Danish Law vs SIRI’s Administrative Practice: Understanding the Difference

It was recently highlighted that the Danish Agency for International Recruitment and Integration (SIRI)  can revoke a residence permit even when the formal salary requirement appears to be met, because its administrative practice is stricter than what is explicitly written in the law. This article examines a recent case involving an international worker in Denmark, highlighting how Danish law and SIRI’s administrative and enforcement practice can differ. Maksim’s case highlights how this can have serious consequences for long‑term residents.

Why This Matters Now 

In 2021, the Aliens Act (Udlændingeloven) was amended with the aim of protecting foreign workers against abusive conditions, including excessive deductions from salary for benefits such as housing and food. The law specifies that when a residence permit is tied to a minimum salary, benefits cannot be counted toward that minimum, as set out in § 9a, section 25 (legal text) and further clarified by the Ministry of Immigration and Integration in its official answer to Parliament (official answer).

For permits tied to employment, this means that benefits like a company car, free lunches or loans must be on top of the minimum salary, not part of it.

Maksim’s Case: An Example

Maksim is a non‑EU software engineer who has lived in Denmark for six years on a residence permit based on employment with a minimum salary requirement. In 2023, he received a 60,000 DKK loan from his employer to cover an apartment deposit, which was repaid by deducting 15,000 DKK per month from his salary over several months. After these deductions, his salary still exceeded the applicable minimum, and his overall annual income did not fall below the required level.

In October 2025, SIRI revoked his residence permit. He must leave the country by the end of November 2025. In the decision letter, SIRI stated that, for the period from August 2023 to November 2023, the employer deducted 15,000 DKK of loan instalments from his salary before it was paid into his Danish bank account and that, in SIRI’s view, this contradicts the requirement that the salary must be paid to a Danish bank account in full (source). The letter further explained that, in SIRI’s practice, payment for an expense cannot take place on the foreign worker’s payslip, even when the deduction is made after tax.​

Maksim appealed the revocation decision with the assistance of a lawyer, requesting permission to stay in Denmark while his main appeal is considered. A week later, he received a refusal to stay, stating that his discomfort related to having to leave the country is not a valid reason to grant a stay. His main appeal against the revocation of his residence permit will be considered regularly in about 6 months. He left Denmark on November 28th 2025.

Law Vs SIRI’s Practice

The wording of § 9a, section 25, focuses on two main elements:

1. The salary conditions attached to the permit must be met.
2. Benefits cannot be included when assessing whether the minimum salary requirement is fulfilled.

The law itself does not explicitly prohibit any type of deduction on the payslip before transfer to the bank account, as long as the salary meets the requirements.​

At the same time, SIRI’s published guidance and the reasoning in decisions such as Maksim’s apply a stricter standard. SIRI states that expenses such as rent or canteen costs cannot be deducted from the salary before it is paid into the foreign worker’s Danish bank account, and that payment for such expenses cannot take place in the payslip at all, even if the salary after deductions remains above the minimum. In practice, this means that SIRI expects the employer to transfer the full contractual salary to a Danish bank account first and only then handle any repayments or fees as separate transactions.​

For international professionals whose permits are linked to minimum salary schemes, the key risk is not only whether the total salary exceeds the threshold, but also whether SIRI considers the way the salary is paid and any deductions made on the payslip to be compatible with its administrative practice. If SIRI finds that the conditions are not met, it may revoke the residence permit.

Maksim’s case shows that inconsistencies between the law and SIRI’s enforcement can create uncertainty for international workers. This underlines the need for clearer, more detailed guidance from authorities, so that both employees and employers know what is expected and can avoid unexpected problems with residence permits. Better communication would help make these rules easier to follow and support international professionals.

Key Takeaways from Maksim’s Story

• SIRI’s Administrative Practice is Stricter than the Law: SIRI can revoke a residence permit based on an interpretation and practice that is not explicitly detailed in the written Aliens Act, specifically regarding salary payments and deductions.
• The Problem is the Method of Payment, Not the Amount: Even when the net salary is above the minimum requirement, SIRI may object to expenses (like loan repayments) being deducted on the payslip before the transfer to the employee’s Danish bank account.
• The Expectation is Full Payment First: SIRI’s practice requires the employer to transfer the full contractual salary (before any deductions for personal expenses) to the employee’s Danish bank account; repayments or fees must be handled in separate transactions afterwards.
• Consequences are Severe and Immediate: A violation of SIRI’s practice can lead to the revocation of a resident’s permit, forcing to leave the country quickly.
• Appealing Does Not Guarantee a Stay: Maksim was refused permission to stay in Denmark during the appeal process, which is expected to take several months.
• Uncertainty for International Workers: The case underscores the urgent need for clearer, more detailed guidance from authorities to reduce the regulatory ambiguity faced by international professionals and their employers in Denmark.