August 2026 Outbound Immigration and Global Mobility Recap | EMEA

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 holistic 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 August 2026 in the Europe, Middle East, and Africa region.

European Union

ETIAS Launch Timeline Remains Unconfirmed as EU Removes Previous Target Date

The European Union’s Electronic Travel Information and Authorization System (ETIAS) is not yet operational. The official ETIAS website no longer refers to a specific launch window and states that the European Union will announce the start date several months before implementation.

Recent media reports have suggested that the previously anticipated rollout timetable may be postponed and that a revised implementation schedule could be announced following further discussions at the EU level.

Organizations with frequent business travelers to Europe should continue monitoring ETIAS developments and ensure travelers remain informed of future pre-travel authorization requirements once an official implementation timetable is announced.

Several Schengen Countries Continue Temporary Internal Border Controls

Multiple Schengen Member States have maintained temporary internal border controls during 2026 under the Schengen Borders Code. The European Commission’s latest notifications confirm that several countries continue to conduct document checks at certain internal borders due to security, migration, and public order concerns.

These measures do not alter underlying Schengen travel rights but may result in additional document inspections and travel delays at affected land, air, and sea ports of entry.

Employers should remind business travelers to carry valid travel documentation when moving between Schengen countries and allow additional time for cross-border travel where controls remain in place.

United Kingdom

UK Expands Global Talent Route for Research and Innovation Employers

On August 6, 2026, the UK government announced an expansion of the Global Talent Visa Endorsed Funder pathway, extending access to a wider range of research-focused businesses. Previously associated primarily with universities and research institutions, the route can now be used by approved research-intensive companies that receive support through eligible funding arrangements. More than 100 organizations have reportedly been approved to participate in the expanded framework.

The changes are intended to support recruitment in sectors that rely heavily on research and innovation, including life sciences, advanced manufacturing, artificial intelligence, digital technology, clean energy, and creative industries. Eligible researchers may benefit from a flexible immigration route that operates outside the traditional sponsored-worker framework and may provide greater mobility between approved organizations and research projects.

Research-led employers should assess whether prospective hires may qualify under the expanded Global Talent route and consider whether it may offer an alternative to Skilled Worker sponsorship for certain high-value research and innovation roles.

Migration Advisory Committee Recommends New Temporary Shortage List Framework

The Migration Advisory Committee (MAC) has published recommendations for the next phase of the UK’s Temporary Shortage List (TSL), proposing a more structured approach to granting access to overseas recruitment in occupations experiencing labor shortages. The review assessed occupations linked to the UK’s industrial strategy and critical infrastructure needs and recommended 28 occupations for inclusion on the TSL for a limited period of 18 months. The recommendations are not yet immigration rules and remain subject to government consideration.

Under the proposed model, eligibility for inclusion would depend not only on evidence of labor shortages but also on employers demonstrating credible workforce-planning measures aimed at reducing longer-term reliance on overseas recruitment. The MAC also recommends greater emphasis on domestic skills development initiatives and safeguards designed to address worker welfare and compliance considerations.

Employers that rely on overseas recruitment for mid-skilled occupations should monitor future government decisions closely. If adopted, the proposed framework could require organizations to demonstrate stronger domestic recruitment, training, and workforce-development strategies when seeking continued access to international talent.

Poland

Poland Restricts Work Authorization for Certain Visa-Free Nationals

Poland has implemented a new regulation on August 22, 2026, affecting citizens of Colombia, Georgia, and Venezuela who seek to work in the country.

Under the new rule, nationals of these countries may no longer perform work in Poland solely based on a work permit while remaining in visa-free status. Instead, they must hold an appropriate immigration status authorizing employment, such as a national visa or residence permit. Transitional provisions protect individuals who had already commenced employment under the previous framework before the regulation took effect.

Employers should review current and planned assignments to ensure affected individuals hold the appropriate immigration status before commencing work. Employers may also need to revise recruitment timelines and secure additional immigration documentation for affected nationals before employment begins.

Belgium

Belgium Updates Cross-Border Worker Rules Affecting Non-EU Nationals

Effective August 15, 2026, Belgium implemented a new framework governing frontier workers. The revised Belgian framework broadens the scope of individuals who may qualify to carry out frontier work activities without obtaining residence rights in Belgium. In addition to employees working under a Belgian employment arrangement, the regime now extends to certain individuals performing cross-border activities under assignment structures or on a self-employed basis.

For non-EU nationals, the applicable administrative process will depend on their country of residence. Individuals residing in neighboring countries that share a land border with Belgium will move to a new documentary framework based on Annex 64, while those residing in the United Kingdom will be required to obtain a dedicated long-stay visa (Visa D, category B63) before undertaking frontier work activities in Belgium.

Annex 64 does not confer residence rights in Belgium; rather, it serves as an authorization facilitating entry into and exit from Belgium for eligible frontier work activities. Existing document holders benefiting from the previous regime may continue to rely on transitional measures during a 12-month adjustment period.

Employers with non-EU personnel who reside in France, Germany, Luxembourg, or the Netherlands and regularly perform frontier work activities in Belgium should review whether affected individuals will need to transition to the new Annex 64 process. This requirement applies both to new applications and to individuals currently relying on an Annex 15 document under the previous framework. Employers with frontier workers residing in the United Kingdom should also ensure that affected individuals obtain the appropriate frontier worker visa before continuing cross-border work arrangements.

Georgia

Georgia Adjusts Foreign Worker Rules Following March 2026 Immigration Reforms
Georgia has adopted further amendments to its labor migration framework, introducing changes that affect employer sponsorship obligations, work authorization exemptions and the management of short-term professional activities. The measures build on the foreign worker regime introduced earlier in 2026 and provide additional clarity on when work authorization is required and how employers may engage foreign nationals in the country.

One of the most notable changes is the replacement of the previous vacancy advertising and labor market testing process with a quota-based mechanism for certain employers seeking to hire foreign workers. Depending on the size and composition of their workforce, employers may now be required to obtain annual quota approval before submitting work authorization applications.

The amendments also broaden the categories of foreign nationals who may be exempt from work authorization requirements, including certain individuals working remotely, providing services to overseas businesses, undertaking specified governance functions, or carrying out qualifying short-term professional assignments.

The amendments provide greater clarity regarding short-term professional activities, which may be performed for up to four months in total during a calendar year. The allowable period is calculated from the individual’s commencement of activities in Georgia and is subject to the applicable registration requirements.

Organizations may benefit from the expanded exemption categories in certain cases, while those intending to sponsor foreign workers should determine whether quota approval will be required before initiating future work authorization applications. Businesses relying on project-based or short-term assignments should also ensure that applicable registration requirements are satisfied before activities commence.

Middle East

Saudi Arabia

Saudi Arabia Announces New Localization Requirements and Extends Work Permit Regularization Period

Saudi Arabian authorities have introduced measures affecting employers that rely on foreign talent and sponsor expatriate workers. Most notably, the Ministry of Human Resources and Social Development (MHRSD), together with the Ministry of Municipalities and Housing, has announced that the localization requirement for certain project management occupations will increase from 40% to 70%, with implementation scheduled for February 14, 2027. The revised threshold applies to private-sector establishments employing three or more individuals in designated project management positions.

The occupations affected include project management managers, project management engineers, and project management specialists. Employers operating in these functions should assess workforce composition and identify any measures required to meet the higher localization target before the implementation date. The authorities have also published procedural guidance outlining the scope of the initiative and the applicable compliance framework.

Separately, Saudi authorities have extended the period available for employers to regularize certain non-compliant work permit situations. The extension applies to foreign workers whose work permits expired more than 12 months ago or whose work permits were not issued within six months of joining an establishment. The regularization deadline has been extended to December 31, 2026, providing employers with additional time to resolve outstanding compliance matters before enforcement measures may apply.

Employers should review project management headcount planning, considering the upcoming localization requirements, and use the extended regularization period to address any outstanding work permit compliance issues. Early action may help reduce operational disruption and mitigate potential enforcement risks.

United Arab Emirates

UAE Introduces Business Mobility and Workforce Compliance Updates

The United Arab Emirates has introduced several developments affecting business travelers, employers, and workforce mobility processes. Among the changes, visa-on-arrival eligibility has been expanded for nationals of Indonesia, Kenya, the Philippines, South Africa, Thailand, and Vietnam, who hold qualifying residence permits issued by specified jurisdictions, including Australia, Canada, European Union member states, Japan, New Zealand, Singapore, South Korea, the United Kingdom, and the United States. Eligible individuals may obtain entry authorization upon arrival for tourism and certain non-remunerated business activities, subject to applicable conditions.

The UAE has also revised Emiratization requirements applicable to private healthcare facilities employing 50 or more workers. Under the updated approach, the mandatory annual Emiratization target must now be distributed equally between specialized healthcare positions and other skilled occupations.

The Ministry of Foreign Affairs has also continued the transition to a fully digital attestation framework. Under the revised process, documents that have already been authenticated by a UAE embassy or consulate abroad generally no longer require a separate physical Ministry of Foreign Affairs attestation within the UAE, reducing administrative steps associated with document legalization.

Employers should review whether expanded visa-on-arrival eligibility may facilitate short-term business travel and ensure healthcare entities remain aligned with revised Emiratization requirements.

Africa

Ghana:

Ghana Introduces New Rules Affecting Expatriate Quotas and Work Permit Processing

Ghana’s new investment legislation, the Ghana Investment Promotion Authority Act, 2026 (Act 1173), entered into force on July 15, 2026 and includes measures that affect how foreign-invested businesses engage and sponsor foreign nationals. The reforms revise the framework governing expatriate quota entitlements and establish a new process for the submission of certain work permit applications.

Under the revised system, access to expatriate quota positions remains linked to capital investment levels, but businesses making higher qualifying investments may now be eligible for a greater number of quota positions than under the previous regime. The legislation also introduces a new limitation on the duration of expatriate quota occupancy, providing that quota positions may be held for a period of five years before renewal becomes necessary.

The law further changes the work permit application process for enterprises with foreign ownership by requiring applications to be submitted through the Ghana Investment Promotion Authority for review and recommendation before consideration by the Ghana Immigration Service. Sector-specific arrangements remain in place for businesses operating in regulated industries, including oil and gas, mining and free zones.

Foreign-invested businesses should review how the revised quota framework may affect future assignments and recruitment. Employers should also account for the additional review stage in work permit processing when planning onboarding schedules and international transfers.

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 August’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.