From 1 May 2026:

• All work permit applications must be supported by a minimum of 21 consecutive days of advertising
• Advertising is expected to be placed on: The WORC Jobs Portal (JobsCayman) and a local newspaper

Transitional position:

• Applications submitted before 1 May 2026: 14-day advertising remains acceptable
• Applications submitted on or after 1 May 2026: 21-day requirement applies

At this stage:

• We have not received confirmation as to whether a formal grace period will be applied
• We understand that WORC is expected to publish FAQs and further operational guidance, which should provide additional clarity

A new consolidated fee framework has been introduced. 

Key points include:

• Revised application, grant, variation, and annual fees
• Annual fees aligned more closely with work permit fee bands
• Updated dependant fee structures
• Cabinet discretion to waive, refund or reduce fees in certain circumstances

Practical impact:

• Greater scrutiny of job titles and classifications, as these directly impact fee levels

We understand that new provisions have been introduced allowing certain Work Permit Grant (WPG) and Work Permit Renewal (WPR) applications to be processed through an expedited, or fast-track, route. However, at this point, detailed criteria and eligibility requirements for fast-track processing have not been formally published. It is still unclear how and when these provisions may apply—for example, whether fast-track processing will be restricted to cases where no suitable Caymanian applicants have been identified.

We will provide further guidance as soon as WORC issues additional clarity on these points. 

Additionally, we understand that efforts are currently underway to actively reduce the existing backlog.

New income thresholds now apply:

• CI$5,000 per month for one dependant
• CI$1,000 per month per additional dependant

These thresholds will be applied by WORC across relevant applications.

The updated framework introduces formal annual declaration obligations for certain Residency and Employment Rights Certificate (RERC) holders, including:

• Spouses of Caymanians
• Spouses of Permanent Residents
• Other applicable RERC categories

Action required:

For our clients, if you would like us to assist with these filings and ensure compliance, it is essential that we have visibility of all relevant individuals. Without this information, we will not be in a position to monitor or manage these obligations on your behalf.

Employers are now required to:

• Notify WORC within 7 days of termination of employment

This effectively triggers the cancellation / cessation of the work permit and is now treated as a key compliance obligation.

Employers are required to provide written notice to the Director of WORC within 7 days after employment ends. Failure to comply constitutes an offence and, on summary conviction, may result in a fine of CI$20,000, imprisonment for up to 2 years, or both.

There has been significant discussion regarding restrictions on employees leaving employment within the first two years of their initial work permit.

Based on current Government communications and policy direction, it is expected that:

• First-time work permit holders granted a permit on or after 1 May 2026 may be required to remain with their sponsoring employer for a period of up to 2 years
• Where a worker leaves employment within this period without a valid reason, they may be required to leave the Cayman Islands for a period (potentially up to 12 months) before being eligible to return under a new permit

However:

• This position is not set out in a fully detailed or clearly defined manner in the legislation as currently gazetted
• The Regulations do introduce provisions allowing individuals to remain in Cayman in specific circumstances, including: Harassment or discrimination, retaliation following complaints, unpaid overtime or breach of employment terms, redundancy or other justified circumstances

Practical position:

• Early termination within the first two years should be approached with caution
• There may be immigration consequences, including potential departure requirements
• Each case may be assessed on its specific circumstances

Domestic helpers: A specific exception may apply, allowing individuals to change employers within the same role without leaving the Islands.

The updated framework places increased emphasis on ongoing compliance and monitoring of individuals who hold Permanent Residence or Status, particularly in the period following grant.

This includes:

• The introduction of formal declaration requirements in certain categories
• Increased ability for WORC to review and assess ongoing eligibility
• A shift away from Permanent Residence being viewed as a purely passive status

In particular, we expect that:

• Individuals may be required to demonstrate continued compliance with the conditions under which status was granted
• Additional filings and declarations may be required during the early years following grant

A further point to note relates to the treatment of term limits for married work permit holders. Under the existing legislative framework, where two work permit holders are married, there is an option to align their term limits. 

• Where this alignment approach is taken, the applicable term limit will now be based on the individual with the shorter remaining time.
• Where permits are not aligned, each individual may continue on their respective term limits, and the requirement to leave the Cayman Islands for a minimum period of one year upon reaching their own term limit will apply independently, unless an alternative immigration permission is obtained (for example, Permanent Residence).

Recent Government communications have suggested a more prescriptive approach to the alignment of term limits. However, the Act as currently gazetted does not expressly set this out in the same way. As such, we expect that further Regulations or formal guidance may be issued to clarify how this will be applied in practice. In the interim, we recommend treating this area with caution, as the practical position may continue to evolve.