Clark Hill’s Outbound Immigration & Global Mobility practice guides corporate clients and individuals through complex global immigration challenges worldwide. We pride ourselves on creative, compliant, and people-centered solutions – looking at global mobility from a wholistic perspective in an ever-changing immigration environment. Our team assists with short-term assignments, long-term relocations, consular processing, document procurement, document legalizations/apostilles, and business visas in 100+ countries worldwide.
Below is an overview of the major updates from April 2026 in the Europe, Middle East, and Africa region.
United Kingdom
Digital Immigration Status and Right-to-Work Compliance Changes Continue in April 2026
As of April 2026, following the recent completion of the UK’s eVisa rollout and the increasing use of Digital Verification Services (DVS), there has been a shift towards digitalization of all UK immigration-related services, including visas and right-to-work (RTW) compliance.
Physical immigration documents have now largely been phased out, with sponsored workers and other visa holders increasingly relying on digital status records. Employers must ensure that internal onboarding and RTW procedures align with Home Office online checking requirements.
In parallel, the Home Office continues to strengthen sponsor compliance obligations. Sponsors should review policies relating to the recovery of immigration costs from sponsored workers, as certain fees and associated costs cannot be passed on where pay of a sponsored worker is reduced below required salary thresholds.
Employers should also ensure sponsored workers are duly informed of key UK employment rights and that evidence of this communication must be retained for audit purposes.
Withdrawal Agreement Beneficiaries Exempt from ETIAS
On April 16, 2026, the European Union confirmed that UK nationals and their family members who are beneficiaries of the EU-UK Withdrawal Agreement will be exempt from the future ETIAS travel authorization requirement, provided they hold a valid Withdrawal Agreement residence document issued in the uniform format by an eligible host country.
Important exceptions apply, including beneficiaries residing in Ireland and holders of certain Withdrawal Agreement residence documents issued by Cyprus when traveling to other ETIAS countries.
This means affected individuals may continue to reside in their EU host country and travel to other ETIAS-participating European countries using their valid Withdrawal Agreement residence document, without needing separate ETIAS authorization.
Spain
Extraordinary Regularization Process Launched
On April 16, 2026, the application period for Spain’s extraordinary regularization process opened, and the Spanish government launched a dedicated online portal providing official guidance, appointment booking, and access to the filing process.
The measure is intended to provide a temporary pathway to lawful status for eligible foreign nationals already residing in Spain.
The process is time-limited and will remain open until June 30, 2026. Applicants must meet specified eligibility criteria, including evidence of a clean criminal record and either (i) continuous residence in Spain for at least five months or (ii) qualifying international protection‑related circumstances.
Successful applicants may obtain temporary residence and unrestricted work authorization for an initial one-year period. Thereafter, individuals must transition into an immigration category available under the ordinary immigration framework.
For employers, the measure may expand access to work-authorized candidates already present in Spain, particularly in sectors experiencing labor shortages.
Poland
New MOS 2.0 Platform Launched
On April 27, 2026, Poland launched the new MOS 2.0 platform for electronic residence permit applications, requiring that applications for temporary residence permits, permanent residence permits, and EU long-term resident permits are submitted online via the new portal.
Any paper applications received after April 26, 2026 will not be considered.
The launch confirms the transition to a more digitalized filing environment and may require timely completion of employer-related supporting documentation for affected employees.
Middle East
Kingdom of Saudi Arabia
Mandatory 100% Saudization Requirements Expanded to Several Occupations
On April 5, 2026, the Kingdom of Saudi Arabia expanded mandatory 100% Saudization requirements to a range of administrative support occupations in the private sector. Certain roles became immediately restricted to Saudi nationals, while others are subject to a six-month transition period.
Occupations affected immediately include secretarial roles, data-entry positions, patient reception roles, security-related positions, HR clerical functions, translation/interpreting roles, and customs brokerage occupations.
A further group of occupations is subject to a grace period until October 4, 2026, including selected HR and people-management functions such as administrative assistants, recruitment roles, HR operations and specialist positions, workforce planning, compensation, employee relations, internal communications, and certain public relations management roles.
Qiwa Contract Registration Requirements Tightened
As of April 15, 2026, Saudi employers may only count Saudi employees toward localization quotas where the relevant employment agreements have been properly recorded through the Qiwa digital platform.
Organizations that fall below the required benchmarks may face restrictions when accessing certain labor-related and immigration services linked to the Qiwa system. Employers should therefore assess the status of existing contracts, update internal HR records, and complete pending registrations ahead of the applicable deadlines.
Saudi Arabia, Russia Agreement on Visa-Free Travel
On May 11, the reciprocal visa waiver agreement between Russia and Saudi Arabia will enter into force. Eligible nationals of both countries will be able to travel without a visa for up to 90 days within a one-year period, whether used continuously or across multiple visits.
The arrangement applies to holders of ordinary, official, and diplomatic passports and is intended for tourism, business travel, and family visits. Visas will still be required for employment, study, and residence categories.
Africa
Zambia
Immigration Control Act Replaces Immigration and Deportation Act
On April 8, 2026, Zambia enacted the Immigration Control Act, 2026, replacing the previous Immigration and Deportation Act, 2010. The new law introduces a more structured immigration framework including clearer permit categories for employment, business, temporary work, residence, and family-based stay. It also sets defined processing timelines for multiple immigration applications, with many permit and visa decisions to be made within 30 days.
The Act further clarifies family-based pathways through dedicated spouse and dependent permit categories, including eligibility for spouses, certain minor children, elderly parents aged 65 or above, and certain family members who are physically or mentally dependent on the principal permit holder.
Important for short-term mobility, the Act provides a detailed statutory definition of “business visitor,” which includes a foreign employee paid by an employer abroad who comes to Zambia to work for a period not exceeding 30 days, as well as persons entering to advise on business matters, establish a business, undertake unpaid voluntary work, or provide services consisting of advice, training, learning by observation or classroom-based activities.
The reform may improve predictability for assignments and short-term business travel, while also increasing the importance of using the correct immigration category for each activity and assignment type.
Angola
Stricter Enforcement of Visa Category Rules
In April 2026, Angolan authorities reaffirmed stricter enforcement of visa category rules for foreign nationals, particularly in sectors relying on short-term international mobility such as oil and gas and maritime and offshore operations.
Under Angolan immigration rules, tourist visas are intended for limited non-work purposes, such as business prospecting, family visits, scientific or technological activities, and recreational, sporting, or cultural travel. They are not appropriate for remunerated work or technical activities.
Foreign nationals travelling to Angola for paid work-related activities should instead hold an immigration status that lawfully permits such activities, which may include a work visa, valid residence permit, temporary stay visa, or other legally permitted short-term or border visa categories, depending on the circumstances.
For additional information, please contact the EMEA Immigration team at EMEA@clarkhill.com
For further information on any of the updates in this bulletin, reach out to one of the members of our Outbound Immigration & Global Mobility team.
To view April’s updates for the Americas and APAC regions, click the respective region.
This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.
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