Registering the start of work for a foreign worker in North Macedonia

The permit does not put the worker into the system. The registration does. Article 13 of the Law on Labour Relations requires an electronic M1 or M2 form filed with the Employment Agency one day before the worker starts. Article 84 of the Law on Foreigners ties the same act to 90 days from the opinion.

The two laws overlap here, and the employer satisfies both duties through the same filing at the same office. A miss is not visible immediately. The worker arrives, works and is paid, and the irregularity surfaces only during an inspection or at the renewal request, when the file is checked for whether a registration ever existed.

The deadlines that run in parallel

Article 16 paragraph 6 of the Law on Employment and Work of Foreigners, Official Gazette 217/2015 and 163/2021, splits the deadlines by type of engagement. Where an employment relationship is established, registration happens within one day of the start of work. Where the engagement is not an employment relationship, registration goes in one day before the work begins. For the emergency services in Article 15, registration happens within three days of the foreign national arriving in the country.

The Law on Labour Relations sets a stricter deadline for the same event. Article 13 paragraph 3 requires the M1 or M2 one day before the worker starts, and for urgent and unpostponable work at least one hour before. Article 13 paragraph 7 leaves no room for interpretation: the worker may not start work before the employment contract is concluded and before the employer has registered the worker in mandatory social insurance. A certified copy of the registration is handed to the worker within three days of the start of work.

The 90 day deadline and what happens when it lapses

The most expensive deadline in the whole procedure belongs to the employer, not to an authority. Article 84 paragraph 2 of the Law on Foreigners requires the responsible person at the legal entity to register the work at the latest within 90 days of the date the Agency issued its opinion. Article 16 paragraph 7 of the Law on Employment and Work of Foreigners sets out the consequence: if the registration is missed, no employment relationship or work contract is deemed to have been concluded with the foreign national, and the Agency notifies the Ministry of the Interior.

A file that passed two positive decisions then ends empty. The employer receives no refusal decision, only a quiet loss of the legal basis, and under Article 84 paragraph 3 the Agency reports exactly these cases to the ministry every quarter. The scenario is typical on corridors with long travel: the opinion issues in March, the visa and the flight are arranged in June, the worker lands in July, and the deadline expired in June.

The duty does not end on arrival. Article 16 paragraph 9 requires the registration form to be kept at the main place of business, and on site where the foreign national works on a construction project. Article 16 paragraph 12 requires the end of work to be registered within 30 days of the ground for termination arising, and paragraph 14 requires deregistration at the latest three days after the work ends. On the social insurance side, Article 13 paragraph 11 of the Law on Labour Relations lets the worker request deregistration through a labour inspector's record if the employer fails to do it within eight days.

What the control side sees

The Agency does not wait for a filing. Article 17 of the Law on Employment and Work of Foreigners obliges it to process registration and deregistration data on foreign nationals monthly, compare it with permits issued by purpose, and report the results to the Ministry of Labour and Social Policy and to the State Labour Inspectorate. Article 22 adds one more link: the Agency sends monthly reports to the Public Revenue Office on employers who have hired foreign nationals.

A mismatch between an issued opinion and a missing registration is therefore not a record sitting in a drawer. It is cross checked every month and travels to two supervisory bodies. The range of fines that follows is set out in inspection and fines, and the conditions for reaching an opinion at all in the Employment Agency opinion.

Employers recruiting from Nepal, India and the Philippines usually lose the 90 day window to visa waiting rather than to carelessness; how Werklist plans that calendar is described on the employers page. The sequence of the whole procedure is in the permit procedure.

Registration is the cheapest step in the procedure and the most expensive one to miss. An employer who puts the date of the opinion in a calendar with a reminder on day sixty rarely reaches day ninety.