Ukrainians in the Netherlands: apply for a work permit (GVVA) before the temporary protection ends

Since 2022, many Ukrainians have been able to live and work in the Netherlands under the EU Temporary Protection Directive (Richtlijn Tijdelijke Bescherming, or the RTB). Temporary protection has provided an important solution during the war, but it remains a temporary residence arrangement.

For Ukrainians who have built their life and career in the Netherlands and want to stay here in the longer term, it may be wise to consider changing to a regular Dutch residence permit before temporary protection eventually comes to an end.

One possible route is the combined residence and work permit (gecombineerde vergunning voor verblijf en arbeid, or often expressed in abbreviation: GVVA).

How long will temporary protection continue?

The Temporary Protection Directive was activated in March 2022 following the Russian invasion of Ukraine. People covered by the Directive can live in the Netherlands and have access to, among other things, accommodation, medical care, education and the labour market.

At present, Ukrainians covered by temporary protection can work as employees without a separate work permit (tewerkstellingsvergunning, TWV). The employer only has to notify UWV of the employment, after which the employee can start working two working days later.

Temporary protection was previously extended until 4 March 2027. On 15 July 2026, EU Member States agreed to extend the protection for another year, until 4 March 2028. At the time of posting this article, the IND website still mentions 4 March 2027 and states that the additional one-year extension is being processed.

The extension gives Ukrainians more time, but it does not change the temporary nature of the scheme. If you intend to remain in the Netherlands in the longer term, this additional time can therefore be used to investigate whether you qualify for a regular residence permit.

Can I change from temporary protection to a regular residence permit?

It is completely possible and legal.

Temporary protection does not prevent a Ukrainian from qualifying for another Dutch residence permit. Depending on your personal situation, possible routes may include:

• employment under a regular GVVA;

• highly skilled migrant (kennismigrant);

• European Blue Card;

• self-employment;

• study;

• residence with a Dutch or EU citizen;

• family reunification with someone who already holds a regular Dutch residence permit; or

• another residence purpose for which you meet the requirements.

The IND specifically allows persons with temporary protection to apply for certain work-related residence permits, including regular employment, highly skilled migrant and self-employment, without first returning to Ukraine to obtain an MVV.

The best route therefore depends strongly on your employment, salary, qualifications, family situation and future plans.

Are you considering self-employment?

Pathway Partners previously explained the possibilities and risks for Ukrainians who want to work as self-employed persons in the Netherlands. You can read our article here:

Ukrainians applying for self-employment in the Netherlands: a critical warning before March 2027

For Ukrainians who already have a regular employer in the Netherlands but do not qualify as a highly skilled migrant or for another special work scheme, the GVVA may be particularly relevant.

What is a GVVA?

A GVVA is a combined permit for both residence and employment.

Instead of relying on temporary protection for your right to stay and work in the Netherlands, your residence would be based on your employment with a Dutch employer.

The GVVA consists of a residence document and an additional document specifying the employer and the conditions under which you are allowed to work. A regular GVVA can generally be issued for a maximum of three years.

It is important to understand that this makes your residence independent from the Temporary Protection Directive, but not independent from your employment. The GVVA is normally connected to the employer and employment stated in the additional document.

What are the main GVVA requirements?

A regular GVVA is different from the current temporary-protection arrangement.

While Ukrainians under temporary protection can currently work without a TWV, a regular GVVA is subject to the normal rules of the Dutch Foreign Nationals Employment Act (Wet arbeid vreemdelingen, Wav).

The most important requirements include the following.

1. The employer must first search in the Netherlands and Europe

This is often the most difficult part of a regular GVVA application.

The employer must demonstrate that it has genuinely tried to find a suitable candidate who is already entitled to work in the Netherlands without a work permit.

UWV requires the employer to search for a suitable candidate in the Netherlands, the EU/EEA and Switzerland for at least three months before applying for the work permit. Recruitment should be sufficiently broad, for example through online advertisements, recruitment agencies and other appropriate recruitment channels.

The employer must also report the vacancy to UWV at least five weeks before the GVVA application.

This is commonly called the labour-market test.

2. The employer must explain why other candidates were not hired

Simply publishing one vacancy for three months is not necessarily enough. The employer should be able to document:

• where and when the vacancy was advertised;

• which recruitment channels were used;

• how many candidates responded;

• which candidates were interviewed or considered;

• why the Ukrainian employee meets the genuine requirements of the position.

UWV may examine whether the job could reasonably be performed by someone who already has unrestricted access to the Dutch or European labour market.

The job description and recruitment strategy should therefore be prepared carefully from the beginning.

3. The salary must meet the applicable requirements

The employee must meet the IND income requirement for regular employment.

Until 31 December 2026, the general income threshold for employment is **€2,337 gross SV salary per month **excluding holiday allowance. These amounts are periodically adjusted.

However, meeting the IND minimum alone is not always sufficient.

The employer must also pay the normal salary applicable under the relevant collective labour agreement (CAO) or employment conditions. If the normal salary for the position is higher than the IND minimum, the higher salary will effectively be relevant.

4. The employer must meet the other employment requirements

Among other things, the employer must normally be properly registered with the Dutch Chamber of Commerce (KvK), comply with the applicable employment conditions and arrange appropriate housing for the employee where required.

Both the employee and employer must therefore be assessed before starting the procedure.

How does the GVVA procedure work?

Step 1 – Start the labour-market test

Step 2 – Submit the GVVA application

Do not wait until temporary protection is about to expire!

The recent extension of temporary protection may make March 2028 seem far away. However, for a regular GVVA, preparation should begin much earlier.

Before the application can even be submitted, the employer normally needs to complete at least three months of recruitment. After submission, the IND and UWV still need time to assess the application.

A company that only starts thinking about the GVVA shortly before temporary protection expires may therefore already be too late to complete the procedure comfortably.

There is another practical reason to start early. If UWV identifies weaknesses in the recruitment efforts, the job description or the evidence showing why other candidates were unsuitable, simply submitting the application earlier will not solve the problem. The employer may need to restart or strengthen parts of the recruitment process.

The best moment to assess the possibilities is therefore before the labour-market test starts.

Could another residence permit be easier?

Definitely true. Honestly speaking, the GVVA is not always the most efficient route. For example, someone who meets the requirements for the highly skilled migrant scheme may be able to use that route without the normal three-month labour-market test, provided that the employer and employee meet the applicable requirements.

Someone with a Dutch or EU partner may have a family-based residence route. A person planning to study may qualify for a student residence permit. An entrepreneur may potentially qualify for a residence permit as a self-employed person.

Choosing the correct route at the beginning can save considerable time and prevent unnecessary procedures.

Interested in changing to a regular residence permit?

If you currently live in the Netherlands under temporary protection and want to establish a residence status that does not depend on the Temporary Protection Directive, Pathway Partners can assess your options with you.

For a GVVA application, we recommend involving both the employee and the employer from the beginning. The labour-market test is largely based on what the employer does during the months before the application, so mistakes made during the recruitment stage can have consequences later.

Pathway Partners can provide a full consultation to assess:

• whether a GVVA is suitable for your situation;

• whether another residence route may be easier or more appropriate;

• whether the salary and employment conditions meet the requirements;

• how the employer should organise the three-month labour-market test;

• how the vacancy should be reported to UWV;

• what recruitment evidence should be retained; and

• how the eventual GVVA application should be prepared.

**Do not wait until temporary protection is approaching its final months. **If you and your employer are considering a regular work permit, contact Pathway Partners early so that the eligibility and recruitment strategy can be assessed before the three-month labour-market test begins.