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

European Union

Improved Monitoring of Third-country Nationals Across the Schengen Area

The European Commission has adopted a decision that significantly strengthens how EU Member States monitor the movement of third-country nationals across the Schengen area. The new framework, applicable from June 12, 2026, requires the monthly production of integrated statistics using data from VIS, Eurodac, EES and ETIAS. This consolidated approach will give authorities far greater visibility over actual entries and exits, overstays, visa usage, asylum applications, and secondary movements within the EU.

This marks a shift toward stricter compliance oversight. Any inconsistencies between travel records, visa conditions or permitted lengths of stay will be more easily detected as systems become fully interconnected. Companies relying on non-EU talent should ensure that all movement within the Schengen area strictly aligns with visa and work permit requirements.

Poland

Proposed Changes to Labor and Social Policy Concerning the Employment of Foreign Nationals

Poland recently published draft bill UD396, led by the Ministry of Family, Labor and Social Policy concerning the employment of foreign nationals. One of the main proposed changes would allow nationals of certain selected jurisdictions to work in Poland without obtaining a work permit prior to commencing employment.

Under the proposed framework, employers would instead be required to submit an electronic notification after hiring the foreign national, in a model broadly comparable to the notification-based system currently used for Ukrainian nationals.

At this stage, the proposal could potentially apply to nationals of Australia, Canada, Japan, New Zealand, Singapore, South Korea, Taiwan, the United Kingdom, and the United States.

In parallel, the draft legislation proposes tighter eligibility criteria for employers seeking priority processing of work permit and visa applications under the Polish Investment Zone, including a minimum declared investment threshold of PLN 100 million.

The reform is expected to progress during the third quarter of 2026 and could enter into force toward the end of 2026 or early 2027.

Romania

Regulatory Changes Regarding the Employment and Secondment of Third-country Nationals

Romania recently introduced regulatory changes affecting the employment and secondment of third-country nationals. The reform (Emergency Ordinance No. 32/2026) establishes a more centralized and digitalized framework for work authorization processes, including the introduction of a unified application concept replacing separate work and secondment authorization procedures.

The new framework also introduces:

• Stricter regulation of foreign placement agencies
• New bilingual employment contract requirements (provided both in Romanian and in the employee’s native language, or in another international language the employee understands)
• Limitations on certain secondment-arrangements (restricted to assignments within the EU/EEA or conducted under the intra-corporate transferee framework)
• A centralized electronic platform intended to support registrations, authorizations, and applications

Employers may face implementation delays while the new electronic system becomes fully operational and should review workforce planning, onboarding procedures, and compliance processes accordingly.

Spain

New Guidance on the Extraordinary Regularization Process

The Spanish Government has published detailed technical guidance in the form of “100 Frequently Asked Questions” relating to the Extraordinary Regularization process currently underway in Spain. The guidance provides additional clarification on eligibility requirements, supporting documentation, filing procedures, and practical implementation issues connected to the temporary regularization framework.

As previously highlighted in our January Bulletin, the Government of Spain is implementing an Extraordinary Regularization process, designed to provide legal certainty and equal rights to an estimated 500,000 migrants already residing in the country. Under this scheme, eligible applicants may obtain temporary residence and unrestricted work authorization for an initial one‑year period. After this initial grant, individuals will be required to transition into an immigration category available under Spain’s ordinary immigration framework.

The publication follows the opening of the application period in April 2026 and may assist employers and affected foreign nationals in assessing eligibility and preparing applications under the new process.

For employers, the measure may expand access to work-authorized candidates already present in Spain, particularly in sectors experiencing labor shortages.

Sweden

More Flexible Immigration Rules for Foreign Researchers and Doctoral Candidates

The Swedish Government confirmed plans to introduce more flexible immigration rules for foreign researchers and doctoral candidates, while simultaneously strengthening safeguards against misuse of residence permits for studies.

Sweden’s new rules for foreign researchers and doctoral candidates allow hosted doctoral students to obtain research‑category residence permits, expand in‑country application rights to those holding post‑study or post‑research job‑seeker permits, shorten the qualifying period for permanent residence, and introduce longer job‑search permits after completing research or doctoral studies.

The proposed changes are intended to facilitate Sweden’s ability to attract and retain international research talent through improved post-study and post-research mobility options.

It is proposed that the legislative amendments enter into force on June 11, 2026.

For employers, universities and research institutions, the measures may improve long-term talent retention and mobility planning for international researchers and highly skilled graduates.

New Citizenship Eligibility Rules

On June 6, 2026, new Swedish citizenship eligibility requirements are scheduled to enter into force, following legislative changes approved by the Swedish Parliament. The new framework introduces stricter conditions relating to residence (increasing from five to eight years), conduct, and self-sufficiency, together with additional requirements connected to knowledge of Swedish language and society.

United Kingdom

Eligibility to Use Automated Passport eGates Expanded

As of July 8, 2026, the United Kingdom will expand eligibility to use automated passport eGates to include certain children aged 8 and 9, provided they are travelling with an accompanying adult and meet the applicable height requirements, at least 120 cm (3 ft 11 in). This measure may help simplify travel and reduce wait times at UK Customs for employees travelling with dependent children, particularly during peak travel periods.

Middle East

United Arab Emirates (Dubai)

Updated Criteria for Property Investor Residence Visas

Dubai Land Department authorities have updated the eligibility criteria for the two-year property investor residence visa. Under the revised framework, sole property owners are no longer subject to a minimum property value threshold, while joint owners must hold a share valued at least AED 400,000.

To qualify, the property must generally be residential, completed, located in Dubai, and registered with the Dubai Land Department. Applicants with mortgaged properties may also qualify, subject to applicable equity and documentation requirements.

Eligible applicants may continue to sponsor qualifying family members, including spouses and children. The residence permit remains valid for two years and may be renewed provided the relevant conditions continue to be met.

Saudi Arabia

Saudization Measures Affecting Marketing, Sales and Tourism-related Professions

The Saudi Ministry of Human Resources and Social Development (MoHRSD), in coordination with the Ministry of Tourism, announced additional Saudization measures affecting marketing, sales, and tourism-related professions.

Saudization (also known as Nitaqat) now includes increased localization requirements for several marketing and sales roles. Affected positions include, among others, Marketing Managers, Marketing Specialists, Public Relations Specialists, Graphic Designers, Sales Managers, Retail Sales Representatives, and ICT Sales Specialists.

The authorities also introduced the first phase of localization requirements covering 28 tourism sector professions, with mandatory Saudization rates varying depending on the role and sector.

The requirements apply to eligible establishments meeting the applicable workforce thresholds and form part of Saudi Arabia’s broader workforce nationalization strategy.

Iraq

Temporary Immigration Measures Introduced for Foreign Nationals Holding Expired Visas or Residency Cards

The Kurdistan Regional Government Ministry of Interior introduced temporary immigration facilitation measures applicable for a 90-day period to certain foreign nationals holding expired visas or residency cards (Ikamma).

Under the temporary measures, eligible individuals seeking to renew their immigration status or depart the Kurdistan Region may be permitted to regularize their situation upon payment of a reduced portion of the applicable overstay penalties. The measures also provide temporary relief from certain enforcement actions related to overstays during the facilitation period.

The temporary measures entered into force on April 27, 2026, and are expected to remain applicable until July 26, 2026, after which standard immigration penalties and procedures are expected to resume.

Africa

South Africa

New Meetings, Events, Exhibitions and Tourism Scheme (MEETS) Introduced

The South African Department of Home Affairs introduced the Meetings, Events, Exhibitions, and Tourism Scheme (MEETS), a new accreditation-based framework intended to facilitate high-volume group visa applications linked to qualifying international events hosted in South Africa.

Under the framework, accredited event organizers may submit group visa applications through a dedicated digital platform designed to support faster processing for eligible conferences, exhibitions, sporting events and cultural or business gatherings. Participation in the scheme is subject to approval by the authorities and compliance with applicable accreditation and operational requirements.

The framework also requires participating organizers to enter into a formal agreement with the Department of Home Affairs and to demonstrate sufficient administrative capacity to manage visa coordination for international delegates.

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 May’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.