The recast single permit directive and what changes for employers in Slovenia

Directive (EU) 2024/1233 of 24 April 2024 recasts Directive 2011/98/EU on the single permit. Member states must transpose it by 21 May 2026. For employers in Slovenia three things change: a decision within 90 days, a right to change employer, and a protected period of unemployment that is not in itself a ground for withdrawal.

The recast creates no new document. The single permit for residence and work stays one application and one card, issued in Slovenia by the administrative unit under the Aliens Act (ZTuj-2) with the consent of the Employment Service of Slovenia. What changes is what the worker may do once the card is in hand, and how long the authorities have to decide.

What Directive 2024/1233 sets out

The first change is the period. Under the directive, a decision on a complete application to issue, amend or renew a single permit must be taken within 90 days, extendable by a further 30 days in complex cases. The period covers the whole chain of authorities rather than the last one to sign, and it runs only from a complete application. The incomplete file is therefore the one lawful way the clock does not start, and that pushes the work of assembling documents onto the employer.

The second change is the change of employer. The directive gives the permit holder the right to change employer during the validity of the permit. Where a member state requires notification of the change, the exercise of that right may be suspended for no more than 45 days from the notification, and within that period the competent authority may object. Once the period expires, the worker may start with the new employer.

The third change is unemployment. A period of unemployment of up to three months is not in itself a ground to withdraw the single permit, and the period is at least six months for a holder who has held the permit for at least two years. For unemployment longer than three months, a member state may require evidence of sufficient resources without recourse to the social assistance system.

How this lands in the Slovenian procedure

The Slovenian transposition touches two statutes: the Aliens Act (ZTuj-2) and the Employment, Self employment and Work of Aliens Act (ZZSDT). Until the amendments appear in the Official Gazette of the Republic of Slovenia, the existing national rules apply, so watch the notices of the Ministry of the Interior and the Ministry of Labour, Family, Social Affairs and Equal Opportunities before 21 May 2026. An employer planning arrivals for spring 2026 works under two regimes at once: the one in force when the application is filed, and the one in force at the first change of employer.

The cost side does not move with the directive. The administrative fee for issuing a single permit remains set by the Slovenian fees legislation, today in the range of a few tens of euros, and on top of it the employer pays for translations, certifications and recognition of qualifications where the occupation requires it. The real cost of the recast is staffing: someone has to track the 45 day period after a change is notified, and someone has to record the date a worker's unemployment began.

What to do before May 2026

The common mistake is to read the 90 day period as a faster arrival. The period runs from a complete application, and for occupations that are not exempt the labour market test remains a condition of the Employment Service consent. File without proof that the vacancy was advertised and the application goes back for completion while the clock stands still. How the same document behaves elsewhere in the union is set out in the single permit directive explained, and the parallel national picture is in the recast directive in Bulgaria. The chain of employer obligations that sits behind any sponsored permit is described in the EU employer sponsorship compliance chain.

Three steps are worth taking this year. First, count how many of your third country workers will hold a permit for at least two years in May 2026, because the longer unemployment period applies to them. Second, name the person who will notify a change of employer and count the 45 day period, since in practice that period sets the first working day with the new employer. Third, check that employment contracts do not restrict a change of employer more widely than the directive allows, because such a clause will not be enforceable after transposition.

Until the Slovenian transposition is published, the text of the directive is the most reliable guide to where the regime is going, and not the rule by which a given application is decided today. An application filed before 21 May 2026 runs under the current ZTuj-2, while a change of employer for that same worker a year later runs under the transposed rules. A 2026 arrivals plan therefore has to carry both dates, not only the nearer one.