Accommodation for migrant workers in Finland: what employers must prove with the permit

The Seasonal Work Act 907/2017 requires a statement on the seasonal worker's accommodation as part of the application. The Finnish Immigration Service (Migri) assesses that statement before deciding. Where the employer arranges or brokers the housing, the rent may not be unreasonable in relation to the salary and may not be deducted from wages automatically. Housing is part of the permit, not a side arrangement.

What the statement has to contain

A statement on accommodation means concrete information about where the worker will live and on what terms. In practice Migri is given the address, the type of housing, the number of occupants in the same dwelling, and the amount of the rent with the method of payment. An intention is not enough: a sentence saying housing will be arranged on arrival leaves a gap that produces a request for further information and moves the decision.

The Seasonal Work Act 907/2017 sets two conditions on employer arranged or employer brokered housing, and they are worth keeping apart. The first concerns price: the rent may not be unreasonable in relation to the salary. The second concerns the method of payment: the rent may not be deducted from wages automatically. These are separate duties, and an employer can breach the second while the rent level itself is entirely reasonable.

Reasonableness is measured against the salary, not against the market rent alone. Three hundred euros for a shared room is a different proposition on a monthly salary of one thousand euros than on two thousand. That is why the housing arrangement and the pay level belong in the same decision. The salary thresholds themselves, the income requirement and the collective agreement rate, are covered in the post on the salary requirement and collective agreement.

The length of the season sets the length of the tenancy

Migri states at migri.fi/en/seasonal-work that seasonal work is capped at nine months in any 12 month period. In practice the same limit governs the housing arrangement, because the tenancy is tied to the work period. A twelve month lease is the wrong instrument when the right to work ends at month nine, and a worker cannot be left carrying three months of rent for a period during which no work is permitted.

The seasonal permit also decides who carries the duty at all. Migri (migri.fi/en/seasonal-work) states that a seasonal work permit is not granted to a posted worker or for an open ended employment relationship. For a posted worker the housing duty follows the posting company and the rules on posting, not the Seasonal Work Act 907/2017. This is where the contract structure decides the obligation, and where a wrong assumption travels straight into an inspection.

Inspection looks at housing from the other end

Migri assesses the housing at the application stage. The occupational safety and health authority (tyosuojelu.fi) looks at the same arrangement later as part of its supervision of foreign labour, and compares the situation on the ground with what the application described. The two most common gaps are the occupant count and the way the rent is collected. A room described as sleeping two that sleeps four is a finding. A rent deducted directly from the payslip is another, and it shows up in the payroll records without anyone visiting the dwelling. The course of an inspection is set out in the post on foreign labour inspection.

Housing standards are also read through the general rules on healthy dwellings, and those rules are not a matter of judgement. Decree 545/2015 of the Ministry of Social Affairs and Health, on the health conditions of dwellings and other premises, sets the action limits a municipal health protection authority measures against, covering temperature, ventilation, moisture and noise, and it applies to employer arranged housing exactly as it applies to any rented flat. Heating, a working kitchen and washing facilities, fire detection and lockable storage belong to the baseline whether the dwelling is owned by the employer or brokered. Temporary cabin accommodation at a site is possible, but it does not lower the requirements, and its terms go into the same statement as an ordinary tenancy.

The health protection authority usually arrives on a resident's notification, and its measurement report is a different document from the occupational safety inspection report. The same dwelling can therefore reach two authorities over one defect, on two separate timetables.

The cost comes in two shapes. The correction itself is usually small, a refunded rent or a change to separate invoicing. The larger cost is timing: a request for further information about housing at the application stage moves the decision by weeks, and seasonal work is tied to a harvest or another season that cannot be moved. Two weeks of delay in seasonal work often means the worker arrives halfway through it.

The practical order is this. Agree the dwelling and its terms before filing, record the address, the occupant count and the rent in the statement, and keep the rent as a payment separate from wages. Make sure the tenancy runs for the same period as the work. The address is also an authority record: the worker files a notification of move with the Digital and Population Data Services Agency, and the address written into the application is worth keeping identical to the one in that notification, because two different addresses produce a request for clarification later. The remaining stages of the application chain are described in the employed person permit and availability consideration.

Housing is the part of the application that is settled in buildings rather than on forms, which is why it belongs at the front of the schedule.