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EU Visa Code Reform: Priorities for Better Schengen Business Travel

October 23, 2026

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  • European UnionEuropean Union
  • BelgiumBelgium

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Jo-Antoons

Jo Antoons

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Brussels, Belgium

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By: Jo Antoons, Elisabeth Kamm

Managing business travel to Europe involves significant uncertainty. A Schengen C visa appointment may be readily available in one location but almost impossible to secure in another. The same business activity may be accepted in one Member State and treated as work requiring additional authorisation elsewhere. With no visibility of the status of a submitted application, businesses also remain uncertain whether a traveller will be able to attend a scheduled meeting or event. 

The European Commission’s review of the EU Visa Code is an opportunity to address these practical barriers.  

Drawing on clients and colleagues’ experience across Europe, Fragomen Consulting Europe submitted a position paper to the Commission’s call for evidence, which closed on 6 October 2026. Our recommendations reflect the practical challenges companies and travellers encounter when navigating short-term business mobility across the Schengen area.  

We recommend that EU Visa Code reform focus on a number of key priorities for business travel, including:  

      •  Schengen-wide trusted-employer mobility framework;
      • clearer and more consistent rules on permissible business activities;
      • more reliable access to visa appointments; and
      • more transparent and effective procedures for understanding visa refusals and factual corrections.  

Create a Schengen-wide Trusted Employer Mobility Framework 

Frequent business travellers and the companies supporting them repeatedly provide much of the same information when applying for Schengen C visas.  

We recommend establishing a Schengen-wide trusted-mobility framework for verified employers and reliable travellers. Businesses should be able to reuse corporate and sponsorship information once it has been verified, rather than submit it for every trip. Their employees could then benefit from priority appointments, faster processing and longer-validity multiple-entry visas. 

Existing national pathways, including the Netherlands’ Orange Carpet and Denmark’s Red Carpet, provide useful examples for inspiration. Our position paper sets out two possible models for a broader Schengen-wide framework: 

      • A verified-information model, under which previously verified information can be reused while assessing each trip, 
      • A pooled-resource model, which would go further by pooling resources and allowing eligible business travellers to apply at any Schengen consular post.  

A trusted employer system could reduce repetitive administration while preserving the assessment required for individual journeys.  

  1. Bringing Greater Clarity and Consistency to Permissible Business Travel 

A persistent challenge for businesses is the differing interpretation of what constitutes a short-term business activity across Europe. Activities such as training, technical support and repairs can be assessed differently by different Member States. Some may classify an activity as requiring a work permit, while others may consider it permissible under business visitor status. The duration of an activity can also change the outcome.  

Businesses can encounter differences even between consulates representing the same country. The result is uncertainty for organisations trying to determine whether a planned trip qualifies as business travel or requires additional work authorisation.   

We recommend the introduction of a common minimum definition of permissible business activity, drawing on the EU Blue Card Directive.  

Visa-exempt nationals should also be able to undertake activities that are exempt from work authorisation without being required to obtain a short-stay visa solely because they are remunerated. 

2. Address Visa Appointment Scarcity and Improve Application Experience 

For many applicants, securing a visa appointment is the greatest obstacle in the Schengen visa process.  

Automated tools and intermediaries can capture appointment slots for resale. At the same time measures designed to stop this activity can inadvertently block legitimate employers using corporate networks or VPNs. 

We recommend enforceable timeframes for appointment access and processing.  

Where a responsible consulate cannot offer an appointment within a reasonable period, applicants should have an alternative means of submitting an application, potentially at a different consular post. 

External providers such as VFS Global and TLScontact shape much of the applicant experience. Member States should remain accountable for the services delivered on their behalf.  

That should include:  

      • clear standards; 
      • reliable and transparent online application tracking; 
      • effective escalation channels; and  
      • a clear distinction between mandatory and optional services. 

3. Make Schengen Visa Refusals Understandable and Correctable 

A Schengen C visa refusal can be difficult for employers and an applicant to understand.  

Usually, an applicant receives a standard form with a box ticked but little meaningful explanation of the reason for the decision. The problem becomes more acute where a refusal is based on a factual error and there is no practical way of correcting that mistake before the planned trip.  

We recommend making meaningful reasons for refusal mandatory, alongside a rapid way to correct factual mistakes. The appeal process needs to be able to deliver a decision while travel is still possible.  

Travel history, including information held in the Entry/Exit System (EES), should be assessed in context rather than treated as conclusive without considering the traveller’s explanation. 

Greater clarity also matters when one Member State’s consulate processes an application on behalf of another. In these cases, the rules of the destination State should govern the assessment, so travellers are not disadvantaged by the practice of the State handling their application. 

Building a More Workable System for Frequent Business Travel  

The priorities above form part of a broader set of recommendations we set out in our position paper.  

We also call for greater flexibility for genuine frequent business travellers approaching the 90/180-day limit, and for the consistent application of existing travel facilitations. Visa restrictions should not impede the mobility of talent and essential travellers. 

Need To Know More? 

We welcome conversations about Schengen C visas, business travel and wider European workforce mobility. Client insights help us bring operational experience into European policymaking.  

To request the full paper or share your experience, contact Fragomen Consulting Europe at [email protected]. 

This blog was published on 23 October 2026 and reflects information available at that time. Updates may occur as policies evolve. To stay informed on the latest immigration news and analysis, please subscribe to our alerts and follow Fragomen on  LinkedIn, Facebook and Instagram.   

Countries / Territories

  • European UnionEuropean Union
  • BelgiumBelgium

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

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  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

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  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Brussels, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Related offices

  • Brussels

Share

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  • Facebook
  • LinkedIn

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Important Updates
Important Updates
October 21, 2026 | AustraliaAustralia: Student Visa Application and Family Inclusion Rules Tightened
October 22, 2026 | NetherlandsNetherlands: New Measures for Addressing Notification Non-Compliance
October 22, 2026 | United StatesUnited States: November 2026 Visa Bulletin – Employment-Based Final Action Dates Advance and Dates for Filing Hold Steady for Most Countries; USCIS to Honor Dates for Filing for Employment-Based Categories
October 22, 2026 | 🌐Worldwide: Temporary Government Website Outages Result from Fixes for Internet Security Vulnerability Issue
October 21, 2026 | AustraliaAustralia: Character Considerations for Visa Decisions Strengthened
October 21, 2026 | AustraliaAustralia: Student Visa Application and Family Inclusion Rules Tightened
October 22, 2026 | NetherlandsNetherlands: New Measures for Addressing Notification Non-Compliance
October 22, 2026 | United StatesUnited States: November 2026 Visa Bulletin – Employment-Based Final Action Dates Advance and Dates for Filing Hold Steady for Most Countries; USCIS to Honor Dates for Filing for Employment-Based Categories
October 22, 2026 | 🌐Worldwide: Temporary Government Website Outages Result from Fixes for Internet Security Vulnerability Issue
October 21, 2026 | AustraliaAustralia: Character Considerations for Visa Decisions Strengthened
October 21, 2026 | AustraliaAustralia: Student Visa Application and Family Inclusion Rules Tightened
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