Europe
Key trends shaping Europe's labor and immigration landscape
Expanded employer compliance across broader workforce engagement models
European governments continued strengthening employer accountability for immigration compliance, with increasing emphasis on responsibilities that extend beyond traditional sponsorship obligations. The United Kingdom confirmed that Right to Work (RTW) obligations and civil penalty exposure will expand to contractors, agency workers, and other labor arrangements from October 2026, while Romania introduced legislative reforms affecting employer registration, foreign worker recruitment, and visa and residence processes.
These developments reflect a broader shift toward wider immigration compliance.
Skilled migration frameworks increasingly aligned with labor market needs
Governments continued refining immigration programs to address labor shortages while supporting the recruitment and retention of skilled foreign talent. Luxembourg expanded its shortage occupation list to facilitate faster recruitment of qualifying third-country nationals, the Netherlands introduced greater flexibility for accompanying family members of Highly Skilled Migrants during overseas assignments, and the United Kingdom proposed a more transparent methodology for calculating Skilled Worker salary thresholds.
Together, these measures generally provide employers with greater certainty when planning international recruitment and assignments.
Salary and employment conditions remain central to immigration compliance
Employment conditions continued to play an increasingly important role in immigration compliance across Europe. France's increase to the statutory minimum wage (SMIC) has implications beyond employment law, as several immigration-related salary thresholds and employer charges remain linked to the minimum wage. Similarly, the United Kingdom's proposed approach to future Skilled Worker salary thresholds reinforces the growing relationship between remuneration and immigration eligibility.
Immigration policy continues to balance labor market access with tighter migration controls
European governments continued balancing measures that facilitate access to foreign talent with broader migration control objectives. Spain introduced a temporary regularization program allowing eligible undocumented individuals to obtain residence and work authorization, potentially expanding the available workforce. Conversely, Hungary's newly elected government outlined proposals to restrict the admission of non-EU guest workers and discontinue the Guest Investor Program, although these measures had not been enacted during the quarter.
Long-term mobility and workforce planning remain an evolving priority
Alongside operational reforms, several jurisdictions introduced measures affecting long-term workforce mobility and international assignments, while the United Kingdom continued consulting on reforms to its earned settlement pathway without implementing legislative changes during the quarter.
France
From June 1, 2026, France increased the statutory minimum wage (SMIC) by 2.41%. While primarily an employment law measure, the increase has implications as several immigration-related salary thresholds and employer charges remain linked to the SMIC.
Germany
German diplomatic missions continued experiencing increased visa processing times for Russian nationals due to enhanced security reviews, resulting in longer processing periods than standard timelines.
Hungary
Following Hungary's parliamentary elections, the TISZA party secured the largest number of parliamentary mandates and outlined proposed reforms to the country's immigration framework.
The proposals include an indefinite ban on the admission of non-EU guest workers from June 1, 2026 and the termination of the Guest Investor ("Golden Visa") Program.
Luxembourg
On March 27, 2026, Luxembourg's employment agency (ADEM) published the updated 2026 shortage occupation list, expanding it to 20 occupations by adding selected construction and industrial roles while removing others.
Netherlands
Effective April 3, 2026, the Netherlands amended its main residence requirements for accompanying family members of Highly Skilled Migrants. Family members may now remain outside the Netherlands for up to eight months where the principal Highly Skilled Migrant is temporarily abroad for work purposes. The change provides greater flexibility for international assignments while reducing the risk of residence status being affected during overseas postings.
Romania
On April 27, 2026, Romania adopted Emergency Ordinance No. 32/2026, introducing significant amendments to the framework governing the employment of non-EU, EEA, and Swiss nationals. The reforms affect employer registration requirements, foreign worker placement agencies, and key visa and residence procedures.
Spain
Spain approved an extraordinary regularization program through a Royal Decree published on April 15, 2026. Individuals who were present in Spain before January 1, 2026, and satisfy the prescribed eligibility criteria may apply for a temporary residence permit with work authorization during the application period from April 16 to June 20, 2026. The program may expand the pool of individuals eligible for lawful employment. Employers should ensure that affected individuals have obtained the appropriate immigration status and work authorization before commencing or continuing employment.
Sweden
The minimum salary to obtain a Swedish work permit has increased to 90 % of the national median salary, corresponding to a minimum monthly salary of SEK 34,470 under the current threshold. This came into effect from June 16, 2026. The Government has exempted 27 shortage occupations, along with other categories of applicants, from the higher requirement. These groups instead need to meet a salary threshold of 75% of the median salary, in recognition of labor shortages in key sectors.
From June 11, 2026, Sweden introduced new migration rules affecting researchers, doctoral students and international students. The changes make it easier for researchers and eligible doctoral students to obtain residence permits and remain in Sweden after completing their work or studies, while introducing stricter requirements for international students, including tougher rules for switching from a study permit to a work permit.
United Kingdom
The United Kingdom introduced several significant immigration developments during the quarter, with the most immediate impact centered on expanding employer immigration compliance obligations.
Updated sponsor guidance published on April 8, 2026 broadened the scope of Right to Work (RTW) checks to include individuals or contractors that company sponsors wish to employ or otherwise directly engage. This was followed by a public consultation and draft Code of Practice proposing an expanded definition of "employer" and seeking views on preventing illegal working while avoiding unlawful discrimination. Legislation laid on June 30, 2026 subsequently confirmed that, from October 1, 2026, RTW obligations and civil penalty exposure will extend beyond direct employees to include contractors, agency workers, and other labor arrangements, together with repeat checks for relevant existing workers. Employers should review worker engagement models and ensure compliance responsibilities are clearly defined across HR, procurement, and operational teams.
Separately, the Migration Advisory Committee (MAC) published a proposed methodology for calculating Skilled Worker salary thresholds and occupation-specific going rates. Although no immediate Immigration Rules changes were introduced, the proposal provides greater transparency regarding how future salary thresholds may be determined. Employers relying on sponsored workers should monitor future developments and assess roles that sit close to existing salary minimums.
The Government also announced targeted immigration support measures for qualifying high-growth businesses operating in strategic sectors, including visa cost reimbursement and fast-track expansion support for eligible UK scale-ups and certain overseas businesses. In addition, public consultation continued regarding potential reforms to the qualifying residence period for Indefinite Leave to Remain (ILR), although no legislative or Immigration Rules changes were introduced during the quarter.
Collectively, these developments reinforce the need for employers to review sponsorship compliance processes, Right to Work procedures, labor engagement models, and future workforce planning while clearly distinguishing between confirmed legislative changes and proposals that remain under consultation.
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Melissa Rowsell Messchaert
Ashton Porter
Senior Associate