Europe
Key trends shaping Europe's labor and immigration landscape
Digital systems increased immigration compliance oversight
Immigration processes across the region continued to move online, but this quarter’s developments show that digital tools are doing more than simply making filing easier. Across Europe, digital systems increasingly gave authorities and employers greater visibility into immigration status, compliance requirements, and access management.
Austria introduced online filing for certain residence permit applications alongside broader procedural reforms, and Cyprus launched digital renewal services for eligible residence permits. In the Czech Republic, new residence permit codes and a unified monthly employer-reporting framework increased the availability of structured work authorization and employee data. The United Kingdom also moved further toward automated residence monitoring and stronger sponsor management system controls. Together, these developments suggest that digitization is increasing regulatory visibility and employer accountability throughout the visa lifecycle.
Employers may benefit from more streamlined and accessible processes, but data accuracy, system access controls, reporting practices, and reliable status records are becoming increasingly important to immigration compliance. Greater digital oversight increases the importance of accurate immigration records, controlled system access, and consistent reporting. As digital oversight expands, authorities may find it easier to identify data discrepancies, unauthorized access, reporting failures, and immigration status issues.
More-selective eligibility criteria balanced greater mobility flexibility
European immigration policy did not move uniformly toward either facilitation or restriction during Q3. Instead, flexibility expanded for specific populations while other workers faced narrower or more conditional access.
Austria introduced greater mobility options for certain permit holders changing employers and expanded employment opportunities for some dependents. Germany provided a potential route for eligible long-term assignees to continue a temporary secondment without first completing a six-month absence from the country.
At the same time, Lithuania’s exhausted foreign-worker quota made employment-based residence access more dependent on salary. The United Kingdom’s higher Skilled Worker skill threshold also increased uncertainty for occupations below degree level, although recommendations for temporary access through the temporary shortage list have not yet been implemented.
The resulting environment is increasingly segmented. Employers may find greater flexibility where a worker meets defined nationality, occupational, salary, or permit conditions, but outcomes outside of those categories are less predictable.
Naturalization and integration requirements bolstered for long-term status
Citizenship and permanent residence developments showed a stronger emphasis on integration, continuous residence, and personal eligibility. Finland enacted a future citizenship test for relevant applicants, and Ireland proposed increasing its citizenship residence requirement from five to eight years and requiring two years of continuous residence immediately before application. Ireland’s draft legislation would also introduce and/or expand language, civic knowledge, financial, tax compliance, and social-welfare-related criteria, although the proposals remain at an early legislative stage.
Latvia revised its permanent residence framework and discontinued certain investment-based residence pathways. A new EUR 150,000 alternative investment fund route was included in the legislation but had not yet become operational during this quarter, with an operationalization date still pending.
Together, these developments suggest that progression from temporary mobility to durable status may require greater preparation and more sustained evidence of integration or residence. For employers, the immediate work authorization impact may be limited, but the changes could influence long-term retention expectations and employees’ decisions about remaining in a host country.
Austria
Austria implemented amendments to the Settlement and Residence Act and the Act Governing the Employment of Foreign Nationals. The changes introduce a general 90-day decision period; enable certain online applications through ID Austria, the country’s national electronic identification system; and provide eligible non-EU nationals with broader labor-market access and greater flexibility when changing employers.
For employers, the reforms may support faster onboarding, permit renewals, employee transfers, and dependent employment. However, businesses will need to manage notification requirements carefully, particularly where a permit holder changes employers or becomes unemployed, to preserve lawful status and employment continuity.
Cyprus
On July 6, 2026, Cyprus launched a digital service for renewing certain residence permits held by third-country nationals. Eligibility for this digital service is dependent on the type of residence permit application being submitted and the nationality of the applicant.
Employers and foreign nationals may benefit from a more accessible renewal process where the relevant permit category is supported. However, they should confirm eligibility before relying on the digital route and continue to follow the applicable filing process where an application is outside the digital service scope.
Czech Republic
During Q3, the Czech Republic introduced several developments affecting foreign workers and their employers.
Effective August 5, 2026, Ukrainian nationals aged 18–60 who are subject to military obligations must demonstrate compliance with those obligations when applying for temporary protection. The requirement doesn’t apply to extensions of existing temporary protection. Temporary protection remains valid until March 31, 2027, with a further extension through March 31, 2028, approved at the EU level.
New residence permit codes introduced on June 1, 2026, help employers identify whether an Employee Card provides free access to the labor market or requires separate work authorization. Existing permits remain valid and don’t require replacement. Separately, the minimum salary for EU Blue Card holders increased to CZK 73,823 gross per month, effective May 1, 2026.
Employers also continued to experience administrative and data-validation challenges under the unified monthly employer-reporting framework. To reduce the risk of delays and challenges, employers should take responsibility for employee data by verifying information carefully before submission and reviewing internal reporting processes to reduce errors and compliance risks.
These combined changes increase the importance of correctly identifying an employee’s work authorization category, reporting on updated salary figures, and maintaining accurate immigration and employment records. Employers supporting temporary protection holders should also distinguish new applications from extensions when assessing documentation requirements.
Finland
Finland introduced amendments to the Citizenship Act that will take effect on January 1, 2027. Under the revised framework, individuals aged 18–64 submitting citizenship applications on or after March 1, 2027, will be required to demonstrate sufficient knowledge of Finnish society by passing a citizenship test in addition to satisfying the current eligibility requirements.
Employers should ensure that affected employees understand that this new test requirement depends on the application submission date and may require additional preparation as part of their citizenship planning.
Germany
On September 1, 2026, Germany announced planned enhanced entry controls for Russian nationals, intensifying the security screening and processing constraints already affecting this population.
The measures may lead to further scrutiny; longer visa- and residence-permit processing times; and reduced predictability for recruitment, assignments, and business travel involving Russian nationals. The closure of the Russian Consulate General in Bonn, Germany, effective September 18, 2026, may also complicate passport renewals and other consular services required to maintain German immigration status. Employers should allow longer lead times, monitor permit and passport expirations, and account for potential consular delays when planning affected cases.
Separately, the German Federal Employment Agency revised its position on certain long-term secondments. Eligible nationals of Australia, Canada, Israel, Japan, Korea, New Zealand, the United Kingdom, and the United States may be able to transition from an intracorporate transfer permit or personnel exchange assignment to Section 26(1) of the Employment Ordinance without leaving Germany—including after reaching the maximum duration of the original assignment category.
This may enable employers to avoid a six-month interruption in qualifying cases. However, the assignment must remain genuinely temporary rather than becoming unlimited or permanent deployment. Employers should assess the employee’s nationality, current authorization, assignment duration, and continuing temporary secondment conditions before relying on the revised approach.
Ireland
Ireland recently introduced temporary concessions to address delays in Irish Residence Permit renewals; however, both concessions have now expired. Employers shouldn’t treat them as continuing permissions and should verify the current residence and work authorization of employees whose renewals remain pending. As announced on July 16, 2026, employees with expired Irish Residence Permits were allowed to continue working through August 31, 2026, provided they retained a valid employment permit or were otherwise authorized to work. The concession applied regardless of how long the Irish Residence Permit had been expired. From July 13, 2026, through August 31, 2026, qualifying non–European Economic Area nationals were also temporarily permitted to leave and reenter Ireland using an expired Irish Residence Permit, subject to the applicable conditions.
Separately, on September 25, 2026, the Irish government published draft legislation proposing substantial changes to citizenship eligibility. The proposals include increasing the residence requirement from five to eight years; requiring two years of continuous residence immediately before applying; excluding temporary protection from qualifying residence for citizenship; and introducing language, civic knowledge, financial self-sufficiency, tax compliance, and social-welfare-related criteria.
The proposed implementation timeline has not been confirmed, and the measures are not in effect under current law. However, if enacted, they could extend citizenship timelines and affect long-term retention and settlement planning for internationally mobile employees.
Latvia
Latvia enacted its new Immigration Law on September 15, 2026, affecting residence permit documentation, permit validity and administration, investment pathways, student family mobility, and permanent residence. Specified documents supporting renewals, permanent residence, invitations, and sponsorship must now be submitted in Latvian.
The reform also removed annual registration requirements for certain temporary residence permits, discontinued residence pathways based on real estate and subordinated credit institution investments, and introduced a five-year temporary residence requirement before an individual may qualify for EU long-term resident status. Additionally, a new EUR 150,000 alternative investment fund pathway is outlined in the law but is not yet operational because the fund has not yet been established.
Employers and foreign nationals should account for the Latvian-language documentation requirement and revised residence conditions when planning applications and renewals. The new investment route should not be relied upon until it becomes operational.
Lithuania
Lithuania exhausted its 2026 foreign-worker quota of 24,706 during this quarter. Once the quota was reached, employment-based temporary residence permits could generally be issued only where specified salary requirements were satisfied, including monthly compensation of at least EUR 2,893.68 or EUR 2,411.40 for occupations included on the high-value-added shortage list.
The quota exhaustion may restrict lower-paid foreign recruitment and increase the employment costs associated with affected immigration cases. Employers should assess proposed compensation against the applicable postquota threshold before proceeding with recruitment or a residence permit application.
Separately, Lithuania announced that Temporary Residence Permit applications could no longer be submitted through external service-provider offices in Bosnia-Herzegovina, Kazakhstan, Kyrgyzstan, and Uzbekistan from November 1, 2026. Employers recruiting applicants who would ordinarily use those locations should identify an available alternative filing route and account for possible changes to application planning and travel.
United Kingdom
During Q3, the United Kingdom advanced a series of changes affecting employer compliance, sponsored work, business travel, digital status monitoring, and sponsor license governance.
Legislation laid on June 30, 2026, proposed that right-to-work obligations and civil penalty exposure would extend beyond conventional employees to contractors, agency workers, gig economy workers, and other labor arrangements. These changes took effect on October 1, 2026.
This marked a transition toward implementation of a broader labor-engagement compliance model. Employers should ensure that right-to-work controls extend across HR, procurement, contingent workforce, and operational functions, rather than remaining limited to directly employed workers.
Effective August 3, 2026, children born in the UK during a parent’s current Graduate route permission may obtain dependent permission in line with that parent. Employers should consider affected dependents when planning family travel or a transition to Skilled Worker sponsorship.
Separately, effective August 3, 2026, an electronic travel authorization (ETA) may be refused or canceled where a traveler has received a suspended custodial sentence of at least 12 months for a criminal offense. The rule is not limited to specific offenses. Applications submitted before August 3, 2026, remain subject to the rules in effect on August 2, 2026. Businesses should identify relevant criminal convictions before travel, as affected individuals may need to apply for a Standard Visitor visa, increasing cost, scrutiny, and processing time.
The Migration Advisory Committee recommended that only 28 occupations retain temporary access to the temporary shortage list for an 18-month period following the Skilled Worker skill threshold increase to RQF Level 6. These recommendations were expected to inform Immigration Rules changes from January 2027, but no confirmed government decision or implementation date has been announced. Employers should monitor developments before the existing arrangements end on December 31, 2026, and shouldn’t treat the proposed occupation coverage as final when planning sponsorship for roles below degree level.
The Home Office also expanded automated monitoring of EU Settlement Scheme residence data. Presettled status holders whose residence history indicates they may no longer meet the relevant requirements could face curtailment or cancellation, even where their digital record shows a future expiration date. Employers should avoid relying exclusively on the displayed expiration date when supporting affected workers and should encourage employees to retain accurate evidence of UK residence and travel. There’s no routine employer upload requirement, and evidence should be provided through the Home Office’s specified process if the employee is asked to explain absences or receives a notice of intended curtailment.
Scotland separately proposed a new Scottish Visa, Scottish Graduate Visa, and Rural Visa pilot, together with Scotland-specific flexibility within the wider UK immigration system. These are policy proposals only at this stage and don’t create routes open for applications. The proposed new visa pathways require agreement from the UK government and amendments to the immigration rules.
Effective September 9, 2026, sponsors can no longer appoint new level 2 users to the UK’s sponsor management system. Existing level 2 accounts may remain temporarily but must be removed or, where eligible, converted to level 1 status before the Home Office deactivates remaining accounts after March 8, 2027.
The level 2 role removal may require employers to redesign system access, particularly where sponsor responsibilities are distributed across multiple HR teams, locations, or external advisers. Sponsors should review existing users, identify appropriate level 1 access, and maintain sufficient governance and operational coverage before the transition concludes.
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Melissa Rowsell Messchaert
Ashton Porter
Senior Associate