Frontiers - immigration update

U-turn: 'Turbo naturalization' to be abolished again 

What?

In June 2024, a reform of the German Nationality Act came into force which allowed for 'turbo naturalization' by reducing residence requirements for citizenship. The new federal government has now announced plans to abolish this. The fast-track naturalization currently allows citizenship after only three years if applicants can show special integration achievements, such as excellent language skills. 

When?

A draft bill is already under discussion in the Bundestag. The law is expected to take effect this summer. 

So what?

The draft legislation includes a cut-off date for turbo naturalization applications that have been submitted but may not be processed in time due to frequent delays. Employers should ensure that any affected employees check whether they are still eligible to apply under the current rules and ensure that all application documents are submitted as soon as possible. 

Digital passport photos: less bureaucracy, more security 

What?

Photos in Germany for passports, ID cards and electronic residence permits can now only be submitted in digital form. The digital photos must be taken by certified photo service providers, special photo terminals located in public authorities or via selected apps. They are then transmitted securely in an encrypted form via a cloud service directly to the issuing authority. 

When?

The digital photo requirement became mandatory on 1 May 2025. There is a transition period until 31 July 2025, during which paper photos are still accepted within Germany. From 1 August 2025, only digital photos will be allowed, with paper photos rejected without exception. 

So what?

Employers should ensure any employees, particularly those applying for residence permits, use digital photos to avoid delays. 

This digital process will ensure higher image quality, more secure transmission and hopefully faster, more efficient administrative procedures which is useful for employers who may have employees that require residence permits to work and reside in Germany. 

Updates to Spanish student visas 

What?

Numerous changes have been introduced to student visas including that graduates will no longer be able to directly switch to a work residence permit and a work visa following completion of their studies. Residence permits for higher education will now be granted for the duration of studies, rather than on an annual basis. 

When?

These changes came into effect on 20 May 2025. 

So what?

Of interest for employers who employ a lot of graduates straight out of university, as the process of acquiring a work visa and residence permit will be less simple. 

Potential reforms 

What?

The following changes are proposed: 

• the acquisition of Portuguese nationality requiring at least 7 or 10 years residence in Portuguese territory (depending whether the applicant is a citizen of a Portuguese-speaking country)
• sufficient knowledge of the Portuguese language and culture being a requirement for acquiring Portuguese nationality
• sufficient knowledge of Portugal's political organisation and fundamental rights and duties being a requirement of acquiring nationality
• when calculating residence periods, the time between the submission of a temporary residence permit application and the date of its approval not being considered. 

When?

The proposals still need to go through the legislative process and with the Portuguese government lacking majority support in Parliament, it is likely the proposals will be amended. 

So what?

We will provide an update in upcoming editions of Frontiers as to what reforms, if any, have been made. 

Key amendment to the Act on Foreign Nationals 

What?

Following on from the last edition of Frontiers, the Act has now been amended, introducing changes to the EU Blue Card. The Blue Card guarantees legal and stable employment for non-EU citizens on the same terms as those applicable to EU citizens. 

The amendment has revised the definition of "higher professional qualifications" to include not only higher education qualifications, but also those acquired through professional experience. This broadens the application of the Blue Card. 

New forms of both short-term and long-term mobility are provided for with EU Blue Card holders able to relocate to another EU Member State under preferential conditions. 

Family members of EU Blue Card holders will be able to apply for a temporary residence permit for the purpose of family reunification with a foreign national residing in Poland. 

When?

The Act was amended on 1 June 2025.

So what?

This will give employers a larger group of applicants to recruit from and allows non-EU citizens to remain united with their families whilst in Poland.

New Act on Employing Foreign Nationals in Poland 

What?

The legislation discussed in the last edition of Frontiers has now been enacted. The Act introduces a classification of work permits, new procedures for granting them and specific conditions that must be fulfilled to qualify for the permits for the employment of foreign nationals in Poland. 

The legislation also provides for the full digitisation of the work permit issuance process, which should enhance efficiency. 

When?

The legislation came into force on 1 June 2025.

So what?

Employers need to ensure that they comply with this legislation as penalties for the illegal employment of foreign nationals range from PLN 3,000 to PLN 50,000.

This legislation will greatly expand the recruitment pool in Poland with employers no longer having to confirm that the job cannot be completed by a Polish candidate before hiring foreign nationals. 

Clarification of the 30% ruling for highly skilled migrants 

What?

The 30% ruling allows employers to provide highly skilled migrants with up to 30% of their salary tax free. This means migrants benefit from higher net salaries. It has been clarified that employers must still ensure that highly skilled migrants' gross salaries meet the applicable salary criteria for their visas.  

When?

The Immigration and Naturalization Service (IND) provided the clarification on 21 March 2025. 

So what?

Employers must ensure that the gross salaries of highly skilled migrants meet the salary thresholds of the IND to avoid interfering with the immigration status of employees. 

Radical changes to immigration rules 

What?

A number of changes are proposed to the immigration system. These include that migrants will need to reside in the UK for at least ten years before they can apply to settle (currently five years). The criteria for skilled worker visas will be narrowed, with a university degree being required. Graduate visas will have a reduced period of post-study work of 18 months, from the current two years. 

When?

No fixed date has been given for some of the changes coming into force, for example, the reduction in the graduate visa length. The narrowing of the criteria for skilled worker visas will take effect from 22 July 2025. 

So what?

These changes are likely to make hiring or posting people other than British or Irish nationals to the UK more expensive. For example, with the time period for settlement being extended, employers will need to sponsor employees and pay the corresponding fees for longer. The skilled worker visa criteria being restricted and the post-study work period for graduate visas being reduced may particularly impact employers who employ graduates. 

You can read more about these changes here and here. 

Right to work checks extended to gig economy workers

What?

Under the current law, right to work checks need to be done for individuals engaged as employees under standard contracts.

 It is proposed that right to work checks shall be extended to employers and businesses who engage individuals in non-employment relationships, such as those acting as workers and through online matching platforms. 

When?

The government has not yet confirmed when these changes will come into effect. 

So what?

Employers should review their current right to work processes to consider whether they can be scaled up to apply to more of the workforce. Employers should ensure that their right to work policies are up-to-date and consider what changes may be required to comply with the proposed reforms. 

You can read more about the changes here.