Stellenmeldepflicht (AIG Art. 21a)

The duty to report vacancies, the five-working-day embargo, and the feedback obligation.

Switzerland requires employers to report vacancies in occupations with above-average unemployment to the public employment service before advertising them anywhere else. The duty comes from Art. 21a of the Foreign Nationals and Integration Act (AIG) and is enforced against the employer, not the platform.

Which vacancies are covered

The list of occupations subject to the duty is published by SECO and revised periodically, based on the unemployment rate per occupation group.

The platform holds occupation reference data with the AVAM code, the ISCO code, the unemployment rate and a regulated flag. The occupation code selected on a position is what decides whether the duty applies — which is why the code is a required field rather than a nicety.

What the duty requires

1. Report before advertising

   The vacancy is reported to the SECO Job-Room. The platform records the Job-Room ID and the management URL returned by the API.

2. Wait out the embargo

   For five working days from publication in the Job-Room, the vacancy may not be advertised publicly. During this window it is visible only to registered jobseekers and to the RAV.

   The platform computes the earliest permitted external publication date as five working days ahead — weekends and Swiss national public holidays excluded, with Easter-relative holidays computed rather than maintained by hand.

3. Consider the dossiers the RAV sends

   The RAV forwards suitable candidates. You must consider them, invite the suitable ones to an interview or an aptitude assessment, and inform the RAV of the outcome.

4. Report back

   Whether a candidate was hired, and whether the vacancy was filled. The platform records how many were invited, how many were hired, and a free-text note.

The lifecycle in the platform

Status	Meaning
NOT_REQUIRED	The occupation is not covered.
PENDING_JOBROOM	Reported; the embargo is running. Public advertising is blocked.
RAV_REVIEW	The embargo has elapsed. Public advertising is permitted; the RAV may still send candidates.
EMPLOYER_RESPONDED	Feedback on invited and hired candidates has been recorded.
CLEARED	The obligation is discharged for this vacancy.

A scheduled job polls SECO for open reports and sweeps expired embargoes from PENDING_JOBROOM into RAV_REVIEW, so the state reflects reality without anyone watching a calendar.

Per legal employer

The reporting duty is a per-employer obligation. On multi-entity installations the Rechtsträger under which a report was submitted is recorded on the Stellenmeldung, so the obligation is attributable to the right legal employer.

Credential handling

The Job-Room access token is stored separately from the management URL and is never embedded in a persisted link. A URL containing a token leaks it to every proxy, CDN and log along the way.

Where credentials come from

SECO issues API credentials on request. The platform supports a staging endpoint for testing and a production endpoint for live reporting; where credentials are not configured, the module degrades to manual tracking rather than failing.

What is not automated

Deciding whether the duty applies

The platform flags it from the occupation code. Confirming that the code is right for the actual role is a human judgement.

Assessing RAV candidates

Suitability is a hiring decision, not a computation.

Exemptions

Internal appointments, short assignments, and family members can be exempt. Determine exemptions deliberately and record the reasoning.

Publishing a covered vacancy publicly before the embargo has elapsed breaches Art. 21a and carries administrative penalties. The platform blocks external publication for the duration rather than merely warning about it.