September 2026 Outbound Immigration and Global Mobility Recap | EMEA

Additional contributor: Olga Sleptcova 

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

EMEA:

European Union:

Entry/Exit System (EES) – Implementation Update

The Entry/Exit System (EES) was scheduled for full implementation by April 10, 2026, following a phased rollout over several months.

The European Union allowed Member States facing operational or internal challenges to temporarily limit EES use through September 2026. Some countries continue to rely on these exceptions and do not yet operate the system consistently at all border crossing points or times: Belgium, France, Germany, Greece, Italy, Malta, the Netherlands, Poland, and Switzerland.

Member States report needing more time to complete deployment and ensure uninterrupted operation. Although the EES should now be active throughout the Schengen Area, travelers may still encounter delays or disruptions at certain border crossing points.

Temporary Internal Border Controls – Update

The European Commission regularly updates its list of Schengen countries that have temporarily reinstated internal border controls. The latest information is available on the Commission’s website: Temporary Reintroduction of Border Control – Migration and Home Affairs

Key developments include Austria, Germany, and Poland extending internal border checks through March 2027, citing concerns related to internal security, migratory pressures, Russia’s aggression against Ukraine, the security situation in the Middle East, and recent incidents in Ceuta.

Denmark, France, Italy, the Netherlands, Norway, and Sweden have also maintained internal border controls for similar reasons. Depending on the country, these measures are scheduled to remain in effect until October, November, or December 2026. Travelers should consult the European Commission’s official website for current, country-specific details.

Spain has temporarily reinstated controls at its internal air and sea borders with Italy through October 7, 2026, citing security concerns and recent migration-related developments.

Travelers should carry valid passports, residence permits, and any other necessary supporting documents to facilitate possible border checks. They should also comply with applicable Schengen stay limits and monitor restrictions that could affect their itinerary.

European Commission Introduces Fair Labor Mobility Package

In a September 15, 2026 press release (Commission proposes ambitious measures to strengthen fair labor mobility), the European Commission introduced the Fair Labor Mobility Package, a set of initiatives designed to strengthen social rights for people living and working in another EU Member State.

The package aims to simplify mobile workers’ access to social security and healthcare benefits and improve recognition of professional qualifications across the EU. It would also help employers recruit across Member States and streamline foreign workers’ access to national labor markets.

According to the European Commission, the package would strengthen protections for mobile workers, improve cooperation among national authorities, and support a more efficient, integrated European labor market.

The package proposes five legislative initiatives:

• A Regulation creating a European Social Security Pass (ESSP)
• A Regulation on digital and comparable qualifications
• A Regulation strengthening the role and enforcement powers of the European Labor Authority (ELA)
• Amendments to the EU Directive on the Recognition of Professional Qualifications
• An EU Directive on the recognition of qualifications held by third-country nationals

Employers should monitor the package’s progress, particularly the proposals concerning the European Social Security Pass, digital qualifications, and recognition of professional qualifications. Companies with cross-border workforces may also wish to review their mobility, recruitment, and compliance processes in preparation for changes intended to facilitate labor mobility within the EU.

United Kingdom:

Sponsor Management System (SMS) Changes and Compliance Requirements

The UK Home Office has announced important changes to the Sponsor Management System (SMS). All UK sponsor license holders should review the changes and take appropriate steps to maintain compliance with their sponsorship obligations.

A key change is mandatory multi-factor authentication (MFA). MFA is automatically enabled for sponsor licenses granted on or after September 9, 2026. Existing sponsors must implement MFA according to the UK Home Office’s phased rollout schedule.

Before MFA is activated, sponsors should review their license records and confirm that all SMS information is current and accurate, particularly contact details and active user accounts.

Sponsors should review all Level 2 Users and decide whether to upgrade them to Level 1 Users or remove them. The UK Home Office is expected to automatically remove any remaining Level 2 User accounts after March 2027.

Sponsors should also ensure that their Authorizing Officer understands the responsibilities of managing the sponsor license and maintaining accurate SMS records. The Authorizing Officer should oversee regular user-access reviews and ensure that at least one active Level 1 User is always linked to the license, as the absence of one may create significant management and compliance issues.

Authorizing Officers should review existing Level 2 User accounts and update, upgrade, or remove them as needed to meet the organization’s operational needs and Home Office requirements.

Reminder: Right to Work Code and New Compliance Requirements Effective October 1, 2026

Please refer to our July 2026 bulletin for a detailed overview of the Right to Work Code requirements and the compliance measures that employers should implement ahead of the changes taking effect on October 1, 2026: EMEA Immigration Updates: Key Global Mobility Changes for July 2026

Spain:

Spain Opens Consultation on Proposed Immigration Law Reform

Spain’s Ministry of the Interior has opened a public consultation on a draft Organic Law amending Organic Law 4/2000 on the rights, freedoms, and social integration of foreign nationals in Spain. Interested parties may submit comments through the formal consultation process from September 23 through October 6, 2026.

The consultation seeks input from individuals whose legitimate rights or interests may be affected, either directly or through representative organizations or associations. Other individuals and entities may also submit comments. Because the proposal remains in draft form, it does not currently change Spain’s immigration framework, work authorization rules, or employer sponsorship obligations.

The consultation creates no immediate compliance obligations. However, employers with foreign national workforces in Spain, business associations, mobility providers, and other stakeholders may wish to review the draft and consider submitting comments because future reforms could affect immigration procedures, workforce mobility, and the employment of foreign nationals.

Although employers face no immediate impact, businesses and industry associations may provide input during the consultation on this potentially significant reform of Spain’s immigration framework.

Ireland:

Government Proposes Changes to the Irish Naturalization Process

The Irish Government has approved the drafting of the Irish Nationality and Citizenship (Amendment) Bill 2026. While the Bill has not yet been enacted and must still complete the legislative process, it proposes significant changes to Ireland’s naturalization framework.

If adopted in its current form, the proposed amendments would introduce several new eligibility requirements, including:

• An increase in the minimum residence requirement from five years to eight years
• A mandatory language requirement, with applicants required to demonstrate proficiency in English, Irish, or Irish Sign Language
• The introduction of citizenship tests covering the Irish Constitution, civics, and government
• A requirement for applicants to demonstrate sufficient financial means, assessed against the applicable annual wage threshold

It is important to note that current naturalization applications are not affected by the proposed changes and will continue to be assessed under the existing legislation.

At this stage, the approval relates only to the drafting of the Bill, which represents an early step in the legislative process. As the proposal progresses through the various stages of parliamentary review, the final legislation may be amended before enactment.

We will continue to monitor developments and provide updates as additional guidance and implementation details are released by the Irish authorities.

Denmark:

Denmark Approves New Work Permit Scheme for Certified Employers

Effective January 1, 2027, Denmark will introduce the Collective Agreement-Based Work Scheme, a new pathway designed to help eligible employers recruit foreign workers and attract international talent.

Employers must meet the following requirements to use the scheme:

• Obtain advance certification from the Danish Agency for International Recruitment and Integration (SIRI)
• Offer employment covered by a qualifying collective agreement
• Hire a national of one of the 16 designated third countries eligible under the scheme
• Meet the applicable salary requirements, which are lower than those for certain other Danish work permit routes

The pathway is limited to employers that satisfy all eligibility criteria and obtain SIRI certification.

Employers considering this route should confirm eligibility and satisfy all requirements before beginning recruitment or immigration processes.

We will monitor developments and provide updates as Danish authorities issue further guidance and implementation details before the scheme takes effect.

Benelux Countries and Sweden:

Schengen Rules Update: Benelux Countries and Sweden Will Not Recognize Non-Biometric Russian Passports

As of October 1, 2026, Belgium, Luxembourg, the Netherlands, and Sweden will no longer recognize non-biometric Russian passports (five-year passports) for travel purposes or visa applications.

Individuals who currently hold a valid visa or residence permit issued by these countries are not expected to be affected immediately. However, new visa and immigration applications will generally no longer be accepted if submitted using a non-biometric Russian passport.

Sweden has established a transition period until December 31, 2026. During this period, holders of non-biometric Russian passports may continue to use such documents for travel if they contain a valid Schengen visa or a valid residence permit issued by Sweden or another EU Member State or Schengen country before October 1, 2026.

In contrast, the Benelux countries (Belgium, Luxembourg, and the Netherlands) have not announced any transition or grace period. Consequently, the new restrictions will apply immediately from October 1, 2026.

Middle East:

Saudi Arabia:

Authorities Update Saudization Requirements for Administrative Support Roles

Saudi Arabia’s Ministry of Human Resources and Social Development has issued an update on Saudization requirements for administrative support roles in the private sector. For details on the original announcement, see our April 2026 bulletin: Global Immigration and Workforce Compliance Updates: UK Digital RTW, EU ETIAS, Middle East Localization, and Africa Reforms

The April 2026 announcement introduced additional Saudization requirements for several administrative support occupations and provided affected employers with a six-month transition period ending October 4, 2026.

Once the transition period ends, 69 additional occupations will become fully subject to Saudization. The requirements apply to all private-sector employers with workers in affected occupations, including administrative support, secretarial, translation, and data entry roles.

Employers should review their workforce, recruitment practices, and staffing plans to identify affected positions and implement any necessary changes before the transition period ends.

Africa:

Angola:

Angola Launches Online Platform for Business and Tourist Visa Applications

Angola’s Immigration and Foreigners Service (SME) has launched a new online platform for business and tourist visa applications: eVISA – eVISA – Serviço de Migração e Estrangeiros

Foreign nationals traveling to Angola for tourism, business, family visits, or other eligible purposes may apply directly through the official portal. According to the authorities, applicants should receive a decision within approximately 72 hours after submitting a complete application.

The platform also identifies countries participating in Angola’s visa-waiver program. Eligible nationals may enter without obtaining a visa in advance for up to 30 days per visit, subject to a cumulative maximum of 90 days per year.

Before applying, travelers should confirm the document requirements for their nationality and visa category.

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 September’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.