The Council of the European Union gave its final approval on 17 November 2025 to an overhaul of the Union’s visa-free suspension mechanism. The regulation allows any Schengen member – including Germany – to trigger a temporary re-imposition of short-stay visa requirements on nationals of a third country much more rapidly than before.
Under the revised rules, the statistical threshold that constitutes a “substantial increase” in irregular migration indicators (refused entry, overstays, asylum claims or serious crime) drops from 50 % to 30 %. The initial suspension can now last 12 months (previously nine) and be prolonged by a further 24 months. Importantly, the Council introduced new grounds that reflect geopolitical and security concerns: lack of alignment with EU visa policy, operation of “golden-passport” schemes and serious deterioration of relations or human-rights standards in the third country. Where problems persist, the Commission can propose the permanent withdrawal of visa exemption.
![EU Council adopts faster visa-free suspension rules, increasing risk of re-imposed visas for travellers to Germany]()
For German corporates that rely on frequent short-term visits by partners and clients from visa-exempt countries, the change heightens travel-planning risk. A partner’s nationality could suddenly shift from visa-free to visa-required within weeks, forcing travellers to secure Schengen C-visas through German consulates and adding biometric and appointment lead-times. Mobility teams should therefore track Commission monitoring reports more closely and build contingency time into travel approvals.
The new regulation also introduces a “targeted suspension” option. Instead of suspending visa-free status for an entire population, the EU could confine the measure to holders of investor-citizenship or to certain passport series. This nuance will matter for German border officers at airports such as Frankfurt and Munich, who will have to screen passports against more granular exemption lists.
Next steps: the regulation enters into force 20 days after publication in the Official Journal (expected early December). Travel-risk teams should brief executives that visa-free access to Germany can no longer be taken for granted, particularly for citizens of Western Balkan and Caribbean states that already face Commission scrutiny.
Under the revised rules, the statistical threshold that constitutes a “substantial increase” in irregular migration indicators (refused entry, overstays, asylum claims or serious crime) drops from 50 % to 30 %. The initial suspension can now last 12 months (previously nine) and be prolonged by a further 24 months. Importantly, the Council introduced new grounds that reflect geopolitical and security concerns: lack of alignment with EU visa policy, operation of “golden-passport” schemes and serious deterioration of relations or human-rights standards in the third country. Where problems persist, the Commission can propose the permanent withdrawal of visa exemption.
For German corporates that rely on frequent short-term visits by partners and clients from visa-exempt countries, the change heightens travel-planning risk. A partner’s nationality could suddenly shift from visa-free to visa-required within weeks, forcing travellers to secure Schengen C-visas through German consulates and adding biometric and appointment lead-times. Mobility teams should therefore track Commission monitoring reports more closely and build contingency time into travel approvals.
The new regulation also introduces a “targeted suspension” option. Instead of suspending visa-free status for an entire population, the EU could confine the measure to holders of investor-citizenship or to certain passport series. This nuance will matter for German border officers at airports such as Frankfurt and Munich, who will have to screen passports against more granular exemption lists.
Next steps: the regulation enters into force 20 days after publication in the Official Journal (expected early December). Travel-risk teams should brief executives that visa-free access to Germany can no longer be taken for granted, particularly for citizens of Western Balkan and Caribbean states that already face Commission scrutiny.
