Last Updated on May 9, 2023
For thousands of years, immigration has been an important tool to help people move around the world. Immigration has historically provided countries with economic, social and cultural benefits. Ultimately, it has given rise to multicultural societies worldwide.
Immigration patterns have changed over time for various reasons including the demands of colonization and the pursuit of economic and religious freedoms. Initially, human migration was not regulated, and it was influenced by many factors. After World War II, the refugee movement that lasted through the 1960s heavily influenced human migration patterns. Immigration to Europe increased drastically, which led to a polarization of views on immigration among the European countries. Some countries welcomed and even pursued immigrants, while others started placing caps on immigration levels.
Today, immigration is influenced by politics, economics and changing societies. Governments around the world continually refine their immigration policies and adjust them based on their own needs. Some of the changes they make include increasing the pathways available for immigrants and raising their immigrant quotas for either employment-based immigrants, family-based immigrants or both.
Over time, countries with similar immigration ideologies have clustered themselves into different immigration regimes. While each country has its own policies regarding immigration, countries with similar immigration policies tend to have similar histories with immigration and colonization, similar political ideologies and similar economies.
The concept of immigration regimes, while complex, can be helpful for human resources professionals to dive deeper into. Understanding how countries around the world have historically and currently approached immigration will help HR and mobility teams determine global mobility strategies for their workforce.
What are Immigration Regimes?
An “immigration regime,” as defined by Crossroads authors Anna K. Boucher and Justin Gest, is the “migration policies and their outcomes that collectively reflect the admission and settlement of foreign-born people over time.”
A regime includes the immigration policies adopted by member states and how those policies affect the movement of people into and out of a country. Although some countries within certain immigration regimes are close to each other geographically, others are much farther apart and are connected by similarities such as political ideology, trade agreements and economics.
This article introduces the types of immigration regimes that currently exist around the world, with the general concept of the world’s immigration regimes and explanation of their frameworks introduced in Crossroads.
The major immigration regimes of the world include:
- Free Movement
- Outlier nations
In addition to this article, future content from Envoy will explore the immigration regimes in more detail through a series of webinars, infographics and much more.
Neoliberal Immigration Regime
The Neoliberal regime is defined as having a large volume of family-based immigration policies, but they also have many employment-based programs. Today, the Neoliberal regime countries are attractive destinations for foreign talent because they have stable, free market economies and mostly favorable immigration policies.
Except for the UK, the Neoliberal countries were all colonized states, and their founding is strongly connected to immigration. The UK was a major colonizer of the other countries in this regime.
The Neoliberal regime countries include:
- United States
- United Kingdom
According to Crossroads, historical immigration trends and characteristics of neoliberal immigration regime includes:
- High naturalization rates.
- Immigration largely focused on labor.
- Free market economies that make these countries desirable destinations for migrants.
- High numbers of work-related visas, both temporary and permanent.
- Overall openness to immigration.
- Extending benefits of citizenship only if it’s beneficial for the economy (the U.S. being an exception).
- Temporary migration models focused on short-term needs of employers.
One of the most popular countries for immigration among the neoliberal regimes is Canada. The Canadian government considers employment-based immigration to be an optimal solution for its aging population and workforce.
Along with welcoming immigrants into the country, the Canadian government has also enacted policies that give individuals more freedom to live and work anywhere in Canada that they want to go. The country also has a policy in place called the Immigration Levels Plan to raise its immigrant quotas each year. At the end of 2021, Canada accepted over 400,000 new immigrants, which was an increase from 351,000 in 2020 as allocated in Canada’s 2020-2022 Immigration Levels Plan. By the end of 2022, Canada hopes to admit 431,645 immigrants.
Canada’s pro-immigration policies have also made it a top business location for companies around the world due to its diversity and progressive immigration policies, according to Envoy’s 2022 Immigration Trends Report. One of the country’s most popular immigration pathways is a points-based system called Express Entry, which facilitates the immigration of skilled migrant workers into the country.
The U.S. has had less predictability in its immigration policies due to politics. For instance, the Trump administration took over 400 executive actions to restrict immigration into the U.S., according to the Migration Policy Institute.
The Biden administration has taken a different approach since January 2021 by enacting more pro-immigration policies. He also outlined an ambitious plan for domestic immigration reform in the U.S. Citizenship Act of 2021.
Although the Biden Administration had hoped to reform the U.S. immigration system, its efforts have been stalled by inactivity in Congress. That, in turn, means the continuation of visa caps that don’t meet employer’s demand for talent.
A prime example of visa caps is the H-1B visa. Although the H-1B is one of the most sought-after visas for foreign nationals, the number of H-1B visas allocated annually through a lottery-based system does not meet the demand. Therefore, competition for H-1B visas is high, which is forcing employers to seek alternatives.
Free Movement Immigration Regime
The Free Movement immigration regime includes countries in the European Union (EU) and Schengen Zone. They are called the “free movement” states because of the freedom of movement permitted with the EU and the Schengen Zone.
Common characteristics of these regimes include:
- Free movement of goods, capital, information and services.
- Free movement of people.
- Market economies.
Countries that fall under the Free Movement immigration regime include Denmark, Norway, Sweden, Austria, Germany, Switzerland and the Netherlands. The Free Movement regime is further divided into Intra-Union and Extra-Union immigration regimes, which are comprised of those participating countries both within and outside of the European Union (EU), respectively. Intra-Union immigration regime countries have high immigration rates from within the EU, while Extra-Union immigration regimes have a more diverse immigration base comprising of migrants from outside the EU as well.
Within the Free Movement regime, there are several notable examples of free movement across the EU. One is that EU citizens can move throughout the EU area to live and work without having to obtain work authorization. Instead, local residency registration is usually all that is required. The Schengen C visa is another option. This visa allows applicants to travel through the EU on one visa instead of multiple visas.
Countries in the Extra-Union regime category include Belgium, France, Italy, Ireland, Spain and Portugal.
Diving a bit deeper into some individual Extra-Union countries, Belgium historically has received immigrants based on a common language. As such, Belgium’s foreign nationals arrived from what are now the EU member states. Ireland has historically received large numbers of immigrants from Scotland. Work visas are available in Ireland for non-EU nationals, but a job offer is required.
The Extra-Union regimes also include the Schengen Area, or the “Schengen Zone,” which includes 26 European countries. The Schengen countries have reciprocal travel and free movement arrangements. They also have a common visa policy.
The Intra-Union immigration regime countries include Austria, Denmark, Germany, Norway, Netherlands and Switzerland.
To help reduce their unemployment rates, many Intra-Union countries discourage foreign nationals from staying if they are not employed. One way they do so is by making it difficult for foreign nationals to obtain welfare benefits. Denmark, for instance, requires foreign nationals to have lived in the country for at least seven years and become permanent residents through either the Active Social Policy Act or the Integration Act before they can apply for immigration benefits.
Kafala Immigration Regime
The Kafala immigration regime (Gulf States) includes Bahrain, Oman, Kuwait, Saudi Arabia, Qatar and the United Arab Emirates (UAE). The Kafala regimes have unique immigration systems largely based on economic conditions. Employment-based options are available for both high-skilled and low-skilled workers.
Migration levels are high across the Gulf States, although Saudi Arabia and the UAE have the third and fifth largest immigration populations in the world, respectively, according to the International Labour Organization. While the Kafala regimes have large immigrant populations, they tend to support temporary work but don’t offer many opportunities for naturalization and permanent residency.
Key characteristics of the Gulf States include:
- Many temporary work options.
- Restrictive immigration policies.
- Few pathways to citizenship.
- Employment-based temporary work visas.
Collectively, the Gulf countries comprise the Gulf Cooperation Council, or the GCC. The GCC was formed in the 1970s, and it functions simultaneously as an economic and political union among the member states. The GCC has several key initiatives, including developing more trade opportunities for member countries, creating similar economic opportunities among them, facilitating the transfer of information and establishing more security and stability in the region.
The GCC allows citizens of its member states to benefit from simplified immigration procedures and requirements or visa-free travel options. Qatar also offers citizens of other GCC states to obtain a one-month business visitor visa.
Foreign national residents based in a GCC member state who wish to enter another GCC member country are typically required to obtain a visa on arrival, apply for a visa prior to travel or apply for an eVisa. Foreign nationals may also need to meet certain eligibility requirements.
Eventually, GCC citizens may even be able to travel to other places visa-free, including the UK and the EU.
The Quasi-Kafala regime includes China, Singapore and Russia. These countries share characteristics with the Kafala immigration regime countries in that they have more temporary work categories and fewer naturalization options. However, the biggest difference in Quasi-Kafala countries is that they have lower migration rates than Kafala regime countries.
The Quasi-Kafala regime countries generally have restrictive policies in place. Russia’s migration policies have been centralized for over 100 years, and they’ve historically been motivated by the needs of the Russian government.
China does not offer a pathway to citizenship for foreign nationals, regardless of the type of employment they seek in the country. Dual citizenship is also not an option.
Singapore permits immigration for work and visit purposes. Individuals who will be employed in Singapore or who will undergo training need an employment pass.
Constrained Immigration Regime
The Constrained immigration regime group includes Mexico, Brazil, Japan and South Korea. These countries have some of the lowest migration rates in the world, as the Crossroads authors point out. Additionally, most foreign nationals to these countries are admitted on temporary visas. Another common characteristic between Constrained immigration regime countries is that immigration is mostly evenly split between family- and employment-based.
Although the Constrained immigration regime countries have historically been less receptive to immigration in the past, Japan has deviated from tradition by recently welcoming more foreign nationals for employment-based purposes to account for an aging workforce, according to Crossroads.
The Japanese government has changed its policies toward skilled immigration by adopting a points-based system similar to Canada’s. Japan adopted this policy in 2012 to attract more high-skilled professionals to the country. Some individuals are granted preferential treatment, which includes several categories such as advanced academic research, advanced technical and specialized activities and advanced business management activities.
The Outlier nations do not fit into any specific regime category. Instead, they have their own policies regarding family-based and employment-based immigration that do not fit into the overarching policies of other immigration regime categories.
Even though they may have their own immigration policies, some outlier countries are part of larger groups and alliances within their regions. Colombia, for instance, is a MERCOSUR member and issues employment visas for individuals who are working for a public or private company.
The MERCOSUR Agreement was implemented in 2009 to manage migration within South America. The Agreement allows residents of MERCOSUR member states and associated states to work and live in another member state for up to two years. It also takes less time to get a work and residence permit in many MERCOSUR states.
Along with Colombia, MERCOSUR member states include Argentina, Chile, Ecuador, Guyana, Peru, Uruguay and Suriname. Argentina has one of the biggest economies in South America. Argentina allows individuals to become citizens after two years of permanent residency, and foreign nationals can seek work in the country after arriving on a tourist visa.
Chile welcomes foreign talent, and foreign workers generally seek work there in professional fields. Most foreign talent in Chile comes from Spain.
India, another outlier, had 4.9 million foreign nationals in 2020, and it was the 14th highest destination globally for immigration in the same year. However, immigration rates are falling in the country. In 2019, an Indian law went into effect requiring religion-based citizenship. Today, India has two employment-based visas, one of which is an employment-based visa and the other is a business visa. The employment-based visa is a high-skilled visa for foreign talent. The business visa is a temporary visa that grants entry to India for business-related activities.
South Africa is another Outlier, but it is an increasingly attractive destination for employers and talent. Historically, immigrants have formed a substantial part of the country’s population, as the Crossroads authors note. South Africa also has increasingly progressive policies for employment-based immigration. The country now offers a critical skills visa for high-skilled workers called the Critical Skills Work Visa (CSWV). The CSWV specifically targets foreign nationals who have certain qualifications and skills that the government deems beneficial to the economy. It has a maximum 10-year validity, with an initial five-year validity and the option to renew for five years after that. Applicants must show that their qualifications, skills and post-qualification experience meet the criteria in the Critical Skills List, which is a list created by the government with over 200 occupations.
The Philippines allows foreign workers to obtain a work visa, which allows them to secure an Alien Employment Permit (AEP) to become residents. Individuals from the U.S., Japan and Germany are assigned a Treaty Trader Visa. Thailand has many high-skilled positions but fewer opportunities for low-skilled workers. Smart Visas are available for long-term investment.
Immigration is as important today as it was 20, 30 and 100 years ago. Countries with high immigration rates tend to experience many economic benefits and social diversity.
As workforces continue to go global, employers and their global mobility teams may discover that some countries are easier to send employees to than others, while other countries may be more restrictive toward immigration.
Understanding the immigration nuances of countries is essential for compliantly managing a global workforce, and Envoy Global is here to help. Learn more about Envoy’s global immigration service offerings and how the Envoy Platform centralizes a company’s immigration program, regardless of where employees are located or where talent is needed.
Envoy is pleased to provide you this information, which was prepared in collaboration with Brendan Coggan, who is the SVP of Global Services at Envoy Global and Brittany Lowe, a Global Account Manager at Envoy Global.
Content in this publication is for informational purposes only and not intended as legal advice, nor should it be relied on as such. For additional information on the issues discussed, consult an attorney at one of the two U.S. Law Firms working with the Envoy Platform or another qualified professional. On non-U.S. immigration issues, consult an Envoy global immigration service provider or another qualified representative.