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IRELAND: Contract for Services Employment Permits (CFS Eps) – Accommodation and Insurance Compliance Under the Employment Permits Act 2024
Recent guidance from Ireland's Department of Enterprise, Trade and Employment (DETE) clarifies how accommodation and health insurance obligations must be handled for non-EEA workers assigned to Ireland under the Contract for Services Employment Permit (CFS EP) route. While the underlying statutory requirements are not new, the Department has adopted a more prescriptive interpretation that applies to both new applications and renewals. Organizations using the CFS route should review Ireland-specific policies to ensure continued compliance and avoid delays.
Key Points
- CFS Permits Are Distinct From Standard Employment Permits: CFS EPs are intended for temporary, service-based assignments where the worker remains employed by a foreign contractor. This structure places additional welfare-related responsibilities on the contractor during the assignee's time in Ireland.
- Accommodation and Insurance Are Mandatory: Contractors must provide board and/or accommodation and compliant health insurance for the entire duration of the assignment. These obligations exist independently of salary thresholds, even though their monetary value may count toward remuneration requirements.
- Allowance vs. Provision Is Not the Same: DETE now draws a clear distinction between reimbursing costs and actively ensuring accommodation and insurance. Paying an allowance alone is insufficient if the contractor cannot demonstrate responsibility and oversight.
- Stricter Interpretation Now Applied: The Department expects contractors to explicitly confirm and evidence accommodation and insurance coverage for the full period of stay. This approach applies to both initial applications and renewals, regardless of when the assignment began.
- Evidence and Confirmation Are Critical: Contractors must be able to show that arrangements are in place and maintained. Documentation must support that responsibility remains with the contractor throughout the assignment.
What Employers Need to Know
- Contractor Responsibility Is Central: U.S. companies using foreign contractors to deliver services in Ireland must ensure the contractor—not the assignee—retains responsibility for accommodation and insurance. This applies even where global mobility policies are used.
- Ireland-Specific Policy Alignment Is Required: Global policies may continue to apply, but they must clearly address Irish statutory expectations. Generic language may no longer be sufficient under the Department's current interpretation.
- Cross-Functional Coordination Is Essential: HR, Global Mobility, Legal, and Procurement teams must align early in the process. Misalignment can result in application delays or compliance challenges at renewal.
- Renewals Are Not Exempt: Existing CFS EP holders are subject to the same scrutiny as new applicants. Employers should reassess ongoing assignments rather than assume prior approvals will carry forward.
- Documentation Must Be Clear and Durable: Assignment documents should explicitly confirm contractor responsibility for accommodation and insurance for the full duration of presence in Ireland. Evidence should be readily available if requested by DETE.
Looking Ahead
- Greater Contractor Accountability Is Likely to Continue: The Employment Permits Act 2024 signals a broader shift toward tighter oversight of service-based deployments. Contractors can expect continued scrutiny of welfare-related obligations.
- Increased Compliance Review at Renewal Stage: Renewals may increasingly function as reassessments rather than routine extensions. Organizations should plan for closer review of accommodation and insurance arrangements.
- More Detailed Evidence Expectations: DETE may continue to refine what constitutes acceptable proof of compliance. Contractors should be prepared to demonstrate oversight, not just financial support.
- Policy Adjustments Will Reduce Risk: Organizations that rely regularly on the CFS route may benefit from light-touch, Ireland-specific policy updates. Proactive alignment can prevent processing delays and follow-up queries.
- Operational Planning Becomes More Important: Repeated or long-term use of CFS EPs will require more deliberate planning. Early compliance checks can help maintain continuity of service delivery in Ireland.
Conclusion
The updated interpretation of accommodation and insurance obligations under Ireland's Employment Permits Act 2024 underscores the distinct nature of Contract for Services Employment Permits. Contractors must now do more than reimburse costs—they must actively ensure and evidence compliant arrangements for the full duration of an assignee's stay. For organizations deploying non-EEA staff to Ireland, modest Ireland-specific policy alignment and early cross-team coordination can significantly reduce compliance risk and ensure smoother application and renewal outcomes.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
