July 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 July 2026 in the Europe, Middle East, and Africa region.

European Union:

EU Member States Agreed to Extend Temporary Protection for Ukrainian Citizens Until March 2028

On July 15, 2026, EU Member States agreed to extend the temporary protection regime for persons displaced from Ukraine by an additional year, until March 4, 2028. The measure is intended to provide continued legal certainty for the individuals benefiting from temporary protection across the European Union. The Council stated that the decision will be formally adopted in the coming weeks.

Member States also agreed that, as a general rule, new applicants may be required to present official documentation confirming compliance with, or exemption from, military obligations in Ukraine. This condition would not apply to individuals already benefiting from temporary protection in the EU.

For employers, the extension is expected to provide additional certainty regarding the residence and work authorization status of Ukrainian nationals currently employed under the temporary protection framework. Organizations with affected employees should monitor the formal adoption of the Council decision and any implementing measures issued at the national level.

EU Common Asylum Pact: Implementation Underway Across the EU

Following the implementation of the EU Common Pact on Migration and Asylum on June 12, 2026, Member States are now focused on putting the new framework into practice. The Pact introduces harmonized procedures for the screening, registration, and processing of asylum claims, with a stronger emphasis on border procedures, biometric registration through the enhanced EURODAC system, and responsibility-sharing among EU Member States.

As national authorities continue to roll out the new rules, attention is shifting to operational aspects, including mandatory pre-entry screening processes, updated asylum procedures, and the introduction of free legal counselling during certain stages of the asylum process. Member States are currently determining how these requirements will be implemented at the national level.

While the Pact primarily concerns asylum and border management rather than employment-based immigration, employers with a significant EMEA footprint should remain aware of ongoing implementation efforts, as they may affect the resources, priorities, and operational capacity of immigration authorities in some jurisdictions.

Employers are encouraged to monitor further developments as Member States continue to adapt their domestic legislation and administrative processes to the new EU framework.

United Kingdom:

Draft Right to Work Code Expands Compliance Requirements

The UK Government has published a DRAFT Code of practice on preventing illegal working, expected to take effect on October 1, 2026, alongside changes introduced by the Border Security, Asylum and Immigration Act 2025.

What is Changing?

Under the current rules, right to work obligations generally apply to employers with traditional employment relationships. Beginning October 1, 2026, these obligations are expected to extend to organizations that engage:

• Individuals under employment contracts
• Workers engaged under worker contracts
• Individual subcontractors
• Certain online matching platforms that connect service providers with customers or clients

The new scheme will not apply to genuinely self-employed individuals who provide services directly to clients through their own independent businesses.

Expanded Liability for Illegal Working

The draft Code introduces circumstances in which liability may extend beyond the direct employer. Organizations involved in:

• Subcontracting arrangements
• Labor supply chains
• Online matching platforms
• Worker substitution arrangements

may be held responsible for illegal working if they cannot demonstrate compliance with the applicable requirements.

To establish a statutory excuse and avoid civil penalties for non-compliance, organizations may need to show that they have implemented appropriate:

• Right to work checking procedures
• Identity verification measures
• Contractual controls governing the engagement of workers

Right to Work Check Requirements

To maintain compliance, organizations must complete a valid right to work check before an individual starts work. Checks may be conducted through:

• A manual document check
• The Home Office online checking service
• A registered Right to Work Digital Verification Service Provider (RtW DVSP)

The draft Code further confirms that, except where a prescribed RtW DVSP service is used, responsibility for conducting right to work checks cannot be delegated to a third party. Organizations remain responsible for compliance.

Actions for Internal HR Teams Now

Organizations that engage contractors, subcontractors, temporary or contingent workers, platform-based workers, or individuals working under substitution arrangements should begin reviewing their internal compliance processes in preparation for the proposed changes.  We strongly recommend evaluating contractual arrangements with suppliers and subcontractors, worker onboarding procedures, right to work verification processes, and identity verification controls across the labor supply chain.

Increased Civil Penalties

The draft Code also confirms that civil penalties for illegal work may reach £45,000 per worker for a first breach within a three-year period and £60,000 per worker for a repeat breach within three years.

These increased penalties highlight the importance of maintaining effective right to work compliance procedures across all worker populations and engagement models.

United Kingdom/Switzerland:

New Free Trade Agreement Expands Framework for Cross-Border Services and Mobility

On July 13, 2026, the United Kingdom and Switzerland announced the conclusion of substantive negotiations on a modernized Free Trade Agreement (FTA). The agreement has not yet entered into force and remains subject to the relevant domestic approval procedures in both countries.

The upgraded FTA goes beyond the existing post-Brexit arrangements and modernizes the legal framework for cross-border services, investment, digital trade, and the temporary movement of service providers. Both governments have indicated that the agreement is intended to facilitate cross-border business activity and provide greater legal certainty for businesses operating between the United Kingdom and Switzerland.

Separately, the two countries announced measures that are expected to allow UK nationals to use Swiss airport e-gates in the future, with the aim of streamlining border controls for business travelers and other visitors.

For employers, the agreement may create additional opportunities to deploy personnel, provide services across borders and support business travel between the United Kingdom and Switzerland. Organizations with operations in both jurisdictions should monitor the ratification process and any future guidance outlining the practical implementation of the mobility-related provisions.

Gibraltar:

Changes to Residency Framework

Gibraltar’s new Residency Regulations 2026 entered into force on July 14, 2026, together with a new online Residency Portal. The new framework establishes residence permit categories for employees, self-employed individuals, students, existing residents, and permanent residents and introduces new eligibility and compliance requirements.

For employees, residence applicants must generally:

• Hold a contract of at least 12 months
• Earn a minimum gross annual salary of £37,500
• Demonstrate suitable accommodation in Gibraltar

Sponsoring employers must be properly registered, licensed and compliant with applicable filing and payment obligations.

The framework also confirms that non-British, non-EU, non-EEA and non-Swiss nationals require employer-sponsored work permit approval in principle before submitting a residence application. Applications remain subject to identity, security, residence and due diligence checks.

Employers planning to recruit or transfer foreign nationals to Gibraltar should review the new salary, accommodation, and residence permit requirements and ensure work authorization and residency processes are coordinated from the outset.

Germany:

Airport Transit Visa Requirement Removed for Indian Nationals

Effective June 3, 2026, Indian nationals no longer require an Airport Transit Visa (Type A) when transiting through German airports en route to a third country.

Under the revised rules, Indian passport holders may transit through German airports without obtaining a separate airport transit visa, provided they remain within the international transit area and continue onward to a destination outside the Schengen Area. The exemption does not permit entry into Germany or the Schengen Area, and standard visa requirements continue to apply where travelers need to pass immigration, collect and re-check baggage, or otherwise leave the transit zone.

The change simplifies international travel for Indian business travelers, assignees, and project-based employees who use major German hubs such as Frankfurt, Munich, or Berlin for onward travel to destinations outside the Schengen Area. Companies may benefit from reduced travel administration, lower costs, and greater routing flexibility for employees traveling on international assignments.

Slovakia:

Immigration Reforms Introduce New Residence, Employment, and Compliance Rules

Effective July 15, 2026, Slovakia introduced significant immigration reforms affecting foreign workers, employers, and beneficiaries of temporary protection from Ukraine.

A key change creates a simplified pathway for certain temporary protection holders to transition to standard residence status in Slovakia. Individuals who have continuously met the requirements of an intended residence category, such as employment, for at least six months may apply from within Slovakia. Employment-based applicants will no longer require Labor Office confirmation and may instead provide evidence of registered employment issued by the Social Insurance Agency.

The reforms also provide greater flexibility for foreign nationals who lose their jobs. Depending on the length of their residence, employment permit holders may have up to three or six months to secure new qualifying employment before their status is affected, subject to notification requirements.

Authorities have introduced stricter oversight of Business Residence Permits, including ongoing monitoring of tax and social security compliance. Permits may be revoked where holders fail to meet applicable obligations.

Additional changes include expanded digitalization of immigration processes, electronic accommodation confirmations, updated residence documents for EU citizens, and the reintroduction of statutory immigration decision deadlines from August 1, 2026.

Organizations should ensure internal immigration processes reflect the new procedural requirements.

Middle East

Saudi Arabia:

Electronic Travel Authorization (ETA) Introduced for UK Citizens

Effective July 1, 2026, the Kingdom of Saudi Arabia has introduced an Electronic Travel Authorization (ETA) program for British nationals, significantly simplifying travel to the Kingdom for certain short-term activities.

The Saudi Ministry of Foreign Affairs has announced that UK citizens will be eligible to travel to Saudi Arabia using an Electronic Travel Authorization (ETA) rather than obtaining a traditional visa for qualifying travel purposes. The ETA program is available to holders of all types of UK passports.

Under the new program, eligible UK nationals may:

• Obtain an electronic authorization prior to travel to Saudi Arabia
• Make multiple entries into the Kingdom
• Stay in Saudi Arabia for up to 180 days within a one-year period, either through a single extended stay or multiple visits
• Travel for purposes including:
  • Tourism
  • Short-term study
  • Business visits

The ETA does not authorize employment or residence in Saudi Arabia. Individuals traveling for work-related assignments requiring employment authorization must continue to obtain the appropriate work and residence permits through existing immigration processes.

Employers with UK-based travelers supporting meetings, training, or other permitted business activities in Saudi Arabia may benefit from a streamlined travel process for eligible visitors. However, companies should continue to carefully assess the nature of planned activities to ensure travelers are entering under the correct immigration category.

Kuwait:

Kuwait Activates 15-Year Residency Pathway for Qualified Investors

Kuwait has announced the eligibility requirements for its recently introduced 15-Year Investor Residency Permit, enabling the program to become operational. The permit is intended to attract foreign investment by offering qualifying investors and certain associated individuals long-term residence in Kuwait.

Under the new rules, qualifying investment entities must:

• Be established and operating in Kuwait for the purpose of direct investment
• Hold a valid investment license issued by the Kuwait Direct Investment Promotion Authority (KDIPA)
• Comply with applicable Kuwaitization requirements
• Maintain an investment value of at least KWD 5 million
• Maintain at least KWD 1 million in paid-up capital deposited in a Kuwait-based bank account

Eligible applicants include:

• Owners and partners of qualifying investment entities
• Directors and senior management personnel
• Eligible family members, including spouses, children, and parents

Applicants must also have a valid passport with at least six months’ validity and no criminal record.

The introduction of clear eligibility requirements provides greater certainty for investors, senior executives, and their families seeking a long-term presence in Kuwait.

United Arab Emirates:

Expands Visa-on-Arrival Eligibility for Nationals of Six Additional Countries

The UAE has expanded its Visa-on-Arrival (VOA) program to include nationals of Indonesia, Kenya, the Philippines, South Africa, Thailand, and Vietnam who hold a valid residence permit by one of the following jurisdictions:

• Australia
• Canada
• European Union Member States
• Japan
• Republic of Korea
• New Zealand
• Singapore
• United Kingdom
• United States

The benefit also extends to accompanying family members who meet the applicable requirements. This measure allows eligible travelers to obtain a visa upon arrival at UAE ports of entry, reducing the need for advance visa processing and facilitating short-term business and tourism travel.

Eligible travelers may choose between:

Visa Type	Government Fee	Validity	Extension
14-day Visa on Arrival	AED 100	Up to 14 days	May be extended once
60-day Visa on Arrival	AED 250	Up to 60 days	Not extendable

 

Travelers must depart the UAE before the authorized stay expires. Overstay penalties apply at AED 50 per day.

The expansion is expected to facilitate short-term corporate travel by providing greater flexibility for eligible employees traveling to the UAE for business meetings, client engagements, project discussions, market exploration, and commercial activities.

Employers should verify eligibility before travel, ensure travelers carry valid residence documentation, and monitor permitted stay periods to avoid compliance issues. Individuals who do not meet the qualifying criteria must continue to obtain a UAE visa before traveling.

Africa

South Africa:

South Africa Launches Trusted Employer Scheme (TES) Phase II

South Africa’s Department of Home Affairs has launched Phase II of the Trusted Employer Scheme (TES), expanding the program to additional categories of employers and opening a new application window for qualifying organizations.

Phase II expands the scheme beyond the original employer category to include:

• Companies involved in strategic infrastructure projects
• Organizations operating or establishing regional or global headquarters in South Africa
• Qualifying financial sector entities under the Synthetic Financial Centre (SFC) pathway

Application Window

• Expressions of Interest open: July 20, 2026
• Application deadline: September 4, 2026
• Expected outcome notifications: Within 30 working days after the closing date

TES members may benefit from:

• Priority processing of work visa applications
• Reduced documentary requirements
• Faster deployment of senior executives, technical specialists, highly skilled employees and investors into South Africa

Multinational companies with significant operations, investment projects, regional headquarters, or financial sector activities in South Africa should assess their eligibility promptly. Participation in TES can provide a more efficient route for sponsoring critical foreign talent while supporting business expansion and investment objectives.

Employers interested in participating should prepare supporting evidence and submit Expressions of Interest before September 4, 2026.

South Africa Introduces Mandatory Online Traveler Declarations

South Africa has implemented a mandatory online traveler declaration requirement for all individuals entering or departing the country through air, land, sea, and rail ports. The measure forms part of the South African Traveler Management System (SATMS), a digital initiative designed to modernize customs processing and strengthen border management.

Travelers must:

• Submit an online declaration through the SARS Traveler Declaration Portal, SATMS mobile application, or other approved digital channels
• Declare goods, currency, and other items subject to customs reporting requirements
• Complete the declaration within 24 hours before travel
• Retain proof of submission and present it to customs officials if requested

The requirement applies to South African citizens, permanent residents, and foreign nationals.

Travelers who do not complete the declaration before arrival or departure will not automatically be denied entry or exit. However, SARS advises advance submission to avoid potential delays and additional customs processing at ports of entry and departure.

Employers with internationally mobile employees should update travel guidance and pre-travel compliance processes to incorporate the new declaration requirement. Travelers should be reminded to complete the online declaration before each trip to or from South Africa to minimize border processing delays

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 July’s updates for the Americas and APAC regions, click the respective region.

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