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Further reforms to the Isle of Man Work Permit System | May 2023

02 May 2023

Chamber was so concerned about this issue, that in 2016 all Chamber members were invited to participate in a survey (“the Survey”) and we had an unprecedented response level which, in part, indicates the importance of the issue to the business community in general. There were 92 responses in total. Businesses that participated ranged from small to large businesses. Participating members included those operating within
the financial sector, retail, manufacturing, hospitality, e-business and construction. Chamber sent a summary of the outcome of the Survey to the Department.

Chamber has again written to its members to encourage them to respond to the current consultation but, where the proposals are similar, we would anticipate responses largely in line with those received in 2016 to the Survey which (for ease of reference) revealed that out of 92 members

- 47 members (52.22%) felt that the work permit system prevented their business from effective recruitment;
- 61 members (66.30% and equating to 2/3 of the participating members) believed that the current work permit system hinders the wider
Isle of Man economy;
- 26 members (28.57%) indicated that the current work permit system had forced them to consider alternatives such as expansion offisland;
- 61 members (66.30%) were supportive of the entire system being suspended for a temporary amount of time to assess economic impact;
- 61 members (66.30%) were supportive of additional sectors being exempt from the requirement to obtain a work permit due to economic
- 57 members (61.9%) were supportive of further specific roles being exempt from the requirement to obtain a work permit due to
economic need; and
- 40 members out of the 92 surveyed, indicated that they would be in favour of a self-certification system.
The results of the Survey showed that the majority of Chamber members are supportive of wholesale reform of the work permit system and one
of the actions that Chamber particularly wanted to see was consideration given to the suspension of the system at the very least for most sectors.

Specific problems that the Survey highlighted in relation were:
1. inefficiency and uncertainty of system (turn-around time and delay in getting permits issued);
2. it encourages adequacy rather than excellence. A business should be able to recruit the best;
3. it does not recognise the advantages that can be gained by upskilling and bringing in outside expertise which can encourage growth
4. it does not recognise the shortages of unskilled or lower skilled workers, which is a big problem on the Isle of Man where the numbers
of unemployed people are low;
5. the system is antiquated and inflexible – it does not evolve as the economy does;
6. it does not recognise unmarried partners or IOM workers or permit holders;
7. the length of the permits being granted is not adequate which creates uncertainty for the potential job holder and business; and
8. it is unnecessary for the vast majority of sectors. Many members made the point that if they could recruit locally then they would every
time as it is much more convenient.

Chamber was very encouraged by the 2017 consultation as almost all of the problems highlighted in the Survey and raised by Chamber were
addressed to some extent, including the concerns as to inefficiency/inflexibility, the length of permit and the fact it does not extend to unmarried
partners. As set out in section 2 of the current consultation, several changes were introduced in 2018 which went some way to addressing the
concerns of Chamber and its members. However, some of the more fundamental issues such as “flipping” the system were not been progressed,
and as such, Chamber welcomes the current consultation and, as mentioned above, we have encouraged our members to respond.

Comments in relation to the Proposals. In response to the specific proposals referred to, Chamber comments as follows:

▪ “To temporarily suspend the requirement for a work permit in all occupations and economic sectors, save for any specific
employments or economic sectors where it is identified there is a justifiable case for the requirement to remain in place”

By reference to the Survey, the overwhelming majority of Chamber members asked for the work permit system to be temporarily suspended.
Chamber members remain strongly supportive, as indicated previously, of the more radical idea of the general flipping of the system/suspension
of the need to have work permits. As there would always be the ability for the system to be reintroduced in whole or in part, Chamber cannot
see that there is any prejudice in the proposals being adopted. Chamber has not received any negative comments from any of its Chamber
Members across any sectors at the time of lodging this response. Chamber’s STEM Committee has expressed particular support for the proposals
as follows:

“For the island’s Engineering sector to thrive, it must compete in a global market. This requires our companies to be better than our offisland competitors for quality, cost and customer service.

This requires a very highly skilled and motivated workforce which is continuously keeping up to date with the latest available tools,
techniques and technology. Although we already achieve many of these goals by employing and training Isle of Man workers, there are
occasions when it would help the companies to have more freedom and flexibility in bringing specialists from off-island to supplement
our local skills. The sector would welcome any changes to the current work permit system which will help our companies to succeed by
removing any barriers to having this flexibility”.

We understand that the general opinion of the construction sector is that permits could be suspended, but would need to be reinstated quickly
if circumstances changed.

“To require a single employer registration for all non-Isle of Man Workers, which will collect key information for the purposes
of monitoring, labour market information and to assist informing future policy, such as:
▪ Basic employment / job role information, including salary level;
▪ Basic information relating to the worker, including dependents and other demographic information; and
▪ Declaration of any criminal convictions which are required to be declared in accordance with the existing provisions of
the CEA.”
▪ Yes, very supportive.

▪ “A fee to be payable upon submission of the employer registration, with the current fee of £60 which may be adjusted based
on the outcome of this consultation;”

▪ Yes, very supportive.
An instant confirmation / unique reference number issued to the employer and employee on completion of the employer
registration valid for 5 years;
▪ Yes, very supportive.

▪ A requirement of the employer to notify of material changes to the employment of the employee for which a registration has been
completed, including cessation of employment;

▪ Yes, very supportive

Retention of the CEA, to provide the ability to reintroduce work permit requirements should there be a significant shift in the economic

▪ Yes, very supportive

27 April 2023
For and on behalf of the Isle of Man Chamber of Commerce