A candidate shows you a Lithuanian residence card valid until 2028 and says they can join next Monday. The expiry date tells you the card is current; it does not, by itself, tell you whether the candidate can work for your employing entity. For a standard temporary residence permit issued for work, a change of employer generally needs Migration Department approval before the new job begins. A Lithuanian EU Blue Card follows a different rule after its first 12 months. The practical first step is to identify the card’s legal basis and when it was first issued.
This guide is for employers hiring someone already in Lithuania, including a move to or from an employer-of-record arrangement. It covers the employer change, not a first residence-permit application. Last reviewed: 29 October 2026.
Start with the candidate’s permit basis
Ask the candidate to show the valid residence card and the decision or MIGRIS record that identifies its basis. Establish the first issue date for that route, who currently employs the person, and whether that employment has already ended. The proposed job description and employing entity matter too. An employer change is a change in the legal employer named in the immigration and employment records, not merely a change in the team directing the work.
This is why “already has a Lithuanian permit” is not a complete hiring answer. A standard work-based temporary residence permit, an EU Blue Card and a permit held on another basis can confer different rights. EU, EEA and Swiss citizens follow free-movement rules, not the non-EU employer-change procedure described below.
Which rule sets the new start date?
| Candidate’s status | Employer-change step | When the new job can begin |
|---|---|---|
| Standard work-based temporary residence permit | Apply for Migration Department permission. The application is generally possible only after six months from permit issue, subject to statutory exceptions. | After approval, with the employment documents and pre-start filings in place. |
| Lithuanian EU Blue Card: first 12 months | Apply for a decision to change employer. Count from the first Blue Card-based Lithuanian residence permit’s issue date. | After the required decision and pre-start filings. |
| Lithuanian EU Blue Card: after the qualifying 12 months | No separate employer-change permission or former special change notice. The new job must still meet Blue Card conditions. | Once the new job is eligible and ordinary hiring requirements are complete. |
| Other Lithuanian residence basis | Determine the work rights attached to that basis; do not assume the standard work-permit rule applies. | When that status authorises the proposed work and normal onboarding is complete. |
The distinction comes from Lithuania’s Law on the Legal Status of Foreigners and the Migration Department’s May 2026 changes. The table gives the route, not a promised processing date for a particular candidate.
For a standard work-based permit, approval comes first
Suppose your prospective data analyst works for another Lithuanian employer and received their work-based temporary residence permit eight months ago. The new employing entity submits a mediation letter through MIGRIS; the candidate uses its number in the employer-change application. The Migration Department assesses the proposed employer and job. Under the current law, the candidate can start with the new employer only after the department grants permission. Filing the request does not move the start date forward.
The ordinary six-month wait runs from the issue of the work-based residence permit, not from the date of the new offer. There are limited statutory exceptions, including permits issued for less than six months and certain employer-fault cases. If the candidate received a standard permit only four months ago, do not promise an immediate transfer based on the card’s remaining validity. A change of job function at the same employer can also require permission, although the six-month application restriction in the law is expressed for a change of employer.
The law gives the department up to one month to decide a standard employer-change request, and the change decision is valid for one month from issue. As at October 2026, the state fee for examining an employer- or same-employer job-function change is €165. This is not the fee for issuing a new residence card.
A Blue Card changes the answer after its first year
A Lithuanian EU Blue Card holder who changes employer during the first 12 months of the first Blue Card-based residence permit must request a Migration Department decision. Article 44¹ provides a 14-calendar-day decision period for that change request. The new role must still qualify as highly skilled employment under the Blue Card rules, including the applicable salary condition.
After the qualifying 12-month period, the holder can change employer without a separate employer-change permission. Lithuania also removed the former requirement to send the Migration Department a special notice of that later change in May 2026. That does not remove the new employer’s ordinary employment filings or the need for the job to continue meeting Blue Card conditions. It does mean that an older guide telling you to send a seven-working-day change notice is out of date. The Migration Department explains the 2026 change.
For a candidate near the first anniversary, use the first Blue Card-based permit’s actual issue date and the applicable decision record. “A year with this employer” and “a year since the first Blue Card was issued” are not necessarily the same thing.
If the previous job has already ended
The answer changed in 2026: ending the previous employment does not automatically make every employer-change application impossible. For the specified standard work-based residence permits, the worker can notify the Migration Department through MIGRIS within 10 working days of the employment ending and state the intention to change employer. While the residence permit remains valid, the worker then has an application window measured from the termination date: three months if the relevant permit has been held for less than two years, or six months if held for more than two years. The Migration Department sets out those steps.
Those periods are time to submit a qualifying request, not permission to start the new job before approval, and they do not extend an expired residence card. The published wording says “less than” and “more than” two years; for someone precisely at the two-year boundary, obtain the department’s determination instead of assigning a deadline from a simplified chart. A Blue Card holder’s job-loss position is governed by a separate Blue Card provision, so do not automatically apply the standard-permit three-/six-month split to them.
Does moving to or from an EOR count?
Yes, when the employing legal entity changes. A candidate can keep the same manager, job title and desk while the employer in the employment contract and immigration file changes. A move from one EOR arrangement to another, from an EOR to your new Lithuanian entity, or from your entity to an EOR therefore needs to be assessed under the candidate’s actual permit basis. A commercial label such as “EOR transfer” does not replace the immigration step.
The practical order is to identify the employing entity for the new arrangement, align the offer and job description with that entity, complete any required employer-change process, then handle the employment contract and payroll registration. NNRoad’s Lithuania Expat Employment service can help coordinate that employer-side sequence when an overseas business needs a local employment arrangement.
Before you confirm day one
Set the start date from the decision that actually applies to this candidate. Your offer file should identify the permit basis and validity, the first issue date where the six- or 12-month rule matters, the old employer and any termination date, the new employing entity and job, and evidence of any required Migration Department approval. If the card will expire soon, plan the residence-permit renewal separately: permission to change employer is not a new residence card.
Then finish ordinary onboarding. Sodra requires the employer’s 1-SD notice no later than the day before work starts. Its LDU notice for employing a foreign national is due at least one working day before employment begins. These notices record the employment; they do not substitute for immigration approval where approval is required.
Questions employers ask before a transfer
Can the candidate start while an employer-change request is pending?
Not when their route requires a Migration Department change decision. For a standard work-based permit, the new job can start only after permission is granted. A separate rule allowing some people with pending residence-permit applications to continue with the same employer does not authorise a move to a new one.
Does a new title with the same employer require approval?
On the standard work-based route, a change in job function can require Migration Department permission. A title-only edit is different from a change in duties. Blue Card holders follow a separate rule for another function with the same employer, provided Blue Card conditions remain satisfied.
What if the candidate’s residence card expires soon?
Treat employer change and residence-permit validity as two deadlines. Permission to change employer does not itself renew the card. Continued work rights during a pending residence-permit application should not be assumed to cover a new employer.