# Work-based residence for Ukrainians: applications and appeals in 2026

The work-based residence proposal includes digital applications, a fee and limited appeal rights. See what approval, refusal and later renewal could mean for you.

Canonical: https://samfunnprep.no/en/nyheter/ukrainere-arbeidsopphold-soknad-klage-2026
Language: en
Publisher: SamfunnPrep
Author: Hlib Suslov
Published: 2026-09-22T08:29:21.425+00:00
Modified: 2026-09-25T01:18:03.610946+00:00
AI use policy: https://samfunnprep.no/ai-policy.txt

## Key takeaways

- 6 300 kroner is the proposed initial fee As of 22 September 2026, the proposed fee is 6 300 kroner per adult and 3 150 kroner for children under 18, with no new renewal fee when conditions are met.
- Manual review is not an ordinary appeal Initial decisions would have no ordinary right of administrative appeal, but you could request an explanation and manual review by UDI.
- Approval changes the grounds for residence Collective protection ends on approval. Under the proposal, if renewal is later refused, you cannot fall back on that scheme.

Work-based residence for Ukrainians is proposed with digital applications and a fee of 6 300 kroner for adults. The initial decision would not be subject to an ordinary appeal, but manual review would be available. This is a proposal as of 22 September 2026.

## Work-based residence: digital applications with electronic ID

The proposal provides for applications to Utlendingsdirektoratet (UDI) using electronic ID, abbreviated to eID. You would normally not need to attend in person, but the authorities could require it.

This is set out in the [consultation letter of 17 September 2026](https://www.regjeringen.no/no/dokumenter/horing-forslag-til-en-sarordning-om-overgang-til-annen-oppholdsstatus-pa-grunnlag-av-arbeid-for-fordrevne-fra-ukraina-med-midlertidig-kollektiv-beskyttelse/id3172986/) and § 7 of the draft law. The consultation deadline is 30 October 2026. The rules have not been adopted.

The draft does not say that BankID will be the only way to log in. UDI will issue more detailed guidelines. Parents would be able to apply for children without their own eID. SamfunnPrep explains the differences between [BankID, ID-porten and MinID](https://samfunnprep.no/en/articles/bankid-id-porten-minid).

UDI would be able to decide cases automatically by checking registered information against the conditions. This does not mean that generative artificial intelligence would decide the application.

## What would the application cost?

The ministry proposes **6 300 kroner per adult** for the first application. Children under 18 would pay half: **3 150 kroner**.

The permit would be granted for one year at a time. If the conditions remain fulfilled, UDI would be able to renew it without a new application or processing fee. Renewal is therefore not guaranteed.

The scheme would be able to form a basis for permanent residence after three years with the new permit and fulfilment of the other requirements. SamfunnPrep has an [overview of permanent residence](https://samfunnprep.no/en/tema/permanent-oppholdstillatelse) and explains [how residence periods are calculated](https://samfunnprep.no/en/articles/botid-permanent-oppholdstillatelse-norge).

## Can I appeal an automated refusal?

The proposal removes the ordinary right of administrative appeal for initial decisions under §§ 5 and 6. However, you would be able to ask UDI for an explanation and manual review.

A UDI caseworker could then check the decision. This is not an independent appeal review by Utlendingsnemnda (UNE). The distinction is set out in the [consultation paper, sections 6.3.4 and 6.3.5](https://www.regjeringen.no/contentassets/2a6832177cab474aac0b86f74d6fec0b/horingsnotat-om-en-sarordning-pa-grunnlag-av-arbeid.pdf#page=28).

If information is wrong, you can ask the responsible agency to correct it. After correction, you can ask UDI to change the decision. UDI can also correct certain errors in its own registers. Manual review does not exempt you from the conditions.

Ordinary appeal rights would, however, apply to later decisions about renewal and revocation, meaning withdrawal of a permit.

## Approval and refusal have different consequences

A refusal of the first application would not in itself remove your existing collective protection. By contrast, a granted permit means a change in your grounds for residence.

| Situation under the proposal | Meaning for residence | Possible follow-up |
| --- | --- | --- |
| First application refused | Existing collective protection is retained | Request an explanation, manual review and any necessary corrections |
| First application approved | Collective protection and rights under utlendingsloven § 34 end | Follow the conditions of the new permit |
| Later renewal refused | You cannot fall back on collective protection | Ordinary appeal rights; clarify other grounds for residence and deadlines |

After a later refusal, other grounds for residence or a new protection application may become relevant. This provides no automatic right to stay. Seek individual guidance about lawful residence, where to apply and deadlines.

At renewal, the proposal also allows spouses or cohabiting partners to switch who is the main applicant. This helps only if the conditions for the new roles are met.

## Check your information before any future application

You can already check whether your pay and personal details are registered correctly. This prepares your documentation but is not an application under the proposed scheme.

1. Compare reported pay with your payslips. Ask your employer to correct reporting errors.
2. Check family information in Folkeregisteret, the public population register, and request corrections if it is wrong.
3. Check that your electronic ID works. Wait for UDI's information about approved solutions and the opening of applications.
4. Provide accurate information about criminal matters. An ordinary criminal fine is covered by the proposal, while **forenklet forelegg** is expressly excluded.

You should therefore not interpret every traffic fine as an automatic refusal. Ask for clarification if the type of penalty is unclear. Do not pay anyone for access to a supposed application portal before UDI has confirmed the scheme. This overview does not replace legal guidance on your own case.

## FAQ

### Has a fee of 6 300 kroner been adopted?

No. As of 22 September 2026, the ministry proposes 6 300 kroner per adult and 3 150 kroner for children under 18 for the first application. The consultation deadline is 30 October 2026.

### Can an automated refusal be checked by a person?

Yes, the proposal gives a right to an explanation and manual review by UDI on request. This is not an ordinary appeal to UNE. Corrections to errors in public registers can be requested, after which you can ask UDI to change the decision.

### Will I lose collective protection if my first application is refused?

An initial refusal would not in itself remove existing collective protection. If the new permit is granted, however, collective protection and the rights under utlendingsloven § 34 end.

### What happens if my residence permit is not renewed later?

The proposal retains ordinary appeal rights for renewal decisions. Under the proposal, you cannot fall back on collective protection. Other grounds for residence, any new protection application and deadlines must be assessed individually.

## Sources

- [Høringsbrev: særordning om opphold på grunnlag av arbeid for fordrevne med kollektiv beskyttelse](https://www.regjeringen.no/no/dokumenter/horing-forslag-til-en-sarordning-om-overgang-til-annen-oppholdsstatus-pa-grunnlag-av-arbeid-for-fordrevne-fra-ukraina-med-midlertidig-kollektiv-beskyttelse/id3172986/)
- [Høringsnotat: punkt 6.3.1.2, 6.3.3–6.3.7 og lovutkastets §§ 5–10](https://www.regjeringen.no/contentassets/2a6832177cab474aac0b86f74d6fec0b/horingsnotat-om-en-sarordning-pa-grunnlag-av-arbeid.pdf)

Citation: Hlib Suslov, "Work-based residence for Ukrainians: applications and appeals in 2026", SamfunnPrep, 2026-09-22T08:29:21.425+00:00, https://samfunnprep.no/en/nyheter/ukrainere-arbeidsopphold-soknad-klage-2026