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

EMEA:

European Union:

Social Security Coordination: Adoption by the Council of the EU

The revised rules on social security coordination between countries were proposed earlier in 2026 and adopted by the Council of the EU in late September. The aim of the revised framework is to make social security coordination clearer, fairer, and easier to navigate. The new rules are also expected to strengthen labor mobility and help workers better understand their social security rights when moving or working across different countries.

The revised rules provide greater clarity on which country’s social security legislation applies to cross-border workers. The following areas are affected:

• Unemployment benefits
• Applicable legislation for posted workers and individuals working in multiple countries
• Family benefits
• Access to social benefits for economically inactive people
• Long-term care benefits

The main reforms are expected to take effect on November 1, 2028.

Among other changes, the revised rules are expected to alter how A1 certificates are handled, including verifying exemptions, submitting applications in good time before a posting begins, and requiring at least three months of prior employment with the employer.

Multi-state workers will also be able to obtain A1 certificates valid for up to 24 months, subject to renewal. In addition, a two-month cooling-off period will apply after a 24-month posting before a worker can be posted to the same destination again for the same or a similar activity.

Overall, the revised framework should give employees working across borders greater certainty by clarifying which country’s social security system applies and how their rights are protected during international assignments. Employers, however, will need to manage cross-border arrangements more closely, particularly A1 certificate applications, pre-posting employment requirements, assignment length, and repeat postings. They should therefore review their mobility and social security procedures before November 1, 2028, to ensure assignments meet the revised requirements.

United Kingdom:

Home Office introduces Additional SMS Notifications to Strengthen Sponsor License Security

The Home Office has announced additional Sponsor Management System (SMS) email alerts for Authorizing Officers. The notifications are designed to improve visibility of significant license activity, support timely updates to sponsor records, and help organizations identify access or changes that they have not authorized.

Alerts will cover amendments to Level 1 User information and the Authorizing Officer’s contact details, as well as newly assigned Certificates of Sponsorship (CoS). Where a sponsor license recorded fewer than 1,000 CoS assignments in 2025, an email will be issued for every new assignment. All other sponsors will receive a daily summary of new assignments.

Authorizing Officers should read each Home Office communication carefully. An email may also contain a request for further information, notice of an inspection, or a formal decision.

Employer recommendation: As good practice, Authorizing Officers should monitor communications from the Home Office daily and promptly report any activity or changes that they do not recognize or that were not authorized by the organization. This will help sponsors identify potential unauthorized activity and maintain appropriate oversight of their sponsor license.

Reminder:

SMS – Important Changes and Compliance:

Please refer to our September 2026 bulletin for a detailed overview of all relevant changes: EMEA Immigration Updates: EU, UK, Spain & Ireland News.

Additionally, the Home Office reminds sponsors that Sponsor Management System (SMS) user accounts that have remained inactive for at least 12 months will be removed. Sponsors should therefore take the necessary steps to maintain appropriate access to their sponsor license before December 6, 2026.

Organizations must ensure that they have at least one active Level 1 user and that access has been removed for users who have left the organization or changed roles. As a matter of good practice, organizations should ensure that all Level 1 and Level 2 users log in to the SMS before the relevant deadline and continue to do so regularly, ideally at least once a month.

Netherlands:

New IND Preventive Approach to Sponsor Compliance

Effective October 1, 2026, the Dutch Immigration and Naturalization Service (IND) may address certain breaches of the reporting and record-keeping duties applicable to recognized sponsors through preventive measures before resorting to formal sanctions. The change concerns the IND’s enforcement approach and does not create additional obligations for recognized sponsors.

Depending on the circumstances, the IND may contact a sponsor in writing or verbally when certain reporting or record-keeping requirements have not been met correctly or on time. This type of preventive intervention can be applied no more than twice within a one-year period starting from the first identified breach.

Repeated non-compliance or other reporting and record-keeping breaches may lead to an enforcement discussion. Warnings, administrative fines, and other measures nevertheless remain available where appropriate, including in cases involving duty-of-care violations, fraud, or abuse.

For employers, the development makes it particularly important to maintain accurate immigration records and ensure that required notifications are submitted to the IND within the applicable deadlines.

Italy:

Constitutional Court Confirms Validity of Citizenship Reform (“Minor Issue”) – Further Information Following our March Bulletin: March 2026 Global Immigration Recap | EMEA | News & Events | Clark Hill PLC

As previously reported, the Italian Constitutional Court confirmed the validity of recent amendments to the citizenship framework concerning children born abroad to Italian parents who, at the time of the child’s birth, already held citizenship of another country.

In late August 2026, the Ministry of the Interior published a new circular providing further guidance to Italian Consulates on the application of the revised framework. The circular refers to the position of the Italian Supreme Court of Cassation, which clarifies the so-called “minor issue” and addresses a key interpretative conflict that had affected numerous applications for recognition of Italian citizenship.

Under this interpretation, the voluntary acquisition of foreign citizenship by an Italian parent while their child was still a minor does not automatically result in the child losing Italian citizenship.

Importantly, individuals whose applications for recognition of Italian citizenship were previously rejected solely based on the former interpretation of the “minor issue” may now request a review of their original applications. A new application is not required, a request for reassessment is sufficient.

Austria:

New Immigration Rules Increase Flexibility for Foreign Workers

Austria amended its immigration rules to provide greater flexibility and align domestic law with the EU Single Permit Directive. Effective August 7, 2026, the changes provide greater flexibility for both foreign workers and employers, including a simplified process for changing employers, faster government processing times, and greater flexibility for foreign nationals who become unemployed.

Single Permit holders may apply to change employers, subject to approval by the authorities. If the authorities do not respond to the application within 45 days, the foreign national may commence employment with the new employer. In addition, foreign nationals who become unemployed may retain their permits for up to six months, if they notify the relevant authorities. This measure provides a transitional period for affected foreign nationals without requiring them to leave the country immediately.

Regarding government processing times, applications must generally be processed within 90 days of the submission date, with shorter processing deadlines applying to certain categories, including EU Blue Card applications.

For employers, the changes provide greater flexibility in recruiting and retaining foreign workers, particularly where a Single Permit holder wishes to change employers. However, employers should ensure that any change of employment follows the applicable authorization process and should factor the relevant processing periods into workforce planning.

Latvia:

Revised Work and Residence Framework Takes Effect

Latvia’s revised immigration framework took effect on September 15, 2026, changing residence permit validity, application processing, documentary requirements, and certain immigration routes. Some provisions are subject to transitional implementation through December 31, 2027.

Certain employment-based temporary residence permits, previously available for up to five years with annual registration, may now be limited to one year, requiring a new application annually. The maximum processing period for residence permit applications has also been shortened to four months.

Document requirements vary by application type. Initial temporary residence permit applications may use Latvian or English but supporting documents for renewals and permanent residence applications must be in Latvian.

The reform also changes investment-based residence options. Real estate purchases will no longer qualify for temporary residence. A separate route allows applicants to invest at least EUR 150,000 in a qualifying alternative investment fund and maintain the investment for at least five years.

Employers may need to manage immigration compliance more frequently, particularly for employment-based permits limited to one year and requiring annual applications. Monitoring permit validity and preparing filings well in advance will therefore be essential.

Luxembourg:

Immigration Reform Eliminates Temporary Authorization to Stay (AST) Process

Effective October 1, 2026, Luxembourg has restructured the pre-entry immigration process for third-country nationals. The previous Temporary Authorization to Stay (AST) procedure has been replaced by a long-stay Visa D process.

As a result, both nationals who require a visa and those who are otherwise visa-exempt must submit applications for D-Visa directly before relocating to Luxembourg. Applications are made through the competent Luxembourg diplomatic or consular representation, in their country of residence or the relevant Belgian representation, where applicable. The D-Visa is valid for six months.

The new procedure applies to applications submitted on or after October 1, 2026. Applications submitted before this date do not require any additional action from applicants. Instead, the authorities will issue a Type D visa in place of the AST.

The immigration reform also extends the validity of the initial residence permit from one year to up to two years, while renewed residence permits may be issued for up to three years.

Reminder:

Armenia Implements Major Immigration Reforms Impacting Employers Effective November 1, 2026:

Please refer to our March 2026 bulletin for a detailed overview of the immigration reforms content taking effect on November 1, 2026: March 2026 Global Immigration Recap | EMEA | News & Events | Clark Hill PLC

Middle East:

Bahrain:

Electronic Secondment Option Introduced for Expatriate Workers

Bahrain has launched a new electronic secondment service that enables expatriate employees with an existing work permit to take up a temporary assignment with a different employer for up to 90 days.

Applications are initiated electronically by the company seeking to engage the employee and processed through the Labor Market Regulatory Authority (LMRA). Participation requires the agreement of the employee, the current sponsoring employer, and the company requesting the temporary assignment. The employee’s existing work permit must also remain valid for the duration of the arrangement.

The new system creates an additional option for businesses seeking temporary workforce support without permanently transferring an employee’s sponsorship. It may be particularly relevant where additional resources or specific expertise are needed for a limited period.

Kuwait:

Introduction of New 10-year Residence Permit for Former Kuwaiti Nationals

In September 2026, Kuwait introduced a 10-year residence permit for former Kuwaiti nationals who lost their nationality under recent citizenship reforms.

Employment rights under the permit remain unclear, with further official guidance expected.

Permit holders may spend more than six months outside Kuwait without losing their residence status and may include dependent family members under the permit.

Africa:

South Africa:

60-day Advance Filing Requirement Removed for Certain Visa Applications

On October 2, 2026, South Africa relaxed the timing requirements applicable to certain visa applications, and as a result, applicants seeking to extend a visa or change their existing visa status or conditions are no longer required to file the relevant application at least 60 days before the current visa expires.

Importantly, the change removes the 60-day advance filing requirement but still requires the application to be submitted while the current visa remains valid.

The amendment gives employers and foreign nationals a wider filing window when preparing qualifying applications.

Tanzania and Kenya:

Introduction of Mandatory Travel Insurance

Effective October 2026, both Kenya and Tanzania have introduced mandatory travel insurance requirements for certain travelers.

Kenya: Travelers planning to enter Kenya must obtain the required travel insurance through a designated provider before entering the country and be prepared to provide proof of coverage upon request at arrival. The insurance must be valid for one year and may be used for multiple trips during its validity period.

Tanzania: Tanzania has introduced a mandatory travel insurance requirement for travelers entering mainland Tanzania and Zanzibar. The insurance must cover visits of up to 92 days. Residents of the East African Community (EAC) and the Southern African Development Community (SADC) are exempt from this requirement.

For employers, the new insurance requirements introduce an additional pre-travel compliance consideration when arranging business trips or short-term assignments to Kenya and Tanzania. Companies should ensure that affected employees obtain the required travel insurance before departure and carry appropriate proof of coverage where required. Travel policies and pre-departure checklists should also be updated to reflect the new requirements and reduce the risk of disruption on arrival.

Contact Clark Hill

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 October’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.