Business immigration updates for employers | April 2026

April has been a quieter month for business immigration updates – which has allowed our readers to embrace (some) sunshine over the UK Easter bank holiday! We've summarised the key changes and updates this month for businesses and employers to understand and act.

EU Entry/Exit System (EES) fully operational from 10 April 2026 

The European Commission has confirmed that the EU Entry/Exit System (EES) became fully operational on 10 April 2026 across 29 participating European countries, following its phased introduction from 12 October 2025.

The EES replaces traditional passport stamping with a centralised digital border management system. It records the entry and exit dates, refusals of entry, and biometric data (fingerprints and facial images) of non‑EU nationals travelling for short stays (up to 90 days in any 180‑day period) within the Schengen area. Travel document details are also stored and made accessible to border authorities across participating states. The EES is designed to identify fraud more easily and take the necessary enforcement action at Europe's borders.

For business travellers, particularly those who travel frequently or at short notice, the introduction of EES is expected to result in:

• Longer processing times at external EU borders, especially during peak travel periods
• Additional delays for first‑time travellers, who must complete biometric enrolment
• Greater scrutiny of travel history, length of stay and documentation

Practical steps for employers:

• Update internal business travel guidance and policies for staff travelling to the EU/Schengen area.
• Build in additional time at borders, particularly for first trips after EES implementation.
• Ensure travellers carry appropriate supporting documentation (purpose of travel, accommodation details, return travel evidence).

Source: The Entry/Exit System will become fully operational on 10 April 2026 - Migration and Home Affairs

UK to rejoin the Erasmus+ programme from 2027

Following Brexit, the UK withdrew from the Erasmus+ programme on 1 January 2021, which immediately halted many overseas programmes offering opportunities for individuals to study, train, gain work experience or volunteer abroad within the EU.

This latest update from the Department for Education confirms that, the UK and EU have signed an agreement for the UK to rejoin the Erasmus+ programme as an associated third country, starting in January 2027. It is expected that more than 100,000 people will participate in the first year, including students, apprentices, educators and school groups. This reciprocal programme means that UK students, apprentices and trainees will once again be able to take EU‑funded study and work placements in Europe, while EU participants return to the UK on the same footing. The participants will be exempt from overseas tuition and examination fees, receiving scholarships to subsidiarise their travel and living costs, making the experience more affordable.

Practical steps for employers:

• Update recruitment strategy and frameworks to recognise the Erasmus+ programme as high-value work experience.
• UK employers should engage with EU colleges and universities in 2026 to discuss how they can host EU individuals.
• Watch out for the British Council employer guidance expected later in 2026.

This appears to be a significant step forward in a renewed relationship with the EU that will strengthen the UK's talent supply, skills and EU labour-market connectivity.

Consultation launched on a new draft code of practice for employers on avoiding unlawful discrimination while preventing illegal working

The Home Office has launched a consultation on the new draft updated code of practice for employers on avoiding unlawful discrimination while preventing illegal working. The revisions reflect the upcoming changes to broaden the scope of the right to work regime to include worker contracts, individual sub-contractors and online matching services.

Interestingly, Parliament is yet to confirm when the extended legislation for right to work checks will commence, but the updated code is expected to come into force on 1 October 2026. So, we would anticipate a similar commencement date for the expansion of the illegal working regime beyond traditional employment relationships.

Practical steps for employers:

• Map all your working relationships – not just employees – so you can understand the impact of this expansion.
• Start to identify where right-to-work checks are not currently completed.
• Consider how your internal systems and processes can be updated to comply with this new enhanced right to work provision. 

Looking ahead - ICIBI inspection of the Future Border and Immigration System (FBIS) programme

The Independent Chief Inspector of Borders and Immigration (ICIBI) has commenced an inspection into the Future Border and Immigration System (FBIS) programme. The inspection will focus on the extent to which the programme has delivered the intended benefits arising from the Home Office’s move to digital border and immigration systems.

In particular, the inspection will examine:

• The transition of digital immigration permissions (including eVisas) from project delivery into business‑as‑usual operations;
• Whether the anticipated benefits of Electronic Travel Authorisations (ETAs) and eVisas are being realised in practice; and
• The generation and sustainability of ETA and eVisa fee income as part of the Home Office’s wider border strategy.

The inspection forms part of ICIBI’s oversight role in assessing whether large‑scale immigration and border reforms are delivering measurable operational, financial and user‑experience benefits. The inspection team expects to report to the Home Secretary by July 2026.

The inspection signals continued scrutiny of the Home Office’s digital‑first approach to immigration status and border control. Regardless of the outcome, employers should expect:

• Ongoing reliance on eVisas, digital status checks and ETAs;
• Continued refinement (rather than reversal) of digital systems; and
• Potential operational changes following ICIBI recommendations.

Source: Inspection announcement: An inspection of the benefits arising from, and enabled by, the Future Border and Immigration System programme - GOV.UK

Please get in touch with our business immigration team on the contact details below if you require further advice on the changes, sponsorship licences or sponsor duties more generally.