Latest legislative developments – Home Conseil Immigration – May 2025
New rules for apostilles, reform of the "European Blue Card" status, stricter naturalization criteria, update of the list of shortage occupations… Our teams dedicated to apostilles and legalizations, as well as professional immigration procedures provide an update on the latest legislative developments and their concrete impacts for employers, international talents, and legal professionals.
Implementation of a new procedure for apostille requests
As mentioned in our December newsletter, which you can find here, and in accordance with the Decree of December 23, 2024, related to the legalization and apostille of public documents issued by French authorities, the procedure for obtaining an apostille has changed and has been effective since May 1, 2025. Since that date, the 15 regional councils or interdepartmental chambers of notaries are responsible for issuing apostilles, replacing the courts of appeal.
From now on, requests must be initiated online via this new dedicated platform. This first step is mandatory and generates a receipt containing a file number. This receipt must be included with the original documents to be apostilled, and these can be sent by mail or delivered in person to the nearest apostille center (note: depending on the city, an appointment may be required). Documents signed electronically should be able to be apostilled online through the platform mentioned earlier. Documents can be sent to any apostille center regardless of where they were signed. The Decree of April 10, 2025, sets the fees for this new procedure, depending on the applicant’s status (individual or legal entity) and the number of documents. The announced delivery time is three days once all necessary information is known by the notaries. A fast-track option is also available for urgent cases, with a delivery time of 24 hours. The table below outlines the applicable rates.
*Counting from the day all necessary information for processing is available in the national database of public signatures.
In practice, since implementation in early May, these timelines have not been met due to technical issues slowing the new notarial system at a national level. Due to a high volume of requests, apostille centers are currently avoiding giving estimated processing times. As a result, government fees are not yet being applied to apostilles issued after the deadline.
While waiting for these issues to be resolved, our teams are closely monitoring the situation to continue delivering effective service.
Implementation of the Directive simplifying the “Talent – EU Blue Card” procedure
Although France had until November 19, 2023, to transpose into domestic law the EU Directive of 20/10/2021 simplifying the "Talent – European Blue Card" residence permit (see our dedicated news here), it was not until April 30, 2025, that law No. 2025-391 (known as the DDADUE 2025 law) was finally enacted.
This law transposes the Directive (EU) 2021/188 of the European Parliament and the Council of the European Union of October 20, 2021, on the conditions of entry and residence in the EU for third-country nationals seeking to work in high-skilled jobs.
The main adjustments include the statuses of “Talent – EU Blue Card,” “Talent – Family,” and the “EU Long-Term Resident Card.”
Modification of the “Talent – European Blue Card” status
Several significant changes apply to the “Talent – EU Blue Card” procedure:
- Required employment contract duration reduced from 12 to 6 months.
- Validity of the card now varies as follows:
- Contract < 2 years: card validity is equal to the contract duration + 3 months.
- Contract > 2 years: card valid for 4 years.
- Degree requirement remains unchanged (minimum Bachelor degree level), but a new option has been introduced that allows the access to the status through three years of work experience within the past 7 years (further applicable details are to come).
- Minimum salary remains 1.5 times the national average gross annual salary, as set by decree.
- The law also outlines cases for withdrawal or refusal, notably in case of employer misconduct (fraud, hidden work, labor law violations).
New renewal options for the “Talent – Family” status
Family members of an EU Blue Card holder now benefit from enhanced rights:
- The “Talent – Family” card is automatically renewed if the holder has resided for at least 5 years in various EU member states, including the last 2 years in France, as a “dependent” of an EU Blue Card holder.
- New: spouses may renew their card even after separation, as long as they resided for 5 years in the EU, including 2 years in France, as a “dependent.”
Facilitating Intra-EU mobility
The law simplifies the procedure for highly skilled workers within the EU:
- The period of residence required to convert an EU Blue Card from another Member State to a French card is reduced from 18 to 12 months (and to 6 months in case of second mobility).
- The application must be submitted within one month after arriving in France.
Easier access to the EU Long-Term Resident Card
An EU Blue Card holder for 2 years can now request a 10-year EU Long-Term Resident Card, if they justify 3 years of continuous residence in the EU. This duration includes various residence permits: researcher, highly skilled worker, refugee, etc.
Temporary absences do not affect eligibility if they do not exceed 12 consecutive months or 18 months in total.
Retailleau Circular: Stricter naturalization criteria
The Minister of the Interior Bruno Retailleau issued a circular to regional prefects outlining new guidelines for acquiring French nationality. Officially published on May 2, 2025, this circular tightens naturalization requirements, emphasizing three key criteria: 1) assimilation into the French community, 2) exemplary behavior, and 3) the applicant's autonomy and professional integration.
Assimilation into the French community, particularly through language proficiency, historical and cultural knowledge, remains essential for obtaining French nationality. As of January 1, 2026, a B2 language level will be required. A civic exam will now test theoretical knowledge, previously evaluated during the assimilation interview. This also applies to holders of resident or multi-year residence cards.
The circular also highlights the importance of maintaining exemplary behavior. Applications will be rejected if the applicant has been convicted of serious crimes or offenses, especially those harming the nation’s fundamental interests. Other disqualifying factors include irregular stay or tactics to prolong unlawful residence.
Moreover, to prove autonomy, the applicant must demonstrate stable employment and financial resources over the past five years. At least a one-year permanent contract or fixed-term contracts totaling two years will be required. Income will be assessed relative to the minimum wage (SMIC), considering family composition. The text also expressly excludes income from social benefits or income from foreign sources.
Recognizing that high-level students and professionals with a Talent permit who contribute to France's international reputation in key sectors (art, science, etc.) may be subject to discretionary evaluation by the Prefect.
Update of the shortage occupations List
The government has published in the Official Bulletin the updated list of occupations and regions facing recruitment difficulties, under article L.414-13 of CESEDA. This decree, published on May 21, 2025, has been awaited for months following repeated delays related to the implementation of the immigration law of January 26, 2024.
This new list replaces the one from 2021, last updated in March 2024. It identifies sectoral labor shortages by region, based on labor demand and the average presence of non-EU foreign workers.
Jointly drafted by the Ministries of the Interior, Labor, Health, Families and Solidarity, with support from social partners, the list serves a dual purpose:
- To facilitate hiring of non-EU foreign workers by removing the job posting requirement (known as the labor market test) in the identified sectors.
- To allow in application of article L435-4 of the CESEDA exceptional residence admissions for undocumented individuals in France, within the framework of an experimental scheme in force until December 31, 2026, detailed in our previous newsletter.
New sectors now covered include hospitality, food service, construction, and home care (domestic workers, cleaning staff). However, jobs related to food retail and childcare remain excluded.
The government plans to update this list annually to better reflect the evolving labor market trends.
Our immigration team will be delighted to answer any questions you may have about these important legislative developments.
Sources:
https://apostille.notaires.fr/accueil
Decree of April 10, 2025 on the terms and conditions of the fee for the legalization and apostille of public documents issued by French authorities :https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000051469010
LAW no. 2025-391 of April 30, 2025 on various provisions for adapting to European Union law in the fields of economics, finance, the environment, energy, transport, health and the movement of persons: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000051538879
Circular NOR INTK 2513256J on Guidelines for acquiring French nationality by decision of the public authority: https://www.gisti.org/IMG/pdf/circ_2025-05-02_intk2513256j.pdf
Decree of May 21, 2025 establishing the list of professions and geographical areas characterized by recruitment difficulties: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000051643488
Travailleurs étrangers : la « liste des métiers en tension » actualisée | info.gouv.fr
https://travail-emploi.gouv.fr/
