Summary of Key Changes
Major updates under ZTuj-2I and ZZSDT-E include:
- Alignment with the EU Blue Card Directive:
- Simplified access to highly qualified employment, including for non-university graduates with verified professional ICT qualifications.
- Reduced salary threshold from 1.5× to the average annual gross salary in Slovenia.
- Shortened minimum employment contract duration (from 1 year to 6 months).
- Streamlined procedures for holders of EU Blue Cards issued in other EU member states;
- Start of employment before obtaining a Single Permit: The option to employ a foreign national based on the certificate of submission of the application for the first Single Permit and the consent of the Employment Service for certain professions, provided that the worker enrolls in Slovenian language courses;
- In-country first-time applications: Foreigners will be able to apply for the first residence permit and submit fingerprints at the administrative unit in Slovenia;
- New type of temporary residence permit for digital nomads
- Extended permit validity: the maximum validity of the first Single Permit is extended from 1 year to 2 years, validity for reewals in extended from 2 years to 3 years;
- Expanded family reunification rights: Immediate family reunification now applies to digital nomad permit holders, Slovenian descendants (second-generation), and holders of temporary protection under the ZZZRO;
- Broadened grounds for long-term visas (D-visas);
- A new condition for the Employment Service’s consent: that the employer has not dismissed workers on business grounds in the past six months, except in certain exceptional
- New ground for refusal: the reason that the employer’s company was established or operates primarily for the purpose of facilitating the entry of third-country nationals.
- Introduction of a lump-sum compensation to which the worker is entitled in the event of the revocation of the single permit due to specific reasons on the part of the employer.
Amendments related to EU Blue Card
Under ZZSDT-E, an EU Blue Card may now be issued to ICT managerial workers (SKP-08 code 133) or ICT specialists (SKP-08 code 25) who demonstrate high professional qualifications. A foreign national will be able to demonstrate high professional qualifications by submitting proof of:
- having been legally employed for at least three of the past seven years as a managerial worker in the field of information and communication technology services, or as an information and communication technology professional, which may be demonstrated by:
- a certificate issued by an official authority of the country of employment confirming that the individual was legally employed and socially insured with one or more employers in the past seven years, or
- a certified translation of a certificate or certificates issued by the employer(s), indicating the positions held and the duration of employment, in cases where no official authority exists in the respective country to issue such a certificate as mentioned above;
- or an opinion pursuant to Article 20.b of ZZSDT, confirming that the individual has relevant professional experience at a level comparable to higher education qualifications, which are relevant to the profession specified in the employment contract.
The employer must request the opinion of the appointed expert and also bears the cost of obtaining the opinion. The appointed expert shall issue a written opinion within 30 days. If the expert fails to issue the opinion within this period, the employer may request an opinion from another appointed expert.
The original proposal of the ZZSDT-E regarding the condition that the foreign national must have been legally employed for at least three of the past seven years as a managerial worker in the field of information and communication technology services or as an ICT specialist did not specify that the foreigner can prove this only with a certified employer’s certificate in cases where the relevant country does not have an official institution issuing proof of employment and social insurance. We believe that such limitations will make it extremely difficult to provide the necessary evidence. For example, in the United States — a country where many foreigners applying for the EU Blue Card have worked — there is no comparable employment and social insurance record such as Slovenia’s ZZZS insurance extract or ZPIZ record of pensionable service. In our experience, obtaining proof of inclusion in the U.S. social security system under the Social Security Agreement (so-called Certificate of Coverage) can take more than six months. Furthermore, the U.S. Embassy does not issue confirmations that certain documentation from the U.S. cannot be obtained.
We believe that requiring documentation from countries whose legal systems are not comparable to Slovenia’s imposes an unreasonable burden on employers and foreign nationals, as such documentation may not be obtainable at all or cannot be obtained within a reasonable timeframe. It is unclear why a foreigner would not be allowed to prove their experience through employer statements, supplemented if necessary with additional documentation such as an employment contract, payslip, or similar.
Moreover, it is unclear why only employment in the form of a formal employment relationship would count toward the required professional experience, while work performed under civil law contracts would not be accepted.
The provision requiring the appointed expert to issue an opinion on the foreigner’s professional experience within 30 days — with the option for the employer to turn to another expert if the deadline is missed — is, in our view, inadequate. The newly appointed expert then also has 30 days to issue an opinion, meaning this preliminary stage before submitting the EU Blue Card application could take up to 60 days. The employer has no legal protection if the opinion is not issued on time, yet bears the cost and faces uncertainty about the overall duration of the procedure (including this preliminary phase).
The ZZSDT-E also shortens the required duration of the employment contract from one year to six months and lowers the required minimum salary, which is currently set at 1.5 times the average annual gross salary.
Additionally, the ZZSDT-E introduces a provision allowing EU Blue Card holders, after one year of employment, to also engage in self-employment or independent professional activity as a supplementary activity.
ZTuj-2I introduces an obligation to process simultaneously the application for a residence permit for a family member of an EU Blue Card holder and the EU Blue Card application itself, provided both applications are submitted at the same time.
The changes related to the EU Blue Card will enter into force on 21 July 2025.
These provisions take effect on July 21, 2025.
Temporary Residence Permit for Digital Nomads
ZTuj-2I introduces a digital nomad permit (modeled after Croatia’s framework) for non-EU/EEA nationals. A digital nomad eligible to apply for this permit is a foreign national who is not a citizen of the EU or EEA, and who is either employed or performs work based on a civil law contract for a business entity established outside Slovenia, or is self-employed abroad, performing work remotely through communication technology.
It is important that neither the foreign national nor their employer or the business entity with whom they have a civil law contract receives income from, or directly engages in sales or service provision within the Republic of Slovenia.
A condition for issuing the digital nomad residence permit is that the foreign national must have monthly funds in an amount equal to at least twice the average monthly net salary in the Republic of Slovenia, as most recently published in the Official Gazette.
According to the proposal, a foreign national who is lawfully residing in Slovenia may also submit the application at an administrative unit, which will issue an official certificate, serving as a temporary residence permit until a final decision is made on the application.
The temporary residence permit for a digital nomad will be issued for a maximum of one year, and cannot be extended. After a six-month break, the foreign national will be able to apply again for a digital nomad temporary residence permit.
Effective from November 21, 2025.
Lump-Sum Compensation for Workers
The amendment ZZSDT-E introduces a lump-sum compensation to which a worker is entitled in the event of the revocation of a single permit due to a fine imposed for certain violations of labour and migration legislation.
The lump-sum compensation, amounting to three times the gross minimum wage as most recently published in the Official Gazette of the Republic of Slovenia, must be paid by the employer or the contracting party. If the payment is not made, the worker may claim the compensation before the competent court.
Register of Violators and Prohibition of Employing Foreign Nationals
The amendment ZZSDT-E introduces a register of employers who are prohibited from employing or engaging foreign nationals or providing services, which will be publicly available until the expiration of the prohibition period.
Extension of the Right to Immediate Family Reunification
The amendment ZTuj-2I extends the right to immediate family reunification, previously granted to holders of EU Blue Cards and ICT permits, also to:
- holders of temporary residence permits for digital nomads;
- foreign nationals of Slovene origin up to the second degree in the direct line, who have been issued a temporary residence permit under Article 48 of the Foreigners Act (ZTuj-2);
- and foreign nationals who resided in Slovenia immediately prior to obtaining a residence permit on the basis of temporary protection granted under the Act on Temporary Protection of Displaced Persons (ZZZRO).
It also enables family members of foreign nationals who are entitled to immediate family reunification to receive a certificate of application from the competent authority, based on which they may reside in Slovenia until a final decision is made on the permit, provided that the family member is already lawfully residing in Slovenia at the time of application.
The extended right to immediate family reunification will apply as of 21 November 2025.
Changes in Residence and Work Permit Procedures
Commencing Work Based on the Certificate of Application and Employment Service Consent
The ZZSDT-E amendment allows employment and commencement of work prior to the issuance of a final Single Permit, based on a certificate confirming submission of the application and the consent of the Employment Service, for professions and sectors determined by the Minister of Labour.
The certificate will be issued if the application is accompanied by:
- a valid travel document, valid for at least three months beyond the intended stay, and
- a criminal record certificate from the foreign national’s country of origin.
In such cases, the employer is obliged, within the first six months of employment, to ensure the foreign worker attends and completes at least 80 hours of a nationally recognized adult education program for learning Slovene, during working hours and free of charge.
The employer must submit proof of compliance to the Employment Service within six months. This deadline may be extended by the Employment Service upon written notice if objective reasons prevent the worker from attending.
Given the obligation for employers to ensure Slovene language training (at their expense and within working hours), this measure could be made available to all foreign nationals and employers willing to meet this additional condition.
The essential eligibility criteria will be assessed already at the stage of issuing consent and the certificate of application.
Possibility to submit fingerprints and first-time applications in Slovenia
The ZTuj-2 amendment expands the possibility to submit a first-time application for temporary residence at an administrative unit in Slovenia, for example, if the foreign national is already lawfully residing in Slovenia.
Additionally, it introduces the possibility for the applicant to submit fingerprints within Slovenia if the application was submitted in Slovenia and the applicant is lawfully residing there.
Until now, a foreign national was required to file a first-time application at a Slovenian embassy or consulate abroad.
(For single permits, the employer could already submit an application at a local administrative unit.)
However, this was not the case for temporary residence permits, except in rare, exceptional circumstances.
This change significantly simplifies the process for foreign nationals who can enter Slovenia without a visa or who are already legally staying in Slovenia on a visa, as it eliminates the need to travel back to their home country or to Slovenian consulates in neighboring countries to provide fingerprints.
This new procedure for fingerprinting at administrative units in Slovenia will be introduced within six months of the entry into force of ZTuj-2E, i.e. from 21 November 2025.
Additional Conditions for Issuing a Single Permit
the ZZSDT-E amendment introduces an additional condition for the Employment Service’s consent to a single permit:
The employer must not have dismissed any employees for business reasons in the past six months who met the conditions for the same job position.
However, exceptions apply if:
- the employer guarantees the foreign national a salary of at least the average gross monthly wage from the previous year in Slovenia, or
- it can be demonstrated during the consent procedure that none of the dismissed workers are registered as unemployed and meet the conditions for the open job position.
This condition is problematic, as it is unclear how the Employment Service will verify whether an employer dismissed workers for business reasons. A more reasonable approach would be to limit the condition to mass layoffs.
Furthermore, it is unclear how an employer could verify whether a former employee is listed in the unemployment register, as the employer has no legal access to such data.
Additional Rejection Grounds
The ZTuj-2I amendment introduces a new ground for rejecting a residence permit application: if the employer’s company was established or operates primarily to facilitate the entry of third-country nationals.
Longer Validity of Permits
The amendment extends the maximum validity of the first Single Permit from 1 year to 2 years and the maximum validity of the renewed single permit from 2 years to 3 years.
The EU Blue Card can already be issued under the current regulation with a validity of 2 years, with a possible extension of 3 years.
However, for certain types of Single Permits, such as those for researchers, intra-corporate transferees (ICT), and seasonal workers, the validity of the Single Permit will not be extended.
Unlimited Duration of EU Citizens’ Residence Registration
The ZTuj-2I changes the validity of the EU citizens’ residence registration from 5 years to an unlimited period.
This means EU citizens will no longer need to renew their residence registration, thus reducing the burden on administrative units and relieving EU citizens from unnecessary renewals.
Expansion of Applicants for Single Permit for Posted Workers
The ZTuj-2I expands the eligible applicants for submitting an application for a single permit for posted workers. Now, the service recipient or economic entity based in Slovenia that the foreign national is posted to for training purposes can also submit the application.
This is not a new provision, as similar legislation had been allowed in the past.
Conclusion
The changes aim to implement Directive 2021/1883 and facilitate the process of obtaining permits and the employment of foreign nationals.
Given the shortage of workers in many sectors, these changes are significant and will reduce processing times, ease the workload of administrative bodies, and help foreign nationals and employers.
The success of these reforms will largely depend on how administrative authorities manage procedures and determine when the prescribed conditions are considered met.
