Employer Obligations When Hiring Non-EU Nationals
Employers who hire non-EU nationals in Lithuania have specific legal obligations under the ULSA and the Law on Employment. Failure to comply exposes the employer to significant administrative fines and, in serious cases, criminal liability.
Work permit application — the employer’s responsibility
The work permit application is made by the employer to the Lithuanian Labour Exchange — not by the employee. The employer submits the application, provides the required documentation (including the employment contract or a binding job offer), confirms that the employer has no grounds for refusal, and pays the state fee. The Labour Exchange assesses whether the employer meets the eligibility requirements and, where a labour market test applies, whether a suitable Lithuanian candidate was genuinely unavailable. Work permits are tied to the specific employer and the specific role described in the application — the employee cannot freely change employers or positions under the same permit.
Labour market test — when it applies
For most national work permit applications, the employer must demonstrate that no suitable candidate from Lithuania (or the EU/EEA) was available for the position. This is demonstrated by: advertising the vacancy with the Lithuanian Labour Exchange for at least 10 days prior to the work permit application; being unable to fill the position with a suitable Lithuanian or EU/EEA candidate; and documenting this process. The labour market test does not apply to EU Blue Card applications (which have a salary-based eligibility mechanism instead), to ICT applications (which concern intra-group transfers), or to positions on the list of occupations in shortage (deficit profesijų sąrašas) published by the Lithuanian Labour Exchange. We confirm whether a labour market test applies for each specific role before the employer begins the advertising process.
Employer notification obligations
Under Article 111 ULSA, employers are required to notify the Migration Department of changes in the employment relationship with non-EU nationals: the commencement of employment (within 5 business days); the termination of employment (within 5 business days); and any material change in the terms of employment (change of position, significant salary change, change of workplace). Failure to notify is an administrative violation with fines of €300–€3,000 for responsible officials and €500–€6,000 for the company.
Prohibition on employing without a valid permit
An employer who employs a non-EU national without a valid work permit and residence permit commits a serious violation under Article 124 ULSA. Penalties include: fines of €1,000–€30,000 per illegally employed worker; prohibition from receiving EU structural funds for up to 5 years; and in cases of repeated violation or exploitation, criminal liability for responsible directors. These sanctions apply regardless of whether the employer was aware of the immigration status issue — the obligation to verify the employee’s legal right to work rests with the employer.
The Immigration Application Process
We manage the complete immigration process for both employers and individual applicants. The process varies by immigration route — the steps below describe the national work permit route, which is the most common.
1
Route assessment and eligibility confirmation
We assess the individual’s qualifications, salary level, and employment situation to confirm the most appropriate immigration route. For Blue Card eligibility, we confirm whether the salary threshold and qualification requirements are met. For ICT applications, we confirm the intra-group transfer eligibility. For investors, we confirm whether the proposed investment meets the qualifying thresholds under Article 43(1)(9) ULSA.
2
Employer eligibility and compliance check
We confirm that the employer meets the eligibility requirements for submitting a work permit application — including no outstanding VMI tax debts, no labour law violations within the previous 12 months, and SoDra employer registration. An employer with unresolved compliance issues cannot obtain a work permit for a non-EU national.
3
Labour market test (where applicable)
Where a labour market test is required, we advise the employer on the Labour Exchange advertising requirement: posting the vacancy with the Užimtumo tarnyba for the required period, documenting the candidates interviewed, and confirming that no suitable Lithuanian or EU/EEA candidate was available. We prepare the documentation of this process for inclusion in the work permit application.
4
Work permit application to the Labour Exchange
We prepare and submit the complete work permit application to the Lithuanian Labour Exchange: employer details, employment contract or binding job offer, job description confirming the role and salary, employer eligibility declarations, labour market test documentation (where applicable), and the applicant’s qualifications documentation. The Labour Exchange has a statutory processing time of 30 business days.
5
D visa application at the Lithuanian consulate
Once the work permit is issued, the individual applies for a Lithuanian national long-stay D visa at the Lithuanian embassy or consulate in their country of residence. We prepare the visa application document set and advise on the consulate appointment process for the specific country. D visas are typically issued within 2–4 weeks of a complete application.
6
Residence permit application at the Migration Department
After arriving in Lithuania on the D visa, the individual applies for a temporary residence permit at the Migration Department. We submit the complete application: work permit, employment contract, D visa, passport, proof of accommodation in Lithuania, and health insurance. The Migration Department processes residence permit applications within 2 months of submission.
7
Biometric data and permit collection
The Migration Department notifies the applicant when the permit is ready for collection. The applicant attends the Migration Department office to provide biometric data (fingerprints and photograph) and receives the physical residence permit card. We accompany the applicant to this appointment and confirm that all permit details are correct.
8
Ongoing compliance — renewals and notifications
A temporary residence permit is typically issued for 1–2 years and must be renewed before expiry. We track permit expiry dates and initiate renewal applications 2–3 months before the expiry date. We also manage the employer’s Article 111 ULSA notification obligations throughout the employment relationship.
Immigration Routes Comparison
| Route |
Salary / Investment Requirement |
Labour Market Test |
EU Mobility Right |
Permit Duration |
| National Work Permit |
Minimum wage (€1,038/month min) |
Yes (with exceptions) |
No |
1–2 years (renewable) |
| EU Blue Card |
≥1.5× average (≈€2,850/month) |
No |
After 18 months |
Employment contract + 3 months |
| Startup Visa |
None — qualitative assessment |
No |
No |
Up to 2 years (extendable) |
| Investor Permit |
€14,000 company / €250,000 property |
No |
No |
1–2 years (renewable) |
| ICT Permit |
Comparable to Lithuanian employees |
No |
EU ICT mobility |
Up to 3 years (managers/specialists) |
| Family Reunification |
Sponsor’s income sufficiency |
No |
Follows sponsor |
Same as primary holder |
| Permanent Residence |
5 years legal residence |
N/A — no work permit |
Long-term resident status |
No expiry (renewed every 5 years) |
Standard Document Requirements
For the employer (work permit application to Labour Exchange)
- Completed Labour Exchange application form
- Certificate confirming no outstanding VMI tax debts (issued within 3 months)
- Copy of the company’s JAR registration extract
- Employment contract or binding job offer — signed by the employer; specifying role, salary, workplace, and start date
- Job description — confirming the duties and qualifications required for the role
- Documents evidencing the labour market test (where applicable) — Labour Exchange vacancy registration, candidate evaluation records
- State fee payment confirmation
For the individual (residence permit application to Migration Department)
- Valid passport (minimum 3 months’ validity beyond the intended stay)
- Passport-size photographs (in accordance with Migration Department specifications)
- Criminal record certificate from the country of origin and from any country where the applicant has resided for 12+ months in the past 5 years — apostilled and certified Lithuanian translation
- Valid work permit issued by the Labour Exchange
- Employment contract — signed by both parties
- Proof of accommodation in Lithuania — lease agreement, hotel booking, or employer-provided accommodation confirmation
- Health insurance — covering the application period until state health insurance (privalomasis sveikatos draudimas — PSD) activation through SoDra
- Educational qualifications (for Blue Card applications) — degree certificate with apostille and certified Lithuanian translation
- Application form and state fee payment confirmation
Translation and apostille — planning ahead
Documents issued outside Lithuania must be apostilled (under the Hague Convention) and accompanied by a certified Lithuanian translation prepared by a sworn translator. The apostille process takes 1–5 business days in most countries; the certified translation takes 3–7 business days. Documents that were not planned for early in the process — particularly criminal record certificates, which have a short validity period (typically 3–6 months) — frequently cause application delays. We provide a complete document checklist at the start of every engagement and coordinate translations through our network of VVKT-registered sworn translators.
Immigration Law Services Pricing
Our immigration services are priced at fixed fees per application. Government fees payable to the Labour Exchange, Migration Department, and consulates are separate and quoted in the engagement proposal.
| Service |
Price |
Immigration route assessment
Written assessment of applicable routes; document checklist; realistic timeline; total government fee estimate |
€1,000 |
National work permit — employer application (Labour Exchange)
Complete application preparation, Labour Exchange submission, and correspondence through to permit issuance |
€2,000 |
National D visa application support
Document preparation, translation coordination, and consulate appointment guidance |
€2,000 |
Temporary residence permit application
Full application preparation, Migration Department submission, appointment attendance, and permit collection |
€3,000 |
Full national work permit package (work permit + visa + residence permit)
All three stages coordinated as a single engagement; most cost-efficient option for the complete process |
€5,000 |
Startup Visa — Startup Lithuania concept submission
Business concept structuring, application preparation, and Startup Lithuania liaison |
€2,000 |
Startup Visa — D visa and residence permit
Full visa and permit application based on Startup Lithuania recommendation |
€2,000 |
Investor residence permit — full application
Investment documentation, Migration Department application, interview preparation, and permit collection |
€3,000 |
Permanent residence permit application
At 5-year milestone; full application preparation, 5-year residence evidence, Migration Department submission |
€3,000 |
Permit renewal (work permit or residence permit)
Renewal application preparation and submission; initiated 2–3 months before expiry |
€1,500 |
Document apostille and translation coordination (per document)
Coordinating apostille through the Ministry of Foreign Affairs and certified Lithuanian translation |
€80–€150 |
Government fees — not included above
Lithuanian immigration applications involve government fees payable directly to the authorities: the Labour Exchange work permit fee (€30 per application); the Migration Department residence permit fee (€120 standard processing, €240 expedited — 5 business days); and consular D visa fees (vary by nationality). We include all government fees in the initial cost estimate provided at the engagement proposal stage.
Frequently Asked Questions