When immigration makes the news in Europe, the focus is usually on borders. In the UK, headlines dwell on "small boats," while across the EU, the debate often centers on asylum seekers crossing frontiers. Yet a quieter change has been unfolding -- not at the border, but in the workplace.

A recent study published by the London School of Economics titled The return of the state: how European governments regulate labour market competition from migrant workers shows how Austria, Germany, Ireland, and the United Kingdom have steadily tightened the rules that govern how migrants present in the country access jobs. Instead of relying only on border control, governments are introducing restrictions that decide who can be hired, on what terms, and at what pay.

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What restrictions look like

The study identifies three main types of barriers that now shape the employment of migrants after they have entered the country:

• Job vacancy tests -- employers must first prove that no local worker is available before hiring someone from abroad.
• Pay and qualification thresholds -- migrants are often required to meet higher-than-average wages or education levels to ensure they do not undercut local labor.
• Employer lock-in periods -- many new arrivals are tied to one employer for at least a year before they can switch jobs.

Asylum seekers face additional rules, such as waiting months before being permitted to work.

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Four countries, four paths -- but converging outcomes

Despite their different histories, the four countries studied ended up with strikingly similar systems.

• Austria launched the Red-White-Red Card in 2004, combining vacancy checks with salary thresholds and binding skilled workers to one employer for at least a year.
• Germany replaced its Aliens Law with a new residency framework in 2005 and later introduced the EU Blue Card, imposing wage floors and job tests, with skilled workers locked into their first employer for two years.

• Ireland, once a country of emigration, imposed some of the strictest conditions: eight weeks of job advertising before a migrant can be hired, steep salary thresholds of 32,000-64,000 euros, and one-year employer ties.
• The United Kingdom introduced a points-based visa system in 2008. Employers provided only statements that no locals were available, but workers remained tied to their sponsors. Salary thresholds applied, and the highly skilled Tier 1 visa was closed in 2011.

By 2020, Austria and Ireland -- which had few restrictions in the 1990s -- had caught up with Germany and the UK. Even highly skilled workers, once thought to be exempt, were now subject to vacancy tests and salary floors.

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Beyond economic models and EU rules

These changes challenge two common explanations.

One argument, rooted in the “Varieties of Capitalism” framework, suggested liberal market economies like the UK and Ireland would stay more open, while coordinated economies like Austria and Germany would be more protective. In reality, all four converged on the same restrictive path.

Another view is that the European Union drives migration policy. While Brussels has set minimum standards -- such as waiting times for asylum seekers -- most workplace restrictions were designed and enforced nationally.

Instead, domestic politics mattered most. The EU’s enlargement in 2004 and 2007 sparked concern about job competition. In response, governments introduced stricter rules on access to employment, particularly in lower-skilled sectors.

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Attracting skilled labor from abroad

While tightening access to jobs for migrants inside the country, European governments are, however, also launching schemes to draw in top talent.

In the United Kingdom, the number of authorized sponsors for the skilled worker visa reached 110,500 in 2024 -- reflecting continued demand -- while the government is drafting reforms to attract high-ability professionals in artificial intelligence, life sciences, clean energy, and biosciences, as outlined in its upcoming immigration white paper.

Germany has launched the new Opportunity Card, a points-based scheme that allows people to come and look for jobs in shortage sectors, with particular outreach to workers from India and African countries such as Kenya.  

Ireland continues to issue employment permits targeted at critical skills in areas such as IT and finance, while Austria promotes its Red-White-Red Card, a points-based system that gives preference to highly qualified migrants in shortage professions.

The wider European tension

The national policies examined by the LSE study mirror a broader contradiction across Europe: economies face growing labor shortages, but political debates continue to cast immigration as a problem to be "solved."

Last week the European Central Bank President Christine Lagarde noted that foreign-born workers make up only nine percent of the EU workforce but have accounted for half of all job growth since 2022. From hospitals to building sites, many industries depend on them.

Yet anti-immigrant parties and populist rhetoric have raised the political stakes. In Germany, officials warn of looming labor shortages while asylum seekers face new restrictions. In the UK, the Labour government has pledged tougher visa salary rules despite warnings from employers that cuts in foreign recruitment will cripple care, construction, and hospitality.

Governments often reach for workplace restrictions because they are politically useful. They are less visible than border fences, but they allow leaders to claim they are protecting local workers while still supplying some labor to employers.

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Economic consequences of protectionism

The study cautions that this approach carries significant economic risks. By limiting migrant access to jobs, governments risk worsening shortages in care work, construction, agriculture, and other key industries.

Strict wage thresholds and job tests also reduce flexibility, the study points out. Workers cannot easily move into roles where demand is greatest, slowing economic responsiveness. Over time, these barriers threaten growth, undermine competitiveness, and intensify the problems of aging populations.

Employers may benefit in the short term when migrants are tied to contracts, but the wider economy loses out on the mobility and dynamism that come with a flexible labor force.

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From borders to labor markets

The study concludes that Europe has shifted from controlling migration mainly at the border to managing it inside the labor market. This represents a new kind of protectionism: instead of shutting the door, states regulate the terms of entry into jobs.

Politically, these measures are attractive because they offer an “easy win.” Governments can say they are shielding local workers without sparking business opposition. Employers often tolerate the extra bureaucracy, and some even welcome the stability of tied contracts. But migrants face reduced rights, limited freedom, and weaker bargaining power.

The bigger lesson is that far from losing control to global markets or EU institutions, national governments remain firmly in charge. They are actively reshaping migration to balance economic needs, political pressures, and worker protection.

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Ever changing rules

Europe’s migration debate is no longer just about who crosses its borders. Increasingly, it is about what kind of work migrants are allowed to do once they arrive, and under what terms.

The shared path taken by Austria, Germany, Ireland, and the UK underscores this shift. States are using employment rules to manage migration in ways that are less visible but just as powerful as border controls. Europe may still look like a fortress, but it is one with many gates -- and the rules governing those gates are being quietly rewritten.

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