Global Alerts

FGI Update: This Week’s Summary of Global Immigration News

HUNGARY: New Immigration Reporting and Employment Procedures and Clarifies Temporary Protection Rules

Hungary’s Immigration Office has announced several immigration-related updates affecting guest self-employed workers, Ukrainian nationals receiving temporary protection, and third-country nationals changing employers. The changes include a new electronic process for fulfilling periodic reporting obligations through the Enter Hungary platform, confirmation that certain Ukrainian temporary protection documents remain valid until March 4, 2028, clarification that military-service-eligible Ukrainian nationals remain subject to existing temporary protection rules, and a new documentation request for certain change-of-employer applications. These developments may require affected individuals, employers, and immigration representatives to update their filing and compliance procedures.

Key Points

• Guest Self-Employment Reporting: Individuals holding a Hungarian residence permit for guest self-employment may now fulfill their required periodic reporting obligation electronically through the Enter Hungary platform. The obligation is completed by filling out and electronically submitting the designated declaration through the platform.
• Temporary Protection Extension: Residence documents issued to individuals granted beneficiary status in Hungary after fleeing the Russia-Ukraine war are considered valid until March 4, 2028, regardless of the expiration date physically printed on the document. The extension applies to all affected documents, including those showing expiration dates of March 4 in 2023, 2024, 2025, 2026, or 2027.
• Ukrainian Applicants Subject to Military Service: Hungary has confirmed that the eligibility requirements for beneficiary status have not changed, meaning Ukrainian citizens subject to military service obligations may continue to receive temporary protection under the rules that have applied since 2022. Individuals who already hold valid temporary protection in another EU Member State will not lose that protection under the new EU rules, but Hungary will reject an application for beneficiary status if the applicant has already obtained protection in another Member State.
• Change-of-Employer Applications: The Hungarian Labour Office will not support issuance of a single permit when another employer holds a valid permit covering a period that overlaps with the requested employment, except where the existing permit authorizes part-time employment. To avoid processing delays, applicants should provide evidence establishing when the previous employment ended.

What Employers Need To Know

• Reporting Compliance: Employers and representatives supporting guest self-employed individuals should ensure that required periodic reporting is completed through Enter Hungary. Compliance with the reporting obligation is important because renewal of the guest self-employment residence permit may be denied if the individual has not properly fulfilled the reporting requirement established by the immigration authority.
• Temporary Protection Documents: Employers of Ukrainian nationals with beneficiary status should be aware that the relevant residence documents are considered valid through March 4, 2028, even if an earlier expiration date appears on the physical document. Employers should therefore account for the statutory extension when reviewing employment authorization and immigration documentation.
• Previous Employment Evidence: Employers filing change-of-employer applications should provide documentation showing that any previous employment covered by a still-valid permit has ended. Acceptable evidence may include an employer-issued certificate confirming the employment end date, a bilateral agreement providing for termination before the new employment begins if authorization is granted, an employer-issued termination notice, or an employee resignation acknowledged by the employer.
• Avoiding Processing Delays: The Labour Office’s request is intended to help establish that there will be no overlapping employment authorizations when the new employment period begins. Providing the requested documentation with the application may help prevent unnecessary delays in the single-permit process.

Looking Ahead

• Electronic Compliance: The availability of Enter Hungary for periodic reporting is likely to make compliance more streamlined for guest self-employed individuals, while also placing greater importance on timely electronic submissions. Employers and immigration representatives should incorporate the electronic reporting process into their ongoing case-management procedures.
• Longer Temporary Protection Period: The March 4, 2028, validity date provides continued immigration documentation coverage for Ukrainian nationals who have been granted beneficiary status in Hungary. Employers should nevertheless continue monitoring developments concerning EU and Hungarian temporary protection rules because future regulatory changes could affect these arrangements.
• Employment Transition Documentation: The new Labour Office request places additional emphasis on demonstrating that a previous employment relationship has ended before a new employment authorization is granted. Employers should obtain appropriate termination documentation early in the change-of-employer process when an existing permit creates a potential overlap.
• Cross-Border Protection Status: Hungarian authorities will continue examining whether an applicant has already received temporary protection in another EU Member State. Individuals considering protection in Hungary should therefore be prepared to disclose and document their existing or previous protection status elsewhere in the EU.

The September 2026 updates provide important procedural clarification for several categories of foreign nationals in Hungary. Guest self-employed individuals should use Enter Hungary for required periodic reporting, employers should account for the March 4, 2028 extension of applicable Ukrainian temporary protection documents, and parties involved in change-of-employer applications should provide clear evidence of the termination of prior employment where permits overlap. These developments underscore the importance of maintaining accurate immigration records and addressing procedural requirements early to minimize potential processing delays.

UNITED KINGDOM: UK Home Office Introduces Multi-Factor Authentication for Sponsor Management System Users

The UK Home Office is rolling out Multi-Factor Authentication (MFA) for users of the Sponsor Management System (SMS) as part of its efforts to strengthen account security. Organisations should monitor their email for notification of their assigned MFA implementation cohort and activation date, review their SMS user information, and ensure that relevant users complete the required preparation before MFA is activated.

Key Points

• MFA Rollout: The Home Office is introducing MFA for all Sponsor Management System users, with organizations being assigned to different implementation cohorts. Sponsors should monitor their email for a notification from the Home Office confirming their assigned cohort and MFA implementation date.
• SMS User Information: Sponsors should review their SMS user details and confirm that the information on file is accurate, including email addresses and, where applicable, dates of birth. Maintaining accurate information will help ensure that users can complete the MFA process without unnecessary administrative issues.
• User Preparation: All internal Level 1 SMS users should complete the required MFA preparation steps before the organisation’s activation date. Sponsors should ensure that relevant users understand the new requirements and are prepared to access the SMS once MFA is enabled.
• Home Office Guidance: Sponsors should familiarize themselves with the Home Office’s MFA guidance before the implementation date. This will help SMS users understand the onboarding process and any steps required to maintain access to the system.

What Employers Need to Know

• Monitor Home Office Communications: Employers should identify and monitor the email account associated with their SMS administration for the Home Office’s MFA notification. Once the organization’s cohort and implementation date are confirmed, the information should be shared promptly with the appropriate immigration or global mobility team and authorized representative.
• Review SMS Records: Employers should verify that all SMS user information is current and accurate before MFA is introduced. Particular attention should be given to email addresses and dates of birth where applicable, as inaccurate information could interfere with the MFA onboarding process.
• Prepare Level 1 Users: Employers should ensure that all internal Level 1 users complete the required MFA preparation before the assigned activation date. Early preparation can help reduce the risk of disruptions to access to the SMS and related sponsor-management activities.
• Coordinate With Representatives: Employers using an authorized immigration representative should promptly provide the representative with the Home Office’s MFA notification and implementation date. Early communication will allow the representative to help coordinate any necessary steps and maintain continuity of immigration support.

Looking Ahead

• Enhanced Account Security: The introduction of MFA will add an additional security layer to access to the Sponsor Management System. Employers should expect secure access requirements to become an increasingly important part of maintaining effective SMS administration.
• Implementation by Cohort: Because organizations will receive individual implementation dates based on their assigned cohorts, sponsors should not assume that MFA will become active for all organizations at the same time. Employers should rely on the specific notification received from the Home Office when planning their preparation and onboarding.
• Ongoing User Management: Employers should continue reviewing their SMS user records and ensuring that only appropriate personnel have access to the system. Keeping user information current will become particularly important as additional security measures are introduced.
• Potential Operational Impact: Employers that do not complete the required MFA preparation before activation could experience difficulties accessing the SMS when they need to undertake sponsor-management activities. Completing the required steps in advance and coordinating with immigration representatives should help minimise potential disruption.

VIETNAM: Increased Penalties for Foreign Worker and Employment Compliance Violations

Vietnam’s new Decree 283/2026/NĐ-CP, which replaces Decree 12/2022/NĐ-CP and governs administrative penalties in the areas of labour and social insurance, took effect on September 10, 2026. The decree aligns Vietnam’s enforcement framework with the foreign-worker management rules introduced by Decree 219/2025/NĐ-CP and expands the compliance obligations applicable to employers of foreign nationals, including by introducing specific penalties for certain notification failures and increasing penalties for several foreign-worker violations.

Key Points

• Work Permit Violations: A foreign national who works in Vietnam without a required Work Permit (WP) or Work Permit Exemption Certificate (WPEC), or who continues working after the relevant document has expired, may face a fine of VND 15–25 million and expulsion from Vietnam. Employers may separately face fines ranging from VND 30–45 million for one to 10 non-compliant foreign employees, VND 45–60 million for 11–20 employees, and VND 60–75 million for 21 or more employees.
• Under-90-Day Assignments: Foreign nationals who work in Vietnam for less than 90 days in a calendar year may qualify for an exemption from both the WP and WPEC requirements under Decree 219. However, employers must notify the competent authority at least three working days before the foreign national begins working in Vietnam.
• Notification Penalties: Decree 283 establishes a specific VND 1–3 million employer penalty for failing to submit the required notification for an under-90-day assignment, submitting it late, or submitting incomplete information. Employers must also complete the required notification as a remedial measure, while the foreign employee does not face a specific penalty solely because the employer failed to submit the notification, assuming the employee genuinely qualifies for the exemption.
• Other Work Authorization Violations: Employers may be fined VND 5–10 million per foreign employee, up to a maximum of VND 75 million per employer, for using a foreign employee in a manner inconsistent with the information stated on the employee’s WP or WPEC. The same penalty range applies to certain failures to return or revoke WP or WPEC documents.

What Employers Need to Know

• Authorization Review: Employers should confirm that each foreign employee either holds the appropriate WP or WPEC or clearly qualifies for an applicable exemption. Employers should also monitor expiration dates and ensure that employees do not continue working after their authorization has expired.
• Under-90-Day Assignments: Employers should distinguish between the foreign employee’s immigration or work authorization status and the employer’s separate notification obligation. Even where a foreign national is exempt from the WP and WPEC requirements because the assignment is for less than 90 days per calendar year, the employer must still submit the required notification at least three working days before work begins.
• Multi-Province Work: Employers must also account for notification requirements when a foreign employee holding a WP or WPEC works for the same employer in multiple provinces or cities. Failure to submit the required notification, or submitting it late or incompletely, may result in a VND 1–3 million employer fine.
• Scope of Authorized Work: Employers should ensure that foreign employees perform work consistent with the position and other information reflected in their WP or WPEC. Changes in duties, employment arrangements, work locations, or other relevant conditions should be reviewed for potential authorization and notification requirements before implementation.

Looking Ahead

• Broader Compliance Focus: Decree 283 reinforces that foreign-worker compliance in Vietnam extends beyond simply obtaining a valid WP or WPEC. Employers will need to manage related notification, work-location, authorization-scope, and end-of-employment requirements as part of their overall immigration compliance programs.
• Greater Attention to Exemptions: Employers relying on WP exemptions should maintain records demonstrating that the applicable exemption requirements are satisfied. The new notification penalty makes it particularly important to distinguish between the underlying exemption and the employer’s separate obligation to notify the authorities.
• Increased Compliance Costs: The expanded penalty framework creates additional financial and operational consequences for employers that do not properly manage foreign-worker requirements. Companies employing foreign nationals in Vietnam should consider incorporating these requirements into regular immigration audits and assignment-management processes.
• Coordination With Immigration Processes: Because Decree 283 implements and reinforces obligations introduced under Decree 219, employers should review their existing foreign-worker procedures to ensure that work authorization, exemptions, notifications, and changes in employment arrangements are handled consistently. Early review of assignments and proposed changes may help prevent avoidable violations and processing issues.

Decree 283 represents a broader approach to enforcement of Vietnam’s foreign-worker rules by imposing specific penalties for notification and other compliance failures in addition to unauthorized employment. Employers should therefore assess each foreign assignment not only to determine whether a WP or WPEC is required, but also to identify applicable notification, work-location, authorization-scope, and other ongoing compliance obligations.

The content of this article is intended only to provide a general guide to the subject matter. It should not be construed as legal advice. Please contact FGI at info@employmentimmigration.com or (+1) 248.643.4900 for guidance if you have specific questions.