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Temporary Protection Transition Scheme Opens: What Ukrainian Nationals in Ireland Need to Know

Temporary Protection Transition Scheme Opens: What Ukrainian Nationals in Ireland Need to Know

The Department of Justice, Home Affairs and Migration has now opened applications for the Temporary Protection Transition Scheme (TPTS), providing an alternative immigration pathway for eligible beneficiaries of Temporary Protection who wish to continue living in Ireland beyond the Temporary Protection framework. Applications opened on 30 September 2026 and will remain open until 30 March 2027.

This marks an important development for many Ukrainian nationals who have established their lives in Ireland over the past number of years. Many have entered employment, pursued education, established businesses, and built strong ties within their local communities. The introduction of the TPTS provides greater clarity for those who are now considering their longer-term future in Ireland.

Under the scheme, eligible applicants may be granted a permission on a Stamp 4 basis. This permission allows an individual to live and work in Ireland without the requirement for an employment permit and may provide a pathway towards longer-term residence and citizenship.

Eligibility for the scheme will depend on a number of factors, including an applicant’s residence history in Ireland, employment status, income and accommodation arrangements. Family members may also be eligible to benefit in certain circumstances. As with all immigration applications, careful preparation and supporting documentation will be key.

While the introduction of the scheme will be welcome news for many, immigration circumstances can vary significantly from one person to another. Questions frequently arise regarding eligibility, family members, long-term immigration options, supporting documentation and alternative pathways where an individual may not satisfy the criteria of the scheme.

For this reason, obtaining legal advice at an early stage can be beneficial. Understanding your options before making an application can help identify any potential issues, ensure the correct documentation is provided, and allow you to make informed decisions regarding your long-term future in Ireland.

At Gibson & Associates LLP, our Immigration Law team is assisting Ukrainian nationals in assessing their eligibility under the Temporary Protection Transition Scheme and advising on alternative immigration pathways where appropriate.

If you would like advice regarding your eligibility or immigration options, please contact our office to arrange a consultation.

” The Temporary Protection Transition Scheme provides a welcome pathway for many Ukrainian nationals seeking greater certainty regarding their future in Ireland. However, the scheme will not be suitable for everyone, and those who do not meet the eligibility criteria should seek advice on the alternative immigration pathways that may be available to them” – Kellie McLaughlin, Immigration Solicitor

Irish Immigration and Citizenship Law – Change is Now the Constant

Irish Immigration and Citizenship Law – Change is Now the Constant

The pace of change in Irish immigration and citizenship law and policy over the past two years has been considerable.

Against that background, the latest proposed changes to Irish Nationality and Citizenship Acts 1956 (as amended) are particularly significant. The Minister for Justice has secured approval for the priority drafting of the Irish Nationality and Citizenship (Amendment) Bill 2026, with the legislation expected to progress on an accelerated basis.

The proposed reforms include significant changes to statutory criteria for a naturalisation application, including an increase in the general reckonable residence requirement from five years to eight years, together with proposed language and civics requirements and changes relating to financial self-sufficiency.

The Bill has not been drafted yet, so we await publication of the draft. The current statutory criteria for an application for naturalisation as an Irish citizen therefore continue to apply and the usual legislative process will be carried out before any amendments come into force.

The proposed citizenship reforms do not stand alone. They form part of a much wider programme of change to Ireland’s immigration system.

The Non-EEA Family Reunification Policy has been subject to significant review and amendment in the past two years. The Revised Policy Document on Non EEA Family Reunification was published in November 2025 in circumstances where no changes had been made to that policy since 2016. The revised policy maintains routes for immediate family members of Irish citizens and eligible non-EEA residents, but places greater emphasis on financial capacity and introduces stricter limits in relation to certain other family members. The Policy Document was amended again on 12th June 2026 to include further restrictions on capacity to sponsor a family member, for example.

Perhaps the most significant legislative development in the international protection sphere has been the International Protection Act 2026, which commenced on 12 June 2026. The Act gives effect to the EU Migration and Asylum Pact and represents a fundamental restructuring of Ireland’s international protection system, including new screening and registration procedures, enhanced identity and security checks and changes to the processing and appeals framework.

The Government has also introduced further measures affecting people who hold temporary protection in Ireland, including those displaced from Ukraine, as Ireland prepares for the eventual transition from the EU Temporary Protection framework.

Taken together, these developments demonstrate just how quickly Irish immigration law and policy is changing. We are seeing amendments to legislation, revised policies, changing administrative policy and significant shifts in the interpretation and application of immigration policies, often within relatively short periods.

For individuals and families navigating the Irish immigration system, the practical consequences can be considerable. A person who was eligible to make an application under one set of rules may find that the position has changed by the time they apply.

This is particularly important in the context of citizenship. Where an individual is already eligible to apply under the Irish Nationality and Citizenship Acts, delaying an application could potentially mean facing a substantially different set of requirements if the proposed legislation is enacted. Please be advised that the final legislation may be significantly different as the proposals are considered further by our legislators.

Proposed Changes to Irish Citizenship Rules: Why Eligible Applicants Should Act Now

Proposed Changes to Irish Citizenship Rules: Why Eligible Applicants Should Act Now

The Irish Government has recently secured approval for the priority drafting of the Irish Nationality and Citizenship (Amendment) Bill 2026, signalling what may become one of the most significant reforms to Irish citizenship law in recent years. According to the Government’s announcement on 9 September 2026, the proposed legislation would introduce stricter eligibility requirements for citizenship by naturalisation, including longer residence requirements, language and civics testing, and new self-sufficiency criteria. These changes are intended to strengthen Ireland’s naturalisation framework and align it more closely with systems used across other European countries. [gov.ie]

While the legislation has not yet been enacted and remains subject to the legislative process, the announcement has already generated significant discussion among individuals who may be considering an Irish citizenship application. For many long-term residents of Ireland, the proposed reforms may represent a narrowing of the pathway to citizenship in the future. As a result, those who are currently eligible under the existing rules may wish to consider submitting their applications sooner rather than later.

What Changes Are Being Proposed?

The General Scheme of the Bill includes several notable proposals. Among the most significant is the plan to increase the qualifying period of reckonable residence from five years to eight years for most applicants seeking citizenship through naturalisation. The Government also intends to introduce language proficiency requirements, whereby applicants would need to demonstrate knowledge of English, Irish, or Irish Sign Language. In addition, applicants may be required to complete a civics, society, and politics test designed to assess their understanding of Ireland and its institutions. The proposed legislation would also introduce measures aimed at ensuring applicants are financially self-sufficient. [gov.ie]

If implemented, these requirements would represent a substantial change from the current naturalisation framework. Many individuals who are approaching eligibility under the existing residence rules could face a significantly longer wait if the new legislation becomes law.

Why This Matters for Existing Applicants

Under the current system, many lawful residents may already be eligible to apply for Irish citizenship through naturalisation after meeting the required period of residence and other statutory conditions. However, once legislative changes take effect, future applicants may need to satisfy more extensive requirements before becoming eligible.

Although the Government has not yet confirmed an implementation date, the fact that the Bill has been prioritised for drafting demonstrates a clear intention to progress these reforms. The General Scheme will now move toward pre-legislative scrutiny before making its way through the Oireachtas. [gov.ie]

For individuals who believe they may already qualify under the current rules, delaying an application could carry risks. Errors in residency calculations, gaps in immigration permissions, missing documentation, or misunderstandings regarding eligibility can result in avoidable delays. Seeking legal guidance now may help ensure that an application is prepared and submitted correctly while the current framework remains in place.

The Importance of Professional Representation

Citizenship applications are often more complex than many applicants anticipate. Determining reckonable residence, addressing absences from the State, proving continuous residence, demonstrating good character, and compiling the required supporting documentation can be challenging. Even seemingly minor discrepancies can lead to requests for further information or delays in processing.

At Gibson & Associates LLP, our Immigration Team regularly assists clients with citizenship by naturalisation applications. We provide comprehensive support throughout the process, including assessing eligibility, reviewing immigration history, advising on documentation requirements, preparing applications, and addressing any issues that may arise before submission.

Our team also assists applicants whose circumstances may involve additional complexities, including previous immigration matters, extensive travel histories, family-based applications, or applications involving Irish associations. By seeking advice at an early stage, applicants can gain clarity on their position and take proactive steps to strengthen their application.

A Potential Surge in Applications

Historically, announcements regarding immigration and citizenship reforms often lead to increased demand from individuals seeking to submit applications before new requirements come into force. Given the scale of the proposed changes, many immigration practitioners anticipate a significant increase in citizenship enquiries and applications in the coming months.

This means that individuals who may already be eligible should not assume they have unlimited time to act. Preparing a naturalisation application can require substantial evidence gathering, including proof of residence, identity documentation, immigration records, and supporting materials covering multiple years. Starting this process early can help avoid unnecessary stress and reduce the risk of missing an opportunity to apply under the current rules.

How Gibson & Associates LLP Can Help

If you are considering applying for Irish citizenship through naturalisation, now may be an important time to review your eligibility. Our experienced Immigration Team can assess your circumstances, explain the current requirements, and guide you through every stage of the application process.

While the proposed legislation has not yet become law, the direction of travel is clear. Individuals who may be eligible today may face more requirement in the future. Seeking legal advice now can help you understand your options and ensure you are in the strongest possible position to pursue Irish citizenship before any legislative changes take effect.

If you believe you may qualify for Irish citizenship through naturalisation, contact Gibson & Associates LLP today to arrange a consultation with our Immigration Team and discuss your eligibility under the current rules.

Q&A with Laura Phelan Starting the Journey at Blackhall

Q&A with Laura Phelan Starting the Journey at Blackhall

We’re delighted to shine a spotlight on one of our team members as Laura prepares to take the next exciting step in her legal career. This December, she will begin her studies at Blackhall Place in Dublin, marking the start of her professional qualification journey.

In this Q&A, we sit down with her to discuss her path into law, what inspired her to pursue a legal career, and her thoughts ahead of starting at one of Ireland’s leading centres for professional legal education. We’re proud to support the development of emerging legal talent and look forward to following her journey as she continues to grow and succeed within the profession.

Question: Hi Laura! Where did you originally study and why did you get into Law?

I completed my undergraduate degree in Law and Media at Dublin City University (DCU), before going on to complete a Master of Laws (LLM) at DCU. I have always had an interest in law, and my studies at DCU further strengthened that interest.

Question : How long have you been working in Gibson and Associates LLP and when did you decide to move forward with starting at Blackhall?

I joined Gibson & Associates in December 2022. I began sitting the FE1 examinations in October 2023 and successfully completed them in March 2026.

Question: What type of Law are you primarily interested in?

I have always had an interest in human rights law. During my Master’s degree, I chose to write my dissertation on the legal position of women in surrogacy arrangements in Ireland, examining the series of governmental failures that have contributed to the lack of legal protection for intended mothers in such arrangements. This research further developed my interest in the way the law affects individuals and their fundamental rights, which naturally led me to immigration law. I find it particularly rewarding to see the tangible impact that legal protection and representation can have on individuals in vulnerable situations. I look forward to gaining further experience across other areas of law, including Litigation and Property, during my training with Gibson and Associates. This will allow me to develop a broader understanding of different areas of practice and, in turn, determine which area I am most interested in pursuing.

Question: What are you expecting before you start in December? Have you spoken to some of our Solicitors for some advice?

I have been fortunate to receive support from my colleagues, including Kellie and Blaithin, who have recently qualified as Solicitors. They have provided valuable insight into what to expect during the Professional Practice Course (PPC) at the Law Society of Ireland, and their guidance has further reinforced my enthusiasm for taking the next step in my legal career.

Question: How would you describe this process to someone who hasn’t any clue about the process of becoming a Solicitor?

My journey to becoming a Solicitor began with an undergraduate degree in Law and Media at Dublin City University (DCU), followed by a Master of Laws (LLM) at DCU.

The next stage involved completing the eight Final Examination – First Part (FE-1) examinations, which are the entrance examinations to the Law Society of Ireland’s Professional Practice Course (PPC). These intensive examinations cover a broad range of legal subjects and are held twice each year.

Following completion of the eight exams, you must then secure a Training Contract in order to progress to Blackhall to complete the Professional Practice Course (PPC). This is offered in two formats, full time and hybrid. Upon completing the Professional Practice Course (PPC) trainee solicitors are required to complete two years of in-office training. When you have successfully completed your PPC examinations and your in-office training you may apply to have your name entered on the Roll of Solicitors.

Question: Do you think working in the firm, and seeing the work our Solicitor’s do has been a motivation to taking this next step?

Working at Gibson and Associates LLP and witnessing the results achieved by the Solicitors within the firm has further strengthened my interest in law and my understanding of the legal process. Seeing the positive impact that the Solicitors have on their clients continues to motivate me to progress towards qualification.

Question: If you had some advice for past you, what would it be? 

If I could give my past self-advice, it would be to learn as much as possible from those around you who have already gone through the process. Much of the learning comes from gaining practical experience, working on matters, and seeing the results achieved through that experience.

Exploring Irish Residency: What’s Behind the Recent Surge in U.S. Applications?

Exploring Irish Residency: What’s Behind the Recent Surge in U.S. Applications?

Ireland is seeing a significant increase in interest from U.S. nationals exploring Irish visas, residency and citizenship options, a movement that has been informally referred to as the “Donald Dash”.

While earlier waves of interest were often associated with ancestral links, business leaders or high-net-worth individuals, advisers now report a broader and more diverse profile of applicants. The latest surge has followed recent political developments in the United States, with Donald Trump’s return to the White House prompting growing numbers of Americans to look to Ireland as a place of longer-term stability, legal certainty and personal safety.

According to a report cited by the Irish Independent, private Immigration and Citizenship advisory firms have recorded sharp increases in enquiries from U.S. Citizens in recent months, with some reporting month-on-month growth of more than 40 per cent. This rise is being reflected across several Immigration and Citizenship pathways, including:

Passport Applications

  • Foreign Birth Registration applications
  • Naturalisation pathways
  • Employment-based residence permissions
  • Family reunification and residency options
  • Initial enquiries relating to International Protection

In particular, Immigration practitioners are reporting an increase in enquiries from members of the transgender and wider LGBTQ+ communities in the United States. For some, the motivation is concern about the potential rollback of legal protections, access to healthcare, or broader civil rights in parts of the U.S. As a result, Ireland is increasingly being viewed not only as a country of cultural connection, but as one offering comparatively strong legal safeguards and social protections.

At Gibson & Associates, our Immigration and Client Care Teams report that many U.S. applicants now describe their plans less in terms of opportunity and more in terms of contingency. These “Plan B” strategies may involve securing residency rights through ancestry, employment or family links, or seeking legal advice on International Protection options where appropriate.
Advisers note that while similar surges were seen in 2017 and again during the pandemic years, the current trend is marked by a greater sense of urgency. The emphasis, increasingly, is on personal security, legal continuity and the ability to live openly and safely, rather than purely economic or lifestyle considerations.

Comparable patterns are emerging in official data. Applications for Irish passports from U.S. citizens have reached historic highs, and legal practitioners report increased preliminary consultations around asylum and subsidiary protection — an area that has traditionally seen very low numbers of U.S. applicants.

The Department of Justice has confirmed that resources are being reallocated to manage rising U.S.-related demand, while stressing that eligibility thresholds remain unchanged.
For individuals and families considering relocation to Ireland, Immigration experts stress the importance of accurate, personalised legal advice. Immigration status, eligibility, timelines and outcomes can vary significantly depending on a person’s background, identity and legal position.

How Gibson & Associates Can Help

Gibson & Associates advises individuals and families navigating Irish Immigration, residency and citizenship law, including cases involving complex personal or humanitarian considerations. The firm works with clients to assess eligibility across available legal pathways — from citizenship by descent and employment-based permissions to family reunification and, where appropriate, International Protection.
Each case is considered on its own facts. Advice focuses on explaining applicable legal criteria, evidentiary requirements, processing timelines and potential outcomes, while ensuring clients understand their rights and obligations under Irish law.
As patterns of migration continue to evolve, the firm’s role is not to predict outcomes, but to provide clear, grounded guidance so that individuals can make informed decisions about their future in Ireland.

Client Advisory Note

Considering Irish Residency, Citizenship or International Protection
Individuals exploring a move to Ireland should be aware that Immigration options vary significantly depending on personal circumstances. Common pathways may include citizenship by descent, employment-based residence permissions, family reunification, naturalisation (subject to residence requirements), or, in some circumstances, applications for International Protection.

Processing times have increased in response to higher demand. Foreign Birth Registration applications can take several months to complete, International Protection applications are assessed on a case-by-case basis and are subject to specific legal and evidentiary thresholds.
Prospective applicants should also consider practical factors such as housing availability, cost of living and access to public services when planning relocation. There is no single route that suits every individual, and assumptions about eligibility can lead to delay or refusal.

Independent, up-to-date legal advice is essential before submitting any application. Careful planning can help ensure that applications are made through the most appropriate channel and in line with current Irish Immigration law.

New Policy on Non-EEA Family Reunification: What Has Changed?

New Policy on Non-EEA Family Reunification: What Has Changed?

On 26 November 2025, the Department of Justice, Home Affairs and Migration published a revised Policy Document on Non-EEA Family Reunification. This new document replaces the previous policy that had been in place since December 2016.

The updated policy sets out who can apply for family reunification in Ireland, which family members may be eligible, and the financial and residency requirements that must be met. While many core principles remain unchanged, the 2025 Policy Document introduces several important developments that will affect sponsors and applicants alike particularly in relation to adult dependants, financial sustainability, and the scope for discretion in exceptional cases.

Below, we summarise the key updates and explain what they mean in practical terms.

Family Members Who Can Be Sponsored

Under the 2025 Policy Document, family members are now grouped into three clearly defined categories.

1. Nuclear Family

This includes:

A spouse or civil partner

Unmarried children under the age of 18

Key change from 2016:
Under the previous policy, dependent children aged 18–23 who were in full-time education could, in some circumstances, be treated as part of the nuclear family. This is no longer the case. The nuclear family category is now strictly limited to children under 18.

2. Dependent Parents

Parents may still be sponsored, but applications are now assessed under stricter financial and dependency criteria (see below).

3. Dependent Adult Children

Adult children can only qualify if they:

  • Are fully dependent on the sponsoring parent, andHave a serious medical or psychological condition that renders independent living impossible

This represents a significantly more restrictive approach than under earlier practice and narrows eligibility considerably.

Who Can Act as a Sponsor?

The 2025 Policy Document divides sponsors into three categories, each with different entitlements and waiting periods.

Category A Sponsors

Includes:

  • Irish citizens
  • Refugees and beneficiaries of subsidiary protection (where family reunification under the International Protection Act does not apply)

Key points:

  • Applications may be made at any time
  • No waiting period applies

Category B Sponsors

Includes:

  • Investors and Entrepreneurs
  • Critical Skills Employment Permit holders

Researchers and PhD students

  • Certain doctors, ministers of religion, and approved scholarship students

Key points:

  • Immediate family reunification is permitted for nuclear family members
  • A two-year waiting period applies before applying for dependent parents or adult children

Category C Sponsors

Includes:

  • General Employment Permit holders
  • Reactivation Employment Permit holders
  • Stamp 4 permission holders

Key points:

  • A 12-month waiting period applies before sponsoring nuclear family members
  • A five-year waiting period applies for parents or dependent adult children

Changes to Financial Requirements

  • The revised policy confirms that only the sponsor’s income is assessed; joint household income is not taken into account.

Category A Sponsors

  • Must demonstrate a total gross income of €40,000 over the previous three years to sponsor a spouse or partner

Category B Sponsors

  • No financial threshold applies when sponsoring a spouse or partner
  • This reflects their entitlement to immediate family reunification

Category C Sponsors

Where there are no children, the sponsor must have earned €30,000 gross in the year prior to application

Key change from 2016:

Previously, Category C sponsors were required to meet the €30,000 threshold for two consecutive years. This has now been reduced to one year, making family reunification more accessible for some applicants.

  • Where children are involved, income must exceed the limits used by the Department of Social Protection for the Working Family Payment (WFP)
  • Exact figures are set out in Appendix D of the 2025 Policy Document

Dependent Adult Relative Applications

Across all sponsor categories, applications for dependent adult relatives are now subject to significantly higher financial thresholds.

Sponsors must demonstrate:

  • Income exceeding 185% of average annual earnings for one adult dependent
  • 250% of average annual earnings for two adult dependants
  • Higher percentages apply for additional relatives
  • These income levels must be met in each of the three years preceding the application. Minimum salary figures are again detailed in Appendix D.

Increased Emphasis on Financial Sustainability and Accommodation

A notable feature of the 2025 Policy Document is the enhanced focus on the sponsor’s ability to:

  • Financially support the family member, and
  • Provide suitable accommodation in Ireland

Meeting the minimum income threshold alone will not guarantee approval. All applications will be assessed holistically, with close scrutiny of long-term financial sustainability.

Exceptional Circumstances: A More Restrictive Approach

One of the most significant and subtle changes in the 2025 Policy Document relates to the treatment of exceptional circumstances.

Under paragraph 1.12 of the 2016 policy, decision-makers were expressly encouraged to retain discretion to approve applications that did not meet the policy criteria, particularly in humanitarian cases. This provision allowed flexibility in rare cases where a strict application of the rules would lead to a disproportionate outcome.

By contrast, Section 13 of the 2025 Policy Document significantly narrows the scope of this discretion.

The revised policy states that:

  • The Minister may waive certain qualifying criteria only in rare and exceptional cases
  • Such cases must arise from specific circumstances personal to the sponsor or family member, rather than from general conditions in the country of origin
  • Applicants must clearly explain why their case is rare and exceptional and provide robust supporting evidence
  • There is no guarantee of a positive outcome, even where exceptional circumstances are claimed
  • Crucially, the policy makes clear that two requirements can never be waived, regardless of the circumstances:
  • The family relationship must be valid and genuine
  • There must be a demonstrable dependency relationship

In addition, section 5.2 of the policy expressly states that family reunification is not intended as an alternative to international protection or other humanitarian admission programmes. The policy specifically references individuals who may be at risk of serious harm in their country of origin.

In practice, this appears to limit arguments that were more commonly advanced under the 2016 policy for example, reliance on generalised conflict, instability, or poor conditions in a country of origin as justification for waiving financial or residency requirements. While applicants may still rely on genuinely rare and individualised circumstances, the threshold is now considerably higher and more narrowly defined.

Conclusion

The 2025 revisions introduce a clearer and more structured framework for non-EEA family reunification, but they also narrow eligibility in several key areas particularly for adult children, dependent relatives, and cases relying on discretion. While certain changes, such as the reduced income history requirement for Category C sponsors, may benefit some applicants, the policy as a whole reflects a more restrictive and evidence-driven approach.

Given the complexity of the revised policy and the heightened scrutiny now applied to eligibility, financial capacity, accommodation and exceptional circumstances, careful preparation is critical. Each application will turn on its specific facts and the quality of supporting evidence.

As specialists in Irish immigration law, our firm advises on all aspects of family reunification — from initial eligibility assessments to the preparation and submission of detailed applications. We regularly assist clients in navigating policy changes, addressing evidential requirements, and engaging with the Department of Justice to maximise the prospects of a successful outcome.

For tailored advice on how the 2025 Policy Document may affect your circumstances, contact us to schedule your consultation today.