Alignment with the new remuneration threshold

Following the adjustment of the average annual gross reference salary by ministerial order dated August 21, 2025, many of you have raised questions about the implications for your foreign employees.

ITAMA provides answers in this article.

As a reminder, the average annual gross reference salary now serves as the basis for setting the minimum salary thresholds applicable to several immigration statuses. As a result, the recent increase has led to a corresponding rise in the minimum salary requirements for the following statuses:

• “Talent – EU Blue Card”: from €53,836.50 to €59,373 gross per year
• “Talent – Qualified Employee” (intra-group mobility): from €38,621.60 to €39,582 gross per year

What are the consequences for your foreign employees?

• The new salary thresholds apply to all visa and/or residence permit applications currently under review by consular or prefectural authorities. For these cases, the proposed annual gross salary must be updated accordingly if you wish to proceed with the hiring. Otherwise, the application may be refused due to non-compliance with current requirements. The same applies to residence permit renewal requests for employees already within your workforce.

• The new thresholds also apply to current employees already holding a valid residence permit under the “(Passport) Talent – EU Blue Card” or “(Passport) Talent – Qualified Employee” status. Unless otherwise instructed by the Ministry of the Interior — which, to our knowledge, has not issued any such guidance — prefectures are enforcing the new thresholds as part of their standard compliance review plans. This means they may verify at any time that the conditions under which the permit was granted, including the salary level, continue to be met. In the worst-case scenario, failure to comply with the applicable salary requirements could lead to the initiation of a residence permit withdrawal procedure.

What should employers do?
You should promptly assess whether it is possible to align the annual gross salary of the impacted employees with the new applicable thresholds.Contrary to some information that may be circulating, this is not a matter that can be postponed until the employee’s residence permit is nearing expiration.

If it is not feasible to align the salary, it will be necessary to initiate a change of status procedure for the affected employee — either to another professional status or one that better reflects their personal situation.
This may also affect the spouse’s residence status, in some cases resulting in the loss of work rights.

Please feel free to contact our firm should you require support in managing these adjustments or the necessary procedures.