The date that decides: filed, approved, or arrived?

By Immimaps5 min read
The date that decides: filed, approved, or arrived?

Recent measures, different cut-offs. Which stage of an application kept the old rules, and which did not.

The question

When a government closes or narrows a route, the people with the most at stake are the ones already part-way through it. Every measure answers one question for them, usually in a single clause: what did you need to have done, by what date, to stay under the old rules?

The answers since late 2023 are not the same twice.

The filing date

  • Spain ended its investor residence route with Organic Law 1/2025, published on 3 January 2025 and in force on 3 April 2025. Investors and their family members who filed before that date may receive the visa or permit under the rules in force on the filing date. Renewals are decided under the rules in force when the first permit was granted.
  • The Netherlands ended its admission scheme for foreign investors on 17 April 2024. Applications filed before that date are still assessed under the old policy, and existing permits can still be extended. The policy text setting this out was published on 26 April 2024, after the date it used as its cut-off.
  • The United Kingdom closed the Afghan Relocations and Assistance Policy to new applicants at 15:00 BST on 1 July 2025, with no notice period. Applications received before that hour continue to be considered. (General information only.)
  • Canada's temporary visas for extended family in Gaza and its family pathway for people affected by the conflict in Sudan were capped. Complete applications submitted before the cap was reached are processed; applications over the cap are returned.

The approval date

  • Malta. On 29 April 2025 the EU Court of Justice ruled that Malta's citizenship-by-investment scheme broke EU law. Malta then rewrote its rules. Its regulations, published on 29 July 2025, say that applications under the direct-investment route "which had not been approved for naturalisation by the Minister … prior to 29 April 2025, shall cease to have effect". The cut-off was the date of the court ruling, earlier than the rule itself, and the condition was ministerial approval, not filing. People already naturalised keep their citizenship.

A document already issued

  • Italy. Decree-Law 145/2024, in force on 11 October 2024, suspended work permits already issued to nationals of named countries (Bangladesh, Pakistan and Sri Lanka, with Morocco added under a later ministerial list). If the visa had already been issued on 11 October 2024, nothing changed. If the work permit was issued but the visa was not, the permit stopped having effect until officials confirmed new checks, and pending visa applications at consulates were suspended. The text sets no deadline for those checks.
  • The United States. The entry bans of June 2025 (Proclamation 10949) and January 2026 (Proclamation 10998) reached nationals of listed countries who were outside the US and held no valid visa on the start date. Both say no visa issued before the start date would be revoked under them. Green-card holders are exempt.
  • Canada. Since 1 March 2026, Iranians in Canada may extend a work permit to 31 March 2027, at standard fees, only if that permit was issued on or before 28 February 2025. Visitors and students use the regular processes.

Where you were on the day

  • Australia. From 26 March 2026, for six months, Iranian-passport holders of visitor visas who were outside Australia could not travel there, even with a valid visa. Anyone already in Australia was not affected. The stated reason was the risk that some visitors would not leave when their visas expired, not security. (General information only.)

A status held on a date

  • The EU's temporary protection for people from Ukraine was extended to 4 March 2028, with a new condition: protection is granted only to people who meet their military obligations in Ukraine. The condition does not apply to people who held temporary protection in a member state on or before 4 August 2026 and keep it there without a break.

The 2020 precedent

COVID-19 gave the widest test. In 2020, the line in most places was a document already in hand. In Canada, an approved permanent-residence applicant whose approval document was issued on or before 18 March 2020 could travel; one issued after that date did not exempt its holder under the general rule, until 21 June 2021 opened travel to anyone with a valid one. The difference was a date printed on a document, not anything the holder did. (Other travel exemptions existed; not everyone after the line was stuck.)

Who it reaches

Anyone choosing when to file, when to pay, or when to travel.

What it tells you

This is analysis of a record, not a forecast. There is no single safe stage. Filing protected people in Spain and the Netherlands. In Italy, an issued work permit did not, and only an issued visa did. Malta used approval, and reached back to a court date. Australia used where a person physically stood on a given day. Each cut-off was chosen when its measure was written, and the stage that was enough in one measure was not enough in the next.

What would show this wrong

Governments converging on one cut-off rule, so that the same stage protects people whatever the measure.

Sources

General information, not legal advice. Rules in the UK and Australia are described for general information only.

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