Card, as the same administrative shortcuts are available through the corresponding national high-skilled pathways.

The EU legislative framework explicitly supports the use of recognised employer mechanisms for highly qualified worker admissions. The Recast Blue Card Directive (EU) 2021/1883 establishes an optional recognised employer framework under Article 13, allowing Member States to apply simplified procedures for approved employers – including exempting applicants from certain documentary requirements – and setting a statutory processing time of 30 days for applications submitted through recognised employers, compared to the standard 60‑day deadline. More recently, the European Commission’s Recommendation on Attracting Talent for Innovation, adopted alongside the first-ever EU visa policy strategy on 29 January 2026, has reinforced this direction. Under points 7 and 8 of the Recommendation, Member States are encouraged to use Article 13 of the Directive to exempt applicants from documents already verified by recognised employers – such as proof of accommodation, diploma translations, proof of sickness insurance, and labour market tests. The Recommendation encourages the implementation of simple, fast, transparent and digitalised application procedures to incentivise highly qualified and skilled workers.

In contrast, Australia and New Zealand use their Accredited Sponsor Schemes widely across all skill levels. However, their administrative functions differ. While Australia’s status is an optional premium tier for employers to access faster processing, New Zealand makes it a requirement to hire temporary labour migrants, with distinct tiers – standard, high-volume and triangular accreditation – for different employer needs.

REM are largely absent from temporary labour migration pathways in Asian and Latin American OECD countries. The only exceptions are Japan’s “Excellent supervising/implementing organization” applied to the Technical Intern Training Programme, Costa Rica’s company certification programme, and Mexico’s Employer Registration Certificate (CIE).

A limited number of systems utilise trusted sponsor mechanisms to regulate the admission of seasonal workers (e.g. Canada, New Zealand, the United Kingdom). In these cases, the schemes are especially important to verify compliance with labour law and labour protection standards. One of the most common features of this type of scheme is facilitated admission for returning workers or multi-year permits.

Different types of trusted sponsor mechanisms

While the general objective of REM is to expedite the admission of foreign workers to meet labour needs, countries apply them in different ways to cater to specific policy objectives. Table 7.1 classifies schemes based on the logic behind certifying an employer as recognised or trusted.

Table 7.1. Classification of recognised employer schemes

By governance logic

Category	Streamlined processing in exchange of…	Countries
Enhanced compliance schemes	Earlier, deeper compliance checks	Australia, Canada, Denmark, Finland, Japan, Mexico, the Netherlands, New Zealand, the United Kingdom (Skilled Worker licence)
Strategic economic schemes	Investment in strategic industries or fulfilling broader economic aims	Costa Rica, Czechia, Hungary, Italy, Spain, Portugal1
Growth and innovation schemes	Reward top performers	United Kingdom (Scale‑Up sponsor), Portugal

1. Portugal’s tech visa can be considered a borderline case between the performance‑based and strategic economic objectives categories as they employ both logics to certify employers.

Source: OECD Secretariat.

The great majority of OECD countries that utilise trusted employer schemes implement them as a form of enhanced compliance that facilitates and speeds up the admission of foreign workers. By submitting to prior vetting, employers benefit from streamlined processing, as well as greater confidence in being able to have a successful outcome of their application. In many cases, authorities rely on recognised employers to verify that workers fulfil education, salary, occupational, or language requirements, rather than conduct their own documentary review. These schemes may also facilitate monitoring and post-enforcement measures, by requiring that employers agree to share additional data, allow random inspections, and participate in compliance checks.

The Netherland’s Recognised Sponsor scheme is an example of this model. The Dutch Immigration and Naturalization Service (IND) assesses the company’s reliability, labour compliance history, criminal record, and financial solvency. If the company is approved, it can lodge an application for a migrant’s permit and get a decision within 14 days. Authorities carry out an initial security check on the foreign worker but rely on the employer to verify other requirements. Employers are obligated to keep comprehensive records on each worker to prove they have fulfilled their duty of care as a recognised sponsor, including employment and qualification requirements (OECD, 2025[1]). Although the recognised status is only mandatory for the Knowledge Migrant pathway, companies can also use it for faster processing for other work permits, including the EU Blue Card. The cost for employers to become a Recognised Sponsor is between 2 400 and 4 800 EUR, depending on the number of employees.

Certain OECD countries use trusted employer schemes to provide additional support to employers in priority industries or sectors – export-oriented or innovative industries, tourism, finance, IT – who want to recruit internationally. They usually offer a simplified and streamlined application process, faster processing times, immediate work authorisation, and longer permit validity to facilitate talent attraction and stimulate investment. Costa Rica and Hungary follow this model, although the former focusses on high-skilled workers and the latter on the lower skilled guest work pathway. Czechia and Portugal also use this type of economically justified mechanisms to speed up processing. Box 7.1 delves into Costa Rica’s Corporate Accreditation scheme.

Box 7.1. Costa Rica’s Corporate Accreditation: Promoting investment through simplified immigration processing

Costa Rica’s Corporate Immigration Accreditation scheme is designed to facilitate the rapid entry of foreign talent recruited by companies that make significant contributions to the national economy, to support foreign direct investment and facilitate skilled labour attraction into strategic economic sectors. The scheme classifies companies into seven categories (A-G) based on the sector they operate in or their relationship with the government.1 It is reserved for highly qualified permits, namely: executive, managerial, and technical personnel, specialised employees, and scientists.

Although eligibility and evidentiary requirements vary, certified companies benefit from shorter processing times (30 business days), a streamlined application (corporate information kept on file, fewer documentary requirements), immediate job start and longer permit validity. Company eligibility is verified through different government agencies depending on the sector, a decentralised approach that facilitates expertise‑based vetting while preventing a single‑point bottleneck at the immigration office.

If approved, companies are added to the National Company Registry (Registro de empresas). In November 2025, the government launched the migration module of the Investment One‑Stop-Shop (VUI), a centralised digital platform that currently allows Category A (Special Export Promotion Regime) companies to bypass standard portals for even faster adjudication – often within two weeks. Following this pilot, the government is executing a phased rollout to onboard Categories B (Exporters) and F (Multinationals) by late 2026, with the remaining categories slated for integration throughout 2027. Notably, the entire certification procedure is free of charge, and the status is valid for four years. During this four‑year period, companies must maintain ongoing tax and social security compliance to remain in good standing; failure to do so can result in immediate suspension of the “trusted” status. At the end of the four‑year term, companies must undergo a formal renewal process to verify they still meet the volume and compliance thresholds required for their specific category.

1. The seven categories are: A. special export promotion regimes managed by the Ministry of Foreign Trade (COMEX), B. export-oriented industries and research institutions, C. tourism, D. finance and insurance, E. telecommunications, F. multinationals, and G. companies that have been awarded a contract by a public administration entity in Costa Rica.

Source: OECD Secretariat, Costa Rican Government, https://vui.cr/

Another form of REM is limited to high-growth or innovation-related firms. Companies that show high economic potential or are experiencing a sustained period of growth are facilitated in recruitment of foreign workers and supported in their talent attraction efforts because of the added value they bring to the economy. To qualify, companies are required to show strong financial results, a steady hiring record, or innovation potential. Portugal’s Tech Visa and the United Kingdom’s Scale‑Up Sponsor scheme fall under this category.

To qualify as a Scale‑up Sponsor, a company must prove sustained growth through HM Revenue and Customs data – at least 20% average annual growth in either turnover or headcount over the previous three years, starting that period with at least ten employees. This status provides two primary benefits: it exempts the employer from the Immigration Skills Charge, and it terminates formal sponsorship duties after the worker’s first six months, giving them access to an open work permit. Only skilled occupations with a high wage are eligible. Standard licence processing takes eight weeks, though a priority service offers a decision within 10 working days for an additional fee. The application cost is between EUR 660 and EUR 1 810 depending on company size. The fee applies for each individual Certificate of Sponsorship.

Box 7.2. Researcher permits and recognised host institutions

Several OECD countries utilise trusted sponsor mechanisms specifically for researcher pathways. Often seen as a channel for talent attraction and innovation, countries can facilitate researcher admissions through expedited processing for recognised host institutions. These schemes are most common among EU countries, thanks to the EU Students and Researchers Directive (2016/801), which introduced the possibility to provide for an approval procedure for public or private research organisations (or both) wishing to host third-country national researchers. This approval should be in accordance with the procedures set out in the national law or administrative practice of the Member State concerned. Applications to approved research organisations should be facilitated and should speed up the entry of third-country nationals coming to the Union for the purpose of research (or studies). If pre‑approved or recognised, approved research organisations can then carry out a hosting agreement with the foreign national that establishes their relationship and expedites the admission process. Host research institutions are responsible for verifying the qualifications and basic eligibility requirements, while immigration authorities retain the prerogative of rejecting an application on security grounds.

Countries instrument this in different ways. Finland, for example, allows research institutions to become certified employers if they fulfil the financial and hiring volume requirements. France, on the other hand, utilises the hosting agreement model: the Ministry of Higher Education and Research grants the status of trusted sponsor based on fiscal compliance, financial stability and capacity to host international researchers. Organisations must submit evidence of active research involvement and an assessment of the number of foreign nationals likely to be hosted. In return, they can hire foreign researchers without a work authorisation on the basis of a hosting agreement. This does not affect their labour status – they may or may not have an employment relationship with the host organisation – but exempts them from any work authorisation related review for their residence permit decision.

In Denmark, not covered by the 2016 Directive, the fast-track permit scheme allows researchers with a concrete job offer at a recognised research institution to access faster application processing. Universities, research institutions and even private R&D firms are eligible for certification through SIRI, the Danish Agency for International Recruitment and Integration. To be eligible, they must not be involved in legal labour disputes, have more than 10 full-time employees, must not have been convicted under the Danish Aliens Act more than twice, and they must offer salary and terms of employment that correspond to Danish standards. Additionally, they must participate in an online guidance meeting with SIRI to receive information about the conditions of the fast-track scheme. Recognition status is valid for four years and takes 30 to 60 days to be processed. In terms of benefits for the applicant, unlike the Danish pay limit and supplementary pay limit routes, researchers are exempt from any salary threshold. Researchers benefit from faster processing (same‑day to 10 days) and can begin work immediately upon a positive decision, before the physical permit card is issued – a distinct advantage from processing speed alone.1

Beyond residence permits for researchers, the EU has developed infrastructure that supports the mobility of researchers across Member States without requiring a harmonised recognised host institution framework. EURAXESS, launched in 2004 and backed by the European Commission and 43 participating countries, operates as a pan-European network of over 650 service centres that provide researchers and host institutions with information and support on 18 topics, among which admission procedures, hosting agreements, entry conditions and visas, social security rights, unemployment and compliance requirements across participating countries. EURAXESS does not perform compliance checks or vetting, but it demonstrates that a lightweight, network-based architecture can support cross-border co‑ordination and information exchange without requiring a centralised EU-wide accreditation system. Another very practical instrument is the HR Excellence in Research Award. It recognises organisations that not only commit to the European Charter for Researchers but also show that they are putting its principles into practice.

1. The processing time depends on whether a worker can legally enter Denmark at the time of application. If the worker is exempt from a visa requirement or has a Schengen visa, the process to obtain a residence and work permit is faster.

Source: 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), Pub. L. No. L 132, Official Journal of the European Union, (2016); OECD (2022[2]), Feasibility Study on the Development of an EU Talent Pool 2022, https://doi.org/10.1787/34c77584-en; OECD Secretariat

The building blocks of REM

As discussed in the previous section, the different types of REM are structured around certain building blocks to grant certification status, stipulate benefits and obligations, and establish monitoring and post-enforcement compliance. This section discusses these elements across OECD countries’ trusted sponsor schemes. Table 7.2 summarises recognised employer schemes found across the countries analysed for this study.

Table 7.2. Recognised employer mechanisms across OECD countries vary in features but provide clear processing benefits

Recognised employer mechanisms across OECD countries

Country	Recognised employer scheme name	Employer eligibility	Employer benefits	Worker benefits	Cost	Recognition timeframe	Validity
Australia	Accredited Sponsor	Strong compliance record; sponsorship history	Priority processing; simplified nominations	Faster visa processing	None	6‑8 weeks	NA
Canada	Recognised Employer Pilot (currently closed, scheduled to conclude in December 2026)	Frequent LMIA users; high compliance	Simplified LMIA; longer validity	Longer permit validity	None.	Not available	3 years
Czechia	Economic migration programmes	Participation in the programme. Worker must apply at specific consulates that have quotas by nationality	Priority processing at consulates	Faster visa processing	None	Not available	NA
Costa Rica	Certified Company	Certified under categories A – G	Fast‑track; immediate work start	Faster labour access	None	4‑6 months	2‑4 years
Denmark	Certification	Larger companies (inc. universities) ≥10 employees; high compliance	Fast‑case processing	Faster permits	EUR 810	~1 month	3‑4 years
Finland	Certified Employer	Financial stability (positive equity, at least EUR 1M average turnover); history of hiring int’l workers (at least 10 work-based permits in the past 3 years)	Simplified applications	Fast‑track; D‑visa	EUR 140‑ 195	1‑2 months	2 years (+ extensions)
Hungary	Preferential employer	Strategic government partner, high-priority investors, major exporters	Streamlined procedures (LMT exemption), expedited processing, bulk applications digital filing	Faster processing	None	Depends on partnership agreement (few weeks to several months)	As long as partnership agreement is valid
Italy	Memorandums of understanding with Ministry of Interior for simplified procedures	MoI and MoL verify economic capacity and compliance with collective bargaining	Less documentation required, no work clearance required. Administrative silence equals consent	Faster processing, no work authorisation required.	None	Depends on MoU	Indefinite/governed by MoU
Japan	Excellent organisation	≥60% excellence score	Higher trainee quotas	Up to 5‑year stay	None	Depends on company performance evaluation	3+ years
Mexico	Employer Registration Certificate	Registered employer	Hire foreign workers	Lawful employment	EUR 15	NA	1 year
Netherlands	Recognised Sponsor	Registered; solvent; compliant	Faster IND processing (14 days)	Faster permits	EUR 2 432‑ 4 866	~90 days	Indefinite, but can be revoked if not used for three years
New Zealand	Accreditation	Good workplace practices; financial stability; compliance with labour /immigration law	Pre‑vetted hiring	Reduced exploitation; faster	EUR 390‑ 2025	~2 weeks	12‑24 months
Spain	Administrative prioritisation through a specific government agency (Unidad de Grandes Empresas y Colectivos Estratégicos)	Any employer that complies with the regulations and is able to assume responsibility for the employment relationship. Recognition occurs at the time employer applies for permit (not a separate recognition procedure).	Expedited processing and positive administrative silence	Expedited processing and positive administrative silence	None	20 days	Indefinite
Portugal	Tech Visa	Innovative firms with growth potential, tax and social security compliance	Fast‑track; LMT exemption	Faster processing	None	≤30 days	2 years
United Kingdom	Sponsor licence	Genuine business; compliant with labour law, growth (Scale‑Up Sponsor)	Issue CoS	Access to sponsored jobs	EUR 660 – 1 810	~8 weeks	Compliance‑ based

Source: OECD Secretariat.

Eligibility requirements and process for certification

Governments verify diverse criteria to certify an employer as a trusted entity. While a clean record regarding labour and immigration law is a baseline for most work authorisations, trusted-employer schemes often impose more rigorous, forward-looking compliance standards that are demonstrated once at the certification stage rather than per application. Some countries exclude employers with any history of violations (e.g. Australia, Ireland, New Zealand), whereas others – like Denmark – maintain a “threshold-based” flexibility, permitting certification provided the employer has not received more than two fines under the Aliens Act within the preceding year, or a single fine exceeding DKK 60 000. Specific jurisdictions explicitly leverage the certification process to enforce worker protection; Canada’s Recognised Employer Pilot and New Zealand’s Accredited Employer scheme require proof of the “highest standards” for working conditions as a prerequisite. Conversely, the Netherlands utilises its “Recognised Sponsor” framework to focus on the institutional integrity of the company’s leadership, requiring board members and executives to provide formal declarations of reliability.

Many OECD countries, especially those using REM for strategic economic objectives, require applying companies to fulfil financial stability and turnover requirements, both to prove that they can host foreign workers and to contribute to economic growth or competitiveness. Costa Rica, the United Kingdom and Portugal’s schemes include this type of requirements.

Recruitment rates can also be a requirement for employers in economic-based schemes, although they can be used in different ways. The United Kingdom’s Scale Up Sponsor programme requires a 20% growth in a company’s headcount, to prove a company is developing rapidly and needs more workers to continue growing. In contrast, Australia’s Accredited Sponsor programme uses recruitment rates as a safeguard for the resident labour force, by requiring that at least 85% of the company’s workforce is Australian citizens or permanent residence. Moreover, some schemes only allow applications from companies that have a track record of recruiting foreign workers, which establishes both their need and experience with labour migration. Canada, Finland and Denmark have this type of requirement.

In terms of the process to become a trusted sponsor, most schemes require companies or research institutions to provide documentation to back up their eligibility. In practically all cases, these schemes are managed by immigration or labour authorities, which grant the status – with the exception of Costa Rica that distributes certification responsibilities across government agencies based on the company’s sector of operation.

In several countries, the procedure carries a specific fee, ranging from roughly 15 EUR in Mexico to 4 866 EUR in the Netherlands. This sharp divergence reflects different approaches. A large group of countries – Australia, Canada, Costa Rica, Italy, Japan and Portugal – do not charge an additional fee to certify an employer. Mexico and Finland charge what appears to be a relatively small or nominal fee to recover costs for the administrative procedure. In contrast, Denmark, the Netherlands, the United Kingdom, and New Zealand maintain the highest fees. In these cases, the fee may be directed not only at recouping costs, but at ensuring that only companies with a high recruitment need apply. In exchange they may offer more benefits – substantially shorter processing times, for example – or extended/indefinite periods of validity.

Benefits, obligations and enforcement measures

Through REM, governments usually exchange prior vetting and enhanced compliance for a variety of benefits for employers. The main benefit for companies is streamlined admission of labour migrants to meet their labour needs. However, other benefits can be attached to the status.

Procedural acceleration is the most common advantage of REM. Taking the form of priority-processing, fast-tracking or service standards, these schemes offer faster admission decisions. Australia, Canada, Denmark, Finland, among many others, use speed as their primary reward for certified employers.

Administrative simplification is another frequent advantage of trusted employer schemes. This benefit relies on lower documentation requirements, both for worker and employer eligibility. In some cases, employers must verify the worker’s legal eligibility and provide a formal statement of liability. Simplification can also include waiving requirements such as notarised copies, apostilles or certified translations. It may involve authorities keeping company information on file, to reduce the need of repeated checks of information. This type of benefit is present in Australia, Costa Rica, Denmark, Finland, and the Netherlands.

In certain countries, recognised sponsors benefit from extended permit validity, which can allow them to plan their recruitment needs with greater certainty. This is also a benefit for workers, since they need fewer renewals. Japan’s Technical Intern Training Program pathway allows companies recognised as Excellent Organizations to host trainees for the full five‑year period without having to temporarily return to their home country. Canada’s Recognised Employer Pilot (closed to new applications but still active for existing participants) allows for simplified LMIA processes and longer employment durations (up to 36 months for high‑wage positions), rather than extending Labour Market Test requirements.

Another benefit observed in these schemes is immediate work authorisation. This feature allows workers to start at their job without waiting for residence and work permit processing to conclude. Finland and Denmark fast-track schemes both have quick job start benefits, sometimes with same‑day processing for workers who do not require a visa.

In other cases, the certification has a “gatekeeping” function, determining whether recruitment can take place at all, or to access a specific pathway. New Zealand and Mexico make this a universal requirement for recruiting any labour migrant. The Netherlands’ Knowledge Migrant Scheme and the United Kingdom’s Skilled Work visa do the same, but for a specific pathway. Here, recognition is not a facilitation tool but an entry condition.

Another observed, although less common, benefit across OECD countries is the ability to recruit larger volumes of foreign workers with streamlined procedures. Again, Japan’s TITP allows “Excellent Supervising Organisations” to accept a higher percentage of trainees relative to full-time employment (10%).

Worker benefits are usually more limited, focussed mainly on faster processing of residence and work permits, faster job start facilities, longer permit validity periods, and additional protection from exploitation.

Most recognised sponsor schemes across the OECD require certified employers to maintain enhanced compliance with immigration and labour rights standards – including working and living conditions, workplace safety, and employee protection. In many cases, obligations also include a duty of care toward migrant workers, requiring sponsors to provide information on legal rights and local administrative procedures. The Netherlands illustrates how these obligations can be applied in practice: Dutch recognised sponsors assume full liability for the accuracy of all data submitted to the IND, must actively vouch for each worker’s eligibility during the application process, and are required to maintain comprehensive records for each sponsored worker for at least five years in preparation for government audits.

Post-enforcement measures are less frequent across the OECD, which reflects a fundamental tension in the design of these mechanisms. If an employer is initially trusted to access simplified admission for its workers, some form of ex-post verification is needed to ensure the scheme is not being abused – yet the very premise of recognised employer status is that intensive case‑by-case scrutiny has been replaced by upfront vetting. Countries have addressed this tension in different ways.

Some have implemented real-time auditing through digital systems. The United Kingdom requires sponsors to report changes in a worker’s circumstances in real time through the Sponsor Management System, creating a continuous compliance record without requiring on-site inspections. Australia’s approach is more comprehensive: its accredited sponsor scheme operates on a high-trust model in which fast-track processing is balanced by strict follow-up audits, combining automated data-matching with tax records, payroll document reviews, and unannounced workplace inspections. To further enhance transparency, Australia transitioned in April 2026 from a register of sanctioned sponsors to a comprehensive Public Register of Approved Work Sponsors, allowing real-time public verification of an employer’s legal standing to sponsor. Failure to meet standards results in significant fines, removal from the public register, or loss of accredited status – which forces the firm back to standard processing timelines. Other countries rely on more traditional on-site inspections: Mexico’s immigration and labour authorities can conduct unannounced verification visits to check that the company is operational, that foreign nationals are working there, and that labour regulations are being met.

As Box 7.3 illustrates, where post-enforcement mechanisms are weak or insufficiently resourced, the integrity of recognised employer schemes can be undermined, with consequences for both the quality of admission decisions and the protection of migrant workers.

Box 7.3. Government reviews and audits of recognised employer schemes

Recent public sector evaluations of trusted employer schemes across OECD countries have highlighted their need for administrative review. In 2023, the Inspector-General of the Netherlands Labour Authority criticised limits to compliance in the employer recognition process. It found that in many cases, failure to initially screen applications allowed non-compliant employers to participate and to bring workers in low-skilled jobs, underpay them, or even fail to employ them at all. Although using the Knowledge Migrant Scheme, certain employers were still able to hire workers in sectors that are not knowledge intensive. Intermediaries acting as payroll companies also were able to use the scheme, obscuring where individuals are actually employed.

The Inspector General suggested that IND and Labour Authority controls were insufficient, relying too much on ad hoc inspections and specific reports, instead of continuous oversight to check whether employer is keeping to the programme terms. Sanctions only entail fines, without expulsion from the programme. These highlight the importance of post-approval monitoring and penalties to ensure the scheme covers the intended group and prevent labour abuse.

Similar reviews in the United Kingdom and New Zealand further illustrate the risks of this type of programmes. A March 2024 report by the UK’s Independent Chief Inspector of Borders and Immigration (ICIBI) revealed that the Home Office issued vast quantities of Certificates of Sponsorship to employers with almost no effective prior scrutiny, effectively outsourcing the state’s vetting role to the sponsors themselves. This was compounded by a March 2025 National Audit Office (NAO) report, which found that data on how these certificates were monitored was “fragmented and incomplete” leading to a 2026 policy overhaul that reintroduced mandatory pre‑approval audits for high-risk sectors. Similarly, a 2024 Public Service Commission review of New Zealand’s Accredited Employer Work Visa (AEWV) found that the “high-trust” model – which relied primarily on employer declarations – led to a surge in migrant exploitation and visa fraud. These evaluations suggest that without continuous, data-driven oversight and credible consequences for non-compliant employers, these mechanisms can transition from an effective tool to a loophole for non-compliance.

Source: Nederlandse Arbeidsinspectie (2024[3]), Jaarverslag 2023, Ministry of Social Affairs and Employment, https://www.nlarbeidsinspectie.nl/publicaties/jaarverslagen/2024/03/27/jaarverslag-2023; J. Bestwick (2024[4]), A review of Immigration New Zealand’s administration of the Accredited Employer Work Visa Scheme, https://www.publicservice.govt.nz/publications/review-of-the-administration-of-the-accredited-employer-work-visa-scheme; National Audit Office (2025[5]), Immigration: The Skilled Worker visa route, NAO Report.

Key takeaways

Recognised employer mechanisms represent a particular approach to managing admission decisions: rather than verifying every application individually, authorities transfer part of the verification function to employers themselves. Once certified, recognised sponsors are expected to assess worker eligibility, vouch for compliance with admission requirements, and maintain records on behalf of the state. This outsourcing of verification reduces the administrative burden on immigration services and speeds up individual decisions – but it also shifts accountability. The quality of admission decisions becomes dependent on the reliability of employers, which makes the design of eligibility criteria, obligations, and post-enforcement mechanisms critical to the integrity of the scheme. In this sense, recognised employer mechanisms are not simply a processing tool but a governance choice about where responsibility for admission decisions sits.

The benefits of recognised employer schemes are not distributed evenly across employers or workers. On the employer side, certification requirements – compliance track records, financial stability thresholds, minimum hiring volumes – tend to favour large, established companies over SMEs and newer firms that may lack the history or resources to qualify. Several OECD countries impose minimum employee thresholds or significant fees that can deter smaller or less frequent recruiters. On the worker side, recognised employer arrangements tend to concentrate benefits on high-skilled roles, since most OECD countries limit these schemes to high-skilled or specialist pathways. Workers in lower-skilled or seasonal roles – who may face vulnerability to exploitation – are less likely to benefit. Canada and New Zealand are notable exceptions, having extended recognised employer logic to seasonal pathways precisely to strengthen labour protection standards.

For employers, the decision to seek recognised status involves a cost-benefit calculation that is not always straightforward. Certification processes vary considerably in complexity and cost – from Spain’s UGE channel, where recognition effectively occurs at the point of application with no separate procedure, to the Netherlands’ Recognised Sponsor scheme, which requires extensive documentation, financial scrutiny, and relatively high fees. Where certification is burdensome, smaller employers or those with occasional recruitment needs may find the process disproportionate relative to the benefits. Uptake is therefore likely to be higher where the gap between standard and expedited processing is large, fees are low or absent, and the recognition process itself is streamlined. The design of certification requirements should reflect the recruitment needs and administrative capacity of the intended employer population – schemes calibrated for large, high-volume recruiters may inadvertently exclude the employers they are most meant to serve.

The integrity of recognised employer schemes depends as much on what happens after certification as on the rigour of the initial vetting process. By design, these schemes reduce per-application scrutiny in exchange for upfront employer verification, but this shift only maintains the quality of admission decisions if post-enforcement mechanisms are sufficiently robust. The evidence reviewed in this chapter suggests this condition is not always met. Reviews in the Netherlands, the United Kingdom, and New Zealand have documented cases where weak monitoring allowed non-compliant employers to remain in schemes, with consequences for both admission integrity and migrant worker protection. The contrast between Australia’s model, which combines consent to automated data-matching, unannounced inspections, and a public register of approved sponsors, and systems that rely primarily on employer declarations illustrates the range of approaches available. Where post-enforcement is weak, recognised employer status risks becoming a pathway for circumventing standard admission controls rather than a quality filter within them.

Recognised employer schemes in the EU remain largely national instruments, with limited co‑ordination across Member States. Despite the legal basis already provided by the recast Blue Card Directive and the direction set by the 2026 Recommendation on Attracting Talent for Innovation, implementation varies considerably and information on vetted or sanctioned employers is rarely shared across borders. This fragmentation has practical consequences: employers operating across Member States may face repeated vetting processes, and a sponsor sanctioned in one country may encounter no obstacles to accessing recognised status in another. The Proposal for a Regulation establishing an EU Talent Pool also leaves the decision on how to determine which employers can participate to the national contact points. The EURAXESS network, discussed in Box 7.2, demonstrates that cross-border co‑ordination on employer recognition does not require full harmonisation. A decentralised, network-based architecture built on information sharing and mutual transparency can support more consistent outcomes even without a centralised EU-wide accreditation system.

Overall, these takeaways suggest that the value of recognised employer mechanisms depends less on their existence than on how carefully they are designed, for whom, and with what accountability structures in place.

References

[4] Bestwick, J. (2024), A review of Immigration New Zealand’s administration of the Accredited Employer Work Visa Scheme, Public Service Commission.

[5] National Audit Office (2025), Immigration: The Skilled Worker visa route, NAO Report.

[3] Nederlandse Arbeidsinspectie (2024), Jaarverslag 2023, Ministry of Social Affairs and Employment, https://www.nlarbeidsinspectie.nl/documenten/2024/03/27/jaarverslag-2023 (accessed on 27 March 2024).

[1] OECD (2025), Improving the Economic Migration Framework to Attract and Retain Qualified Talent in Flanders, OECD, Paris.

[2] OECD (2022), Feasibility Study on the Development of an EU Talent Pool 2022, OECD Publishing, Paris, https://doi.org/10.1787/34c77584-en.