On 14 May 2026, the Seimas adopted amendments to the Law on the Legal Status of Foreigners, introducing significant changes in foreigner employment.
Most of the amendments (with a few exceptions) came into force on 22 May 2026 and will have a direct impact on employers hiring third-country nationals. Below we outline the key aspects to which we recommend you pay attention.
1. Additional safeguards for foreign nationals holding a temporary residence permit on the basis of work
Until now, for foreign nationals holding a temporary residence permit on the basis of work as non-highly qualified specialists, the termination of the employment relationship automatically meant the revocation of the permit.
The new regulations introduce a more flexible model, providing greater stability for employees – if their employment relationship ends, they will be able to remain in Lithuania for a certain period and look for new work.
Important: this right applies only if the foreign national fulfils their obligation to notify the Migration Department in a timely manner. The notification must be submitted within 10 business days of the termination of the employment contract. It should be noted that if this notification is not submitted on time, the Migration Department will revoke the foreign national’s temporary residence permit.
If the foreign national exercises their right to seek new employment and submits a notification to the Migration Department in timely manner (i.e. within 10 working days of the termination of the employment contract), they are granted a period to find a new employer: 3 months, if the permit was issued less than 2 years ago, or 6 months, if the work-based temporary residence permit has been held for more than 2 years.
2. Foreigner’s registration certificate
Cases where a temporary residence permit has expired but a decision on a new permit has not yet been adopted are now more clearly regulated.
Until now, in such situations, foreign nationals, having no other legal basis to remain in Lithuania, were usually required to leave the country and terminate their employment.
From now on, foreign nationals who have submitted an application to renew their temporary residence permit in accordance with the established procedure and deadlines, or who hold a permit on one basis and have applied for a permit on another basis, will be able to remain in Lithuania and continue working for the same employer or carry out other lawful activities until the Migration Department has made a decision, even if their current permit expires whilst the application is being processed. In such cases, the foreign national will need to apply for a foreigner‘s registration certificate.
According to information provided by the Migration Department, this registration certificate will be digital. To obtain it, the foreign national will need to submit an application via the MIGRIS system, and the certificate will be generated in PDF format within 3 days of the application being submitted and sent to the foreign national’s personal account.
Although the aforementioned change came into force on 22 May 2026, we have not yet seen any technical capability within the MIGRIS system to submit an application for this registration certificate.
3. Stricter liability for employers
The list of cases when third-country nationals applying for temporary residence permits on the basis of employment (as non-highly qualified specialists) or for the issuance or renewal of an EU Blue Card will have their applications denied is being expanded due to violations committed by the employer.
Until now, such violations have included cases of illegal and undeclared work, as well as breaches of the procedures for employing foreign nationals. From now on, an additional restriction will apply if the employer has been fined at least twice in the past year for breaches relating to the notification on employed or posted foreign nationals.
Considering this, it is particularly important for employers to ensure that LDU notifications are submitted and updated in a timely manner.
Furthermore, the calculation of the restriction period is changing. Previously, it was calculated from the date the fine was paid, but from now on, it will be one year from the date the decision comes into force.
4. EU Blue Card and special leave
New legal regulations have been introduced regarding special leave for foreign nationals holding EU Blue Cards (temporary residence permits for highly qualified specialists).
Until now, it was unclear under what conditions such employees could take special-purpose leave without losing their EU Blue Card. In practice, there was a risk that, after taking special-purpose leave (e.g. for child care leave), the salary requirements would no longer be met, as the state benefits paid are usually lower than those stipulated for the EU Blue Card.
The new regulation introduces an exception whereby EU Blue Card holders may be not meet the salary requirement for a maximum of 12 months if this relates to maternity, paternity or childcare leave, illness or disability, as well as in cases where maternity, paternity or childcare benefits are paid. This exemption applies provided that the employment contract with the foreign national has not been terminated.
This 12-month period is calculated only for those months in which the salary or benefits received do not meet the salary requirements set out for the EU Blue Card.
5. Restriction on applying for a temporary residence permit on the basis of work with a Schengen visa
From 1 November 2026, a new restriction will come into force whereby foreign nationals entering Lithuania on a Schengen visa will no longer be able to apply in Lithuania for a temporary residence permit on the basis of work as non-highly qualified specialists.
This change will significantly reduce the opportunities for citizens of certain countries to obtain temporary residence permits on the basis of employment. This is because foreigners who are not in Lithuania can already only apply for such a permit in their country of nationality.
Consequently, in practice, this will become an additional restriction in cases where there is no external service provider centre in the country of nationality with which the Migration Department cooperates.
In turn, a foreign national in Lithuania will be able to apply for a work-based temporary residence permit (as a non-highly qualified specialist) only if they hold a valid temporary residence permit, a national visa (D) issued by Lithuania, a residence permit issued by another EU Member State, or if they are covered by the visa-free regime.
6. New restrictions on student work are being introduced
restrictions are being introduced on work for undergraduate (Bachelor‘s students in their first and second years. Such students will be permitted to work no more than 20 hours per week, except during the summer holiday period as determined by the educational institution and during the practical training period specified in the study programmes.
It is important to note that failure to comply with this restriction will have serious consequences – in such cases, it will not be permitted to renew a temporary residence permit, and existing permits will be revoked.
The law also provides for an exception: the aforementioned 20 hour-per-week restriction does not apply to foreign nationals who were issued a temporary residence permit on the basis of studies before 21 May 2026.
However, employers are advised to treat this exception with caution, as there is no clear position on situations where:
- the permit was issued before 21 May 2026, but the person is employed after that date;
- a foreign national was employed on a full-time basis under this exemption and subsequently applies for a change of permit, and the new permit is issued after the aforementioned date.
In view of this, in our opinion, when hiring new employees, it is recommended not to rely on this exception and to adhere to the 20-hour-per-week limit.
It is important to remember that it is the employer’s responsibility to ensure that the foreign national is entitled to work in Lithuania and to verify the number of working hours per week. Therefore, an employer intending to employ a foreign national holding a temporary residence permit on the basis of studies for more than 20 hours per week must ensure that this is permitted under the current legal regulations.
7. Changes to the conditions for obtaining a temporary residence permit on the basis of work as a non-highly qualified specialist
Instead of the two alternative conditions that previously applied, employers will now need to choose at least one of the three conditions listed below so that a foreign national can apply for a temporary residence permit on the basis of work as a non-highly qualified specialist:
- Has qualifications relevant to the work to be performed, or
- Have at least 1 year’s work experience in the last 3 years related to the work to be performed, or
- The employer undertakes to pay the foreign national a monthly salary of no less than the average monthly gross salary in the country’s economy for the calendar year, as last published by the State Data Agency (including data from sole traders), which currently stands at EUR 2,411.40 gross per month.
It should be noted that previously these conditions did not apply to foreign nationals who had completed their studies or formal vocational training in Lithuania, provided that no more than 10 years had passed since the completion of their studies. Under the new regulations, this period has been reduced to 5 years.
