Response on Proposed Draft Scheme on the introduction of Employment Permits for non-EEA students

April 2008

ICOS acknowledges that the Government has made a commitment in the context of the current Social Partnership Agreement, "Towards 2016" which will see the employment of non-EEA students become subject to an application for employment permits. ICOS also acknowledges the Government’s willingness to consult with stakeholders on this matter and is pleased to submit the following comments on behalf of its members. We also refer to earlier representations to the Department of Enterprise Trade and Employment (DETE) and to a 2006 ICOS’ submission on the working rights of non-EEA students.

In terms of the admission of international students to the state and their working and other rights while temporarily resident here, the policy context is very important and we note the Government’s previous commitment to the internationalisation of Irish Education Services. Higher Education institutions (HEIs) are enthusiastic partners in this process for educational as well as economic reasons and have enjoyed the active support of DETE, through Enterprise Ireland in their promotional activities in overseas markets. The most recent statistics reveal that there were over 27,000 international students enrolled in Irish HEIs in 2006/2007 with a value to the economy conservatively estimated at over €370 million. To ensure continued growth and success, it is particularly important that the education sector continues to enjoy the support of the enterprise sector in attracting more international students to Ireland.

International students will have a key role in the development of our HEIs and in the Government’s strategy for Science, Technology and Innovation in particular. As Ireland competes globally for the best students, it will be important that the country provides a receptive environment in terms of employment and immigration policy and while ICOS accepts the genuine desire of the Government and social partners to protect workers from exploitation and welcomes the recent establishment on a statutory basis of the National Employment Rights Authority (NERA), it feels that it is important that balance is achieved. Systems introduced should be targeted at identifying rogue employers and students and not constructed such that genuine students are penalised and deterred by bureaucratic and costly procedures.

In the context of access to employment for non-EEA students, it is also worth noting that employment experience contributes not only to students’ financial well-being, but by broadening students’ range of social contacts, also assists in language and cultural understanding and general integration into Irish society. Well adjusted students with good language skills are in turn more likely to succeed academically.

ICOS welcomes certain aspects of the proposed scheme in particular the recognition that student internships should not be subject to employment permit applications and the lack of restriction on the categories of jobs that will be open to students. However, ICOS is not convinced that the scheme as presented in the current proposal is fair or workable from the international student perspective. Our detailed comments are set out in the document below