By Jen Vosler
On 16 October the revised EU Blue Card Directive was a key topic covered at Permits Foundation’s Paris Roundtable and we were privileged to feature a presentation by the European Commission.
The revised EU Blue Card Directive, only recently implemented by all participating Member States, is significant because it offers a number of benefits, including for accompanying family members. In this article we provide an explainer of the elements that employers of highly qualified international employees with accompanying dependants should be aware of.
What is the EU Blue Card?
The EU Blue Card is a residence and work permit for highly qualified third-country nationals (TCNs), available in 25 EU Member States, excluding Denmark and Ireland.[i]
Which countries make most use of the EU Blue Card?
According to Eurostat data, the number of EU Blue Cards has been increasing since 2013, except for a dip in 2020 due to the COVID-19 pandemic. A record 89,037 EU Blue Cards were granted to TCNs in 2023; an increase of 8.8% from 2022. By far, Germany issued the most EU Blue Cards in 2023: 69,353; followed by Poland, France and Lithuania.
What is the history of the Blue Card?
The initial scheme, adopted in 2009, aspired to “address[] the consequences of demographic ageing” as well as “respond to . . . demands for highly skilled [TCNs in order] to offset skills shortages” and “enhanc[e] . . . intra-EU mobility.”[ii] In 2016, the EU Commission proposed reforming the initial scheme in order to streamline admission conditions and make the EU Blue Card an attractive option in light of parallel national options. Flash forward to 2021, when the revised Directive was adopted as part of the EU’s overall migration policy, aimed at attracting skills and talent and providing legal pathways to the EU.[iii]
The deadline for Member States to transpose the revised Directive into their national laws was 18 November 2023. Timelines tend to take longer in practice and Permits Foundation is happy to report that since 21 July 2025, all participating countries have (at least partially) enacted the revised Directive into their national laws.
What’s new?
Improvements in the new Directive include: more flexible admission conditions, enhanced rights and the possibility to move and work more easily between EU Member States.[iv] With a more accessible and attractive framework in place, it is hoped that the revised EU Blue Card can help to address skills shortages, labour markets facing demographic aging and help grow economies.[v] More EU Blue Cards will also provide greater rights/benefits to the highly qualified international employees that acquire them and their accompanying family members. By offering a single recognisable programme with a set of common rights that facilitates intra-EU mobility and access to EU long-term resident status, the EU becomes a stronger contender in the global competition for talent.
What changed for family members in the 2021 Directive?
The EU Blue Card has always included provisions that would enable work authorisation for accompanying family members but the revised scheme includes a number of further improvements that employers and relocating families may want to consider:
- Family member applications can be submitted at the same time as the one for the EU Blue Card.
- Family member applications must now be decided more quickly, within 90 days (down from 6 months).
- Family members now expressly have access to self-employment (subject to national standards).[vi]
- They also now benefit from mandatory cumulation of residence periods in various Member States for purposes of an autonomous permit.[vii]
- Intra-EU mobility with family is now faster and easier.[viii]
- Access to EU long-term resident status is clarified and enhanced.
Rising salary thresholds?
The revised EU Blue Card Directive sets a harmonised and capped range for salary thresholds across Member States. Specifically, the salary threshold must be between 1.0 and 1.6 times the average gross annual salary in the Member State concerned. This cap means that the threshold for EU Blue Card admission cannot exceed 1.6 times that average.
This ensures that the EU Blue Card remains accessible to a wider pool of highly qualified third-country nationals, while maintaining a high level of harmonisation and legal certainty across the EU labour market. Member States also have flexibility to set lower thresholds, for instance, for shortage occupations or recent graduates, further enhancing the scheme’s attractiveness and responsiveness to labour market needs.
What was Permits Foundation’s involvement in the Revised Blue Card?
Permits Foundation’s advocacy during the development of the revised Blue Card Directive helped to ensure that a mooted labour market test for accompanying family members was not included in the adopted version of the text. We continue to relay the employer perspective and the importance of direct work access for accompanying partners via representation in person and in writing to key representatives at the EU institutions. We also signal where we hear countries have not fully implemented the family clauses.
What further improvements at Member State level would be welcome?
The EU Blue Card Directive sets the minimum standard for recognised dependant family members of EU Blue Card holders as the spouse and the unmarried minor children. The fact that the Directive recognises accompanying family members is commendable but employers would welcome a broader definition of family members than is currently being recognised in many Member States. This is in line with global best practice, our international survey findings and reflective of the relocating families of today. Many partners are for example in same-sex couples or are not married but in durable relationships. Many families considering relocation would not leave behind parents or older children.
Work access barriers remain in certain countries
Although the Blue Card Directive is now officially transposed across all participating Member States, we understand that some countries are yet to provide direct work access (including self-employment), incident to dependant status, to accompanying spouses.
The Directive states that “access to work for spouses should be a fundamental element of this Directive in order to better attract highly qualified workers from third-countries”; and that family members shall have access to any employment, and self-employment in accordance with requirements under national law.[ix] The Directive further requires that Member States not impose time restrictions on family member access to the labour market. Permits Foundation continues to monitor implementation of the EU Directives with respect to partner work access. We have identified a handful of countries which may require extra measures for dependants before they can work, reducing the efficiency that the Directive intended.
- Bulgaria: recognised family members must first receive permission from the Executive Director of the Employment Agency before receiving access to the labour market, including self-employment. We believe the process requires the employer to submit a request for the permit along with justification for hiring a third-country national as well as upon demonstrating the foreigner has specialised knowledge, skills and professional experience for the respective position.
- Hungary: a preliminary employment contract is required and an employer-specific work permit must be applied for. If work authorisation is granted, dependant status must be relinquished (but can be regained).
- Romania: an employer-specific work permit is required.
- Slovenia: there is a labour market test and work authorisation must be granted, appears to be position/employer specific. Self-employment available after 1 year.
Permits Foundation continues to liaise with representatives from Member States and the EU institutions to improve the provisions within national and EU wide directives aimed at attracting talent and needed skills. We welcome feedback from employers as to how EU Blue Card Directive implementation is working in practice.
Summary
The revised EU Blue Card Directive, now implemented across all participating EU Member States, represents a major step forward in attracting and retaining highly qualified third-country nationals while improving conditions for their accompanying families. Originally launched in 2009 and reformed in 2021, the revised Directive introduces more flexible admission criteria, enhanced mobility between Member States, and expanded rights for family members, including faster processing times, access to self-employment and easier intra-EU movement. Permits Foundation played a key advocacy role in ensuring that a proposed labour market test for spouses was removed and continues to push for broader family definitions and universal work access for dependants. Despite the overall progress, some Member States still impose barriers to partner employment, which the Foundation continues to monitor and address to support employers and relocating families.
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[i] European Commission. (2025, April 1). EU Blue Card.
[ii] European Commission (2016). IMPACT ASSESSMENT regarding Proposal for a Directive of the European Parliament and the Council on the conditions of entry and residence of third-country nationals for the purposes of highly skilled employment and repealing Directive 2009/50/EC (see section 4.1 regarding General policy objectives and end note 115 stating objectives are in line with the 2007 Impact Assessment). SWD(2016) 193 final.
[iii] European Commission. (2021, May 18). EU Blue Card: Commission welcomes political agreement on new rules for highly skilled migrant workers. IP/21/2522.
[iv] Id.
[v] European Commission. (2025, January 22). Speech by Commissioner Šuica at the European Parliament plenary on EU demographic challenges: towards the implementation of the 2023 Demography Toolbox. SPEECH/25/369. “A working age population in decline comes with increased pressure on: labour markets, public budgets, Member States’ social welfare and pension systems, and our economies’ productivity. In a nutshell, demographic change affects Europe’s competitiveness.”
[vi] Directive (EU) 2021/1883 of the European Parliament and of the Council of 20 October 2021 on the conditions of entry and residence of third-country nationals for the purpose of highly qualified employment, and repealing Council Directive 2009/50/EC (“Revised EU Blue Card Directive”), Article 17(6).
[viii] Id., Article 22; see generally id., Recital (43), Article 15(3) (providing an incentive in practice to the EU Blue Card holder to engage more easily in intra-EU mobility after 12 months [and for its family members to follow him/her] due to the restriction of further labour market testing after 12 months).
[ix] Revised EU Blue Card Directive, Recital (50); Article 17(6).
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