The developments in professional immigration in 2025 illustrate France’s constant tension: the economic need for labor and protection of foreign workers on one hand, and the political will to control migration flows and protect public order and the national labor market on the other. For companies, this “French schizophrenia” translates into growing administrative complexity.

Within the inter-ministerial committee on immigration and integration launched in 2019, the State aimed to simplify certain schemes to attract highly qualified foreign talent and address sectoral shortages. Strategies included:

• Digitalization of work authorization applications
• A nationwide efficiency-oriented organization
• Simplified eligibility criteria
• Updated shortage occupation lists
• Forward-looking planning to attract rare skills

At the same time, sanctions against illegal work and labor exploitation were toughened, and inspections by URSSAF, the Labor Inspectorate, and other agencies increased.

In contrast, recent months have brought a tightening of residence rules, controls, and access to regularization. Administrative hurdles now abound: chronic dysfunction of digital platforms, inconsistent prefectural practices, and informal ministerial instructions that add extra-legal requirements.

The result: unintentional breaches of rights for migrants, increased litigation, and employers left uncertain about their obligations.

This article reviews the latest legislative, regulatory, and judicial developments and sheds light on how administrations and employers deal with the employment of foreign nationals.

Entry into France: Selective and Complex Immigration

A landmark decree in June 2025

The decree of 13 June 2025 updated the regulatory part of CESEDA to align with the Immigration Law of 26 January 2024, the DDADUE Law of 30 April 2025, and Directive (EU) 2021/1883 on the EU Blue Card.

It reinstated provisions removed during the 2021 recodification and primarily concerns “talent,” “job-seeking/business creation,” and “entrepreneur/liberal profession” residence permits.

Key changes include:

• The “passeport talent” became simply “talent”
• Skilled workers now receive a single “talent–skilled worker” card
• Investment and entrepreneurship permits merged into “talent–project holder”
• A new “talent–medical and pharmacy professions” card was created

The EU Blue Card was adapted to the 2021 directive:

• Timelines set at 90 days for first applications and 30 days for intra-EU mobility
• Temporary six-month permits pending issuance
• Salary thresholds reinstated

Thresholds are now among the strictest in the EU:

• Talent–skilled worker: average gross salary
• EU Blue Card: 1.5 times average gross salary (€59,373)
• Medical professions: €41,386
• Project holders: minimum wage + €30,000 project funding

These rules could deter applicants and redirect them toward more flexible countries like Germany or Spain.

Medical Professions: A New Talent Category

As of January 2024, foreign-trained doctors made up 21% of surgical specialists and 17.4% of medical specialists in France.

To address shortages, the 2024 law created a four-year talent–medical and pharmacy professions permit for doctors, dentists, midwives, and pharmacists authorized to practice under French public health law.

• Allows direct employment without a separate work permit
• Salary threshold: €41,386 annually
• Visa applications are now operational via France-visas

Visa Difficulties and Administrative Gaps

Non-EU nationals must first obtain a long-stay visa, but consular practices vary widely, creating delays and unpredictability.

Even students—whose rights are guaranteed under EU law—face:

• Refusals without explanation
• Long waits
• Administrative litigation

Recent changes in service providers, such as TLS Contact in the U.S., worsened the situation. These inconsistencies undermine France’s attractiveness for students and professionals.

Residence and Work Rights: A Difficult Path

The ANEF digital platform

Since 2020, the National Digital Administration for Foreigners (ANEF) has digitized residence permit applications. Intended to simplify, it has instead created dysfunction:

• Blocked files
• Lack of receipts
• Excessive delays

Although CESEDA guarantees continuity of rights during renewals, many applicants wait months without proof of status—risking jobs, housing, and benefits.

The Conseil d’État has ruled the State must provide alternatives, but inconsistencies remain. Civil society organizations have filed legal actions, and the Defender of Rights has criticized discriminatory effects.

Regularization Through Work: The 2025 Shift

The circular of 23 January 2025 abolished the Valls Circular (2012) and restricted exceptional admission to stay (AES) to shortage occupations.

Requirements include:

• 3 years’ residence
• 12 months’ recent work in a shortage job
• French proficiency
• Adherence to republican principles

The May 2025 order updated shortage occupation lists regionally. While pragmatic, the list is criticized as rigid and poorly aligned with real labor needs.

The June 2025 circular emphasized integration:

• Registration with France Travail
• Language and vocational training
• Skills recognition
• A central role for employers

Implementation remains uneven, raising concerns about over-reliance on businesses.

Employers’ Growing Preventive Role

Employers must ensure employees hold valid work permits both at hiring and during employment. This obligation creates tensions between anti-discrimination principles and compliance duties.

HR departments must:

• Detect forged documents
• Monitor subcontractors’ compliance
• Anticipate the EU’s Entry/Exit System (EES), which will automate border checks

Sanctions are severe:

• Up to 10 years’ imprisonment and €200,000 fines for organized cases
• Exclusion from public contracts
• Confiscation of assets
• Business closure

Best practices:

• Regular internal audits
• Careful tracking of permit expirations
• Dialogue with employees and authorities

Conclusion

For employers, recent reforms present a double reality:

• Easier access to foreign talents in shortage sectors
• Increased compliance burdens and legal risks

Incomplete digital reforms, rigid regularization criteria, and stricter sanctions create uncertainty. Immigration management is no longer a simple administrative task—it is a strategic HR and legal issue requiring:

• Robust compliance tools
• Careful monitoring of permits
• Active collaboration with employees and authorities

Co-authored by Clarisse Delaitre, Partner, Majorelle Avocats, Head of Majorelle Mobility, and Justine LAVENANT, Lawyer in professional immigration