Europe

Rising salary thresholds and cost pressures for employers

Across Europe, governments continued to increase minimum salary thresholds tied to work and residence permits, often linked to broader wage growth or social security ceilings. Germany confirmed increases to pension insurance ceilings effective 2026, directly impacting EU Blue Card and senior skilled worker thresholds.

Ireland announced phased employment permit salary increases from March 2026, with mitigations for recent graduates but further rises expected in 2027.

The Czech Republic and France aligned higher minimum wages and integration requirements with immigration eligibility, raising baseline compliance costs.

The Netherlands updated salary thresholds for Highly Skilled Migrants and labor migrants, differentiated by age and graduate status. Collectively, these measures reinforced a trend toward costlier sponsorship and tighter financial eligibility.

Intensified compliance, audits, and employer accountability

Q4 saw heightened scrutiny on employers’ compliance obligations. The Czech Republic introduced stricter pre-employment reporting requirements for foreign workers, with financial penalties for non-compliance.

The Netherlands expanded administrative duties for recognized sponsors, requiring proof that salaries are deposited into employees’ bank accounts.

Germany increased audits at borders and pre-visa stages, scrutinizing prior travel and potential unauthorized work, while also mandating written provision of labor-law advisory information to new hires from 2026.

The UK plans to expand Right to Work requirements to self-employed, zero-hours, and gig-economy workers, alongside warnings about phishing attacks targeting sponsor licences. These developments signaled a clear shift toward enforcement, traceability, and employer risk management.

Poland has significantly expanded documentation requirements for work permits, introducing new mandatory employer declarations on salary levels, financial capacity, and the foreigner’s criminal record, thereby shifting greater legal and compliance risk onto employers. At the same time, restrictions on work permit exemptions for foreign full-time students—now limited to approved universities—further increase employer verification duties and the risk of unlawful employment.

Digitization, centralization, and border control modernization

Governments accelerated digital immigration infrastructure while tightening border oversight. The EU launched the Entry/Exit System (EES), introducing biometric registration across the Schengen Area with full rollout by April 2026, increasing employer exposure in cases of overstays or unauthorized work.

Germany announced a new Work-and-Stay Agency under its Modernization Agenda, aiming to centralize case handling through a single digital system, with AI-enabled processes expected in future phases.

In December 2025, Poland passed an amendment to the Act on Foreigners introducing full digitalization of residence permit procedures. The changes bring new organizational and technical obligations for foreigners, employers, and legal representatives (including e-signatures and new representation rules) and significantly reshape the existing residence legalization framework in Poland.

At the same time, the UK confirmed strict enforcement of Electronic Travel Authorisation (ETA) from February 2026, significantly impacting short-term business travel planning.

Changes to long-term residence, citizenship, and integration pathways

Several countries adjusted long-term planning frameworks. Germany abolished “Turbo Naturalization,” reinstating a uniform five-year residence requirement for citizenship while maintaining the broader 2024 nationality reform.

France introduced a strengthened integration path from January 2026, increasing civic and language requirements for residence and nationality. Belgium announced a mandatory integration program for non-EU skilled migrants in Flanders from 2027, replacing the voluntary system.

The UK continued consultations on earned settlement and ILR reforms, including proposals that may extend qualifying residence periods from 5 years to 10 years or more and introduce additional eligibility conditions.

Temporary protection transitions and workforce continuity risks

Temporary protection frameworks remained a key focus for employers. Poland extended protection for Ukrainian nationals only until March 2026 and confirmed no further extension, urging employers to transition affected workers into standard immigration routes such as Single Permits. Germany confirmed automatic extensions of Ukrainian protected status until March 2027, supporting business continuity.

Italy has extended temporary protection for Ukrainian nationals until March 4, 2027. This applies to Ukrainians who were already in Italy before February 24, 2022, and currently hold special protection status. The extension is in line with the Council Implementing Decision (EU) 2025/1460 which extends temporary protection for displaced Ukrainians across the EU.

However, the Czech Republic warned of risks linked to automatic loss of temporary protection due to address-registration issues, placing monitoring burdens on both employers and employees. These developments highlighted diverging national approaches and the need for proactive workforce planning.

Policy uncertainty driven by elections, consultations, and future reforms

Political developments introduced uncertainty across several jurisdictions. Dutch general election results signaled a potential shift in immigration and labor policy direction, pending coalition outcomes. In the UK, multiple overlapping consultations covering ILR, earned settlement, skills charges, and shortage occupation frameworks indicated further structural reforms ahead.

Germany’s BAMF Migration Report underscored evolving talent pipelines, including student-to-work transitions, while heightened security reviews in China caused regional visa delays. Employers increasingly face a dual challenge of managing current compliance while anticipating policy change.