Immigration Digest 🌏
In September, another wave of immigration changes occurred across popular destinations such as the UK and the US. While the UK is tightening its oversight of sponsors holding sponsor licences and introducing new technical requirements, the US is seeing significant tension between the courts and the Trump administration over sensitive immigration matters, including birthright citizenship and the controversial $100,000 H-1B fee.
At the same time, some countries have revised their investor immigration rules, with changes varying from country to country. In particular, New Zealand is expanding its range of eligible investments, while Panama is strengthening investment verification and Latvia is narrowing the routes available to new applicants.
At the same time, some countries have revised their investor immigration rules, with changes varying from country to country. In particular, New Zealand is expanding its range of eligible investments, while Panama is strengthening investment verification and Latvia is narrowing the routes available to new applicants.
🇬🇧 United Kingdom
Mandatory multi-factor authentication (MFA) for users of the Sponsorship Management System (SMS)
The UK Home Office is introducing mandatory multi-factor authentication (MFA) for all users of the Sponsorship Management System (SMS). The rollout began on 3 September 2026 and is expected to cover all existing sponsors by November 2026. Organisations granted a new sponsor licence on or after 9 September 2026 will have MFA enabled.
❗️ Inactive SMS User accounts can put your sponsor licence at risk.
It is important to keep SMS User accounts active, because if an account is not accessed for 12 months or more, it will be considered inactive and may be deactivated. Sponsors will be contacted and given 3 months to take the required action before inactive accounts are deactivated. If this results in the organisation having no active Level 1 Users, the sponsor licence will be suspended, and the licence being revoked if the sponsor fails to nominate an eligible Level 1 User.
The Home Office has been testing MFA voluntarily with a limited number of sponsors since November 2025. The new requirement now makes the additional security step compulsory across the sponsor licence system and protects sponsor accounts from unauthorised access, even if a password is compromised.
💡 Why it matters:
The change does not alter the substantive requirements of the UK sponsorship system, but it has an important practical impact on how employers manage and access their sponsor licences. Organisations should review the contact details of their Level 1 and Level 2 Users now, particularly where SMS accounts are managed by several employees or external representatives.
Outdated or inaccessible phone numbers and email addresses could create difficulties accessing the SMS once MFA is activated – potentially affecting time-sensitive sponsor actions such as assigning Certificates of Sponsorship or reporting changes.
Mandatory multi-factor authentication (MFA) for users of the Sponsorship Management System (SMS)
The UK Home Office is introducing mandatory multi-factor authentication (MFA) for all users of the Sponsorship Management System (SMS). The rollout began on 3 September 2026 and is expected to cover all existing sponsors by November 2026. Organisations granted a new sponsor licence on or after 9 September 2026 will have MFA enabled.
- Additional login security: SMS users will need to enter a one-time passcode in addition to their username and password each time they access their sponsor account.
- Level 1 Users: The passcode will normally be sent by SMS to the registered mobile number. If no valid mobile number is recorded, it will be sent by email.
- Level 2 Users: The passcode will be sent to the user's registered email address.
❗️ Inactive SMS User accounts can put your sponsor licence at risk.
It is important to keep SMS User accounts active, because if an account is not accessed for 12 months or more, it will be considered inactive and may be deactivated. Sponsors will be contacted and given 3 months to take the required action before inactive accounts are deactivated. If this results in the organisation having no active Level 1 Users, the sponsor licence will be suspended, and the licence being revoked if the sponsor fails to nominate an eligible Level 1 User.
The Home Office has been testing MFA voluntarily with a limited number of sponsors since November 2025. The new requirement now makes the additional security step compulsory across the sponsor licence system and protects sponsor accounts from unauthorised access, even if a password is compromised.
💡 Why it matters:
The change does not alter the substantive requirements of the UK sponsorship system, but it has an important practical impact on how employers manage and access their sponsor licences. Organisations should review the contact details of their Level 1 and Level 2 Users now, particularly where SMS accounts are managed by several employees or external representatives.
Outdated or inaccessible phone numbers and email addresses could create difficulties accessing the SMS once MFA is activated – potentially affecting time-sensitive sponsor actions such as assigning Certificates of Sponsorship or reporting changes.
🇳🇿 New Zealand
Active Investor Plus Visa Expands Eligible Investment Options
On 9 September 2026, New Zealand announced a further expansion of eligible investments under its Active Investor Plus (AIP) Visa. From December 2026,
qualifying Build to Rent developments will be recognised as eligible investments under the Growth category.
💡 Why it matters:
The change creates another potential investment route for high-net-worth individuals interested in New Zealand residency. Investors who prefer exposure to professionally managed property projects may have an additional option beyond the existing eligible investment categories. However, the new route will depend on approved fund structures and the detailed rules still to be published.
Active Investor Plus Visa Expands Eligible Investment Options
On 9 September 2026, New Zealand announced a further expansion of eligible investments under its Active Investor Plus (AIP) Visa. From December 2026,
qualifying Build to Rent developments will be recognised as eligible investments under the Growth category.
- New investment option: Investors will be able to invest in purpose-built rental housing projects through approved managed funds that meet the programme’s requirements.
- Fund requirements: Managed funds offering these investments will need to meet applicable capability, governance and delivery standards.
- Implementation: Further guidance on eligibility, investment structures and timelines is expected before the changes take effect.
💡 Why it matters:
The change creates another potential investment route for high-net-worth individuals interested in New Zealand residency. Investors who prefer exposure to professionally managed property projects may have an additional option beyond the existing eligible investment categories. However, the new route will depend on approved fund structures and the detailed rules still to be published.
🇵🇦 Panama
Panama Tightens Qualified Investor Rules and Adds New Options
On 8 September 2026, Panama issued Executive Decree No. 17, which replaces the previous rules for its Qualified Investor permanent residence programme. The decree took effect on 16 September 2026. It tightens the investment and documentation requirements and sets out the qualifying investment options in more detail.
Key changes include:
Transitional rules: Applications filed before 16 September 2026 are assessed under the previous rules. Investments already made, or binding agreements already signed, may still qualify under the previous rules if the application is filed within 6 months.
💡 Why it matters:
These changes are particularly relevant for investors considering Panama through real estate or a corporate structure. Secondary-market property now requires a significantly higher investment, and the stricter source-of-funds rules make the financial documentation and ownership structure especially important. Investors who already hold a qualifying investment or have a binding agreement in place should note the 6-month transition window.
Panama Tightens Qualified Investor Rules and Adds New Options
On 8 September 2026, Panama issued Executive Decree No. 17, which replaces the previous rules for its Qualified Investor permanent residence programme. The decree took effect on 16 September 2026. It tightens the investment and documentation requirements and sets out the qualifying investment options in more detail.
Key changes include:
- Different real estate thresholds: The minimum investment is now USD 300,000 for a property bought on the primary market (first sale) and USD 500,000 for one bought on the secondary market. Previously, both were set at USD 300,000.
- Bank deposit option: Investors can qualify through a 5-year fixed-term deposit of USD 500,000 with a state-owned bank (Banco Nacional de Panamá or Caja de Ahorros), or USD 750,000 with a private bank holding a general licence. The deposit must be free of liens, pledges and restrictions arising from third-party financing.
- Securities option: A qualifying investment of at least USD 500,000 can also be made through the Panamanian securities market.
- Stricter source-of-funds requirements: The investment must be made with the applicant’s own funds, and their ownership and origin must be traceable. Gifts, donations and other gratuitous transfers from third parties cannot be used to meet the minimum investment.
- Corporate structures: Where the investment is held through a company or foundation, applicants must identify the ultimate beneficial owner and provide evidence of ownership and control.
- Ongoing compliance: The investment must be maintained for five years. Evidence of this must be submitted each year to the Ministry of Commerce and Industries (MICI) through legal counsel, within the 30 calendar days before the anniversary of the immigration approval.
Transitional rules: Applications filed before 16 September 2026 are assessed under the previous rules. Investments already made, or binding agreements already signed, may still qualify under the previous rules if the application is filed within 6 months.
💡 Why it matters:
These changes are particularly relevant for investors considering Panama through real estate or a corporate structure. Secondary-market property now requires a significantly higher investment, and the stricter source-of-funds rules make the financial documentation and ownership structure especially important. Investors who already hold a qualifying investment or have a binding agreement in place should note the 6-month transition window.
🇱🇻 Latvia
Golden Visa Property and Deposit Routes Closed to New Applicants
On 15 September 2026, Latvia’s new Immigration Law took effect and changed the investment routes for residence permits. Applications filed up to and including 14 September were accepted under the previous rules. From 15 September, new applicants can no longer qualify through real estate or bank deposits.
The main changes are:
💡 Why it matters:
The changes significantly narrow the options for investors considering Latvia as a route to European residence. Property and bank deposits, historically the most popular choices, are no longer available. The remaining business route also comes with tighter conditions: annual tax contributions and a shorter, two-year permit. That makes it more suitable for investors who plan to run an active business rather than make a passive investment. Until the state fund is set up, the business route is the only investment option available in practice.
Golden Visa Property and Deposit Routes Closed to New Applicants
On 15 September 2026, Latvia’s new Immigration Law took effect and changed the investment routes for residence permits. Applications filed up to and including 14 September were accepted under the previous rules. From 15 September, new applicants can no longer qualify through real estate or bank deposits.
The main changes are:
- Real estate: The route requiring a property purchase of at least €250,000, plus a state fee of about 5% of the property value, is closed to new applicants. It previously led to a 5-year residence permit.
- Bank deposits: The route involving a €280,000 five-year deposit with a Latvian bank, plus a €25,000 state fee, has also been closed to new applicants.
- Business investment: Investing in a Latvian company remains possible, but on new terms. The minimum is €50,000 for smaller companies (up to 50 employees and a turnover of up to €10 million). For larger companies it is €100,000. Both routes require a €10,000 state fee and minimum annual tax contributions from the company: €40,000 for smaller companies and €100,000 for larger ones. Residence permits under this route are now issued for up to two years instead of five.
- Investment fund: A new route has been introduced: a €150,000 investment through a state-established alternative investment fund, held for at least five years, plus a €10,000 state fee. It can lead to a residence permit of up to five years. However, Latvia’s financial regulator has confirmed that the required fund has not yet been set up, so this route is not currently available in practice.
- Nationality restrictions: Citizens of Russia and Belarus are excluded from the investment-based routes.
💡 Why it matters:
The changes significantly narrow the options for investors considering Latvia as a route to European residence. Property and bank deposits, historically the most popular choices, are no longer available. The remaining business route also comes with tighter conditions: annual tax contributions and a shorter, two-year permit. That makes it more suitable for investors who plan to run an active business rather than make a passive investment. Until the state fund is set up, the business route is the only investment option available in practice.
🇺🇸 United States
1. US Court Blocks Latest Trump Attempt to Restrict Birthright Citizenship
On 2 September 2026, the U.S. District Court for the District of Maryland issued an order and preliminary injunction preventing the federal government from applying the latest Executive Order on birthright citizenship to the affected class of children.
💡 Why it matters:
The court concluded that maintaining the existing position on birthright citizenship does not harm the government, while allowing the Executive Order to take effect could cause serious and irreparable harm to the affected children through the denial of citizenship.
2. Trump Extends $100,000 H-1B Fee
On 18 September 2026, President Trump issued a new proclamation aimed at extending the $100,000 fee requirement for certain H-1B petitions for another 12 months – until 21 September 2027.
❗️The legal validity and enforceability of the policy remain uncertain following an earlier federal district court decision in June 2026, which vacated the policy and found that the $100,000 charge amounted to an unlawfully imposed tax. The existing court order continues to block USCIS from collecting the fee. The government is appealing that decision. If the government succeeds in overturning the court ruling, the extended policy could become enforceable again.
💡 Why it matters:
For now, the new proclamation does not change the practical position for H-1B sponsors – the $100,000 fee remains blocked. However, the extension keeps the policy in place until September 2027, meaning employers and prospective H-1B workers should continue to monitor the ongoing litigation.
1. US Court Blocks Latest Trump Attempt to Restrict Birthright Citizenship
On 2 September 2026, the U.S. District Court for the District of Maryland issued an order and preliminary injunction preventing the federal government from applying the latest Executive Order on birthright citizenship to the affected class of children.
- The Executive Order, issued in August 2026, sought to exclude certain categories of children born in the United States from automatic citizenship.
- Birthright citizenship remains protected for the affected class: The court relied on the Supreme Court’s earlier 2026 decision confirming that the children covered by the class – including those born to parents unlawfully or temporarily present in the United States – are U.S. citizens at birth.
💡 Why it matters:
The court concluded that maintaining the existing position on birthright citizenship does not harm the government, while allowing the Executive Order to take effect could cause serious and irreparable harm to the affected children through the denial of citizenship.
2. Trump Extends $100,000 H-1B Fee
On 18 September 2026, President Trump issued a new proclamation aimed at extending the $100,000 fee requirement for certain H-1B petitions for another 12 months – until 21 September 2027.
- The original policy was introduced in September 2025 and generally targeted certain H-1B workers outside the United States whose petitions required consular processing.
- According to the new proclamation, the Administration considers the 2025 measures to have been effective. It states that, since 21 September 2025, the $100,000 payment has been made for more than 700 petitions.
❗️The legal validity and enforceability of the policy remain uncertain following an earlier federal district court decision in June 2026, which vacated the policy and found that the $100,000 charge amounted to an unlawfully imposed tax. The existing court order continues to block USCIS from collecting the fee. The government is appealing that decision. If the government succeeds in overturning the court ruling, the extended policy could become enforceable again.
💡 Why it matters:
For now, the new proclamation does not change the practical position for H-1B sponsors – the $100,000 fee remains blocked. However, the extension keeps the policy in place until September 2027, meaning employers and prospective H-1B workers should continue to monitor the ongoing litigation.
This immigration digest is for informational purposes only. If you have any specific questions regarding relocation or a particular country program, please reach out to us at beyondborders.relocation@gmail.com or book a free consultation with us