New EU visa strategy published: Real progress or just hot air?

The gateways to Europe are facing a digital and legal transformation unlike anything we have seen before. With document COM(2026) 43 final, the European Commission has presented a comprehensive strategy aimed at modernizing existing visa regulations. For us, as a law firm that grapples daily with the hurdles of the Schengen Borders Code and the Visa Regulation, this signals a new beginning . While the previous system was often characterized by rigid deadlines and bureaucratic opacity, the new document promises to build a bridge to global opportunities. It is no longer just about mere administration, but about a strategic lever for both economic growth and security. We take a look behind the scenes of this announcement and analyze the specific legal changes that travelers , businesses , and skilled workers can expect.

Rethinking mobility: Breaking the 90-day rule

One of the most exciting aspects of the new strategy concerns the hitherto almost sacrosanct "90-days-within-180-days" rule . For many highly mobile professional groups, such as international touring artists , elite athletes , or truck drivers in the cross-border logistics sector, this limit has so far represented a significant obstacle. The Commission has recognized that a stay of more than 90 days does not necessarily constitute permanent residence, which would require a national visa of category D. We expressly welcome the fact that the introduction of specific rules for "extended short stays" is now being considered. This could create an entirely new legal category that bridges the gap between the classic Schengen visa and full residency, thus reflecting the operational reality of globally networked professionals.

A paradigm shift for companies and talent?

The strategy contains groundbreaking approaches for the European economy, and especially for innovative start-ups. A key element is the planned introduction of a list of "verified companies ." Employees of these trusted firms would benefit from accelerated procedures (fast-track). This would supplement the current practice of individual case reviews with a systemic trust model. This is complemented by the consideration of issuing multiple-entry visas with a validity period significantly exceeding five years. Until now, five years often marked the absolute maximum. Extending this period for demonstrably reputable travelers ("bona-fide applicants") would not only reduce administrative burden but also raise planning certainty for international business relationships to a new level.

Innovation, research and humanitarian responsibility

The EU is also planning a realignment in the field of research through a so-called "omnibus" procedure for start-up founders and innovative entrepreneurs. In parallel, the complete digitalization of the visa process is intended to reduce bureaucratic hurdles. The strategy also emphasizes that the Visa Code continues to offer flexibility for vulnerable individuals such as human rights defenders. The Commission has updated the Visa Manual to facilitate the harmonized application of these humanitarian exceptions.

The downside: Visionary strategy meets lack of implementation

Despite these bright prospects, we as practitioners must issue a clear warning: there is a real danger that this strategy, like so many before it, will end up as nothing more than hot air . The core problem with European visa law is rarely the legal framework itself, but rather the glaring shortcomings in the enforceability of existing rights. Even today, applicants complain about waiting months for appointments and opaque decision-making processes, despite the Visa Code stipulating clear deadlines.

A new strategy does not solve the structural problem that member states chronically underfund their consulates or interpret legal requirements arbitrarily . As long as there are no effective sanction mechanisms against member states that delay procedures, the promised "fast tracks" and "facilitations" remain mere theory on paper. While the Commission acknowledges that the lack of support from an EU agency is a shortcoming, we doubt whether a simple "support office" within Frontex is sufficient to guarantee comprehensive law enforcement. Without a radical improvement in operational implementation on the ground, the strategy remains a toothless tiger.

Our conclusion

The new EU visa strategy COM(2026)43 is an ambitious roadmap that addresses the real pain points of the economy and mobile society. However, we remain skeptical: as long as the EU fails to address the massive shortcomings in enforceability and practical implementation, little will change for the frustrating reality faced by many applicants. As your law firm, we will not only utilize the new legal options on your behalf, but above all, we will continue to exert pressure where authorities ignore their legal obligations.

Here is the full text of the new EU visa strategy: https://home-affairs.ec.europa.eu/eu-visa-strategy_en