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On 19 May 2025, the European Council and the European Parliament agreed to implement digital border management with the Entry/Exit system (EES) progressively over a period of six months, rather than implementing the system all at once across the Schengen-zone countries.1 Ìý(For prior coverage, see GMS Flash Alert 2025-072, April 8, 2025.)

One of the considerations behind a proposal for a progressive launch of the EES system is that full commencement of the system could pose a risk for the IT infrastructure supporting the system.

The agreement about a progressive start to the EES is provisional and must be confirmed by the European Council and the European Parliament before it can be formally adopted. ÌýThe start date for progressive deployment of the EES system will be set by the European Commission in a separate decision. Ìý

WHY THIS MATTERS

The EES system will introduce automated border checks for travelers entering and exiting the Schengen area via e-gates. ÌýThis IT system is designed to record entries and exits, as well as capture data from passports, fingerprints, and facial images of non-EU nationals traveling for short stays in the European Union.

The primary objective of the EES is to provide real-time access to non-EU nationals� personal data, travel history, and whether their stay complies with the authorized duration for stay in the Schengen area.

The EES is expected to reduce the likelihood of identity fraud and the overstay of non-EU nationals, including holders of short-term business visas and visa-exempt travelers who are allowed to travel to Schengen-zone countries up to 90 days within any 180-day period.Ìý

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Countries that are taking part in the EES are: Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and Switzerland.

Ireland and Cyprus are EU member states that are not party to Schengen and will not implement automated border checks. ÌýTravelers to Ireland and Cyprus will continue to get stamps in their passports.Ìý

Gradual Implementation

The gradual implementation of the EES system allows the countries that prefer to introduce the system progressively over a six-month period to do so, while also enabling others to operate the system fully from the outset.

The progressive start of the deployment of the EES system means that a country implementing the system will aim to operate it at a minimum of 10 percent of border crossings during the first month.

For the first two months, countries may run the EES without biometric functionalities. ÌýAfter three months, countries are expected to operate the EES with biometric functionalities at a minimum of 35 percent of their border crossing points.

By the end of the six-month period following the launch of the EES, countries should achieve full registration of all individuals entering and exiting at all border crossings.

During the transition period, countries will continue to manually stamp travel documents.

The date for the progressive launch of the EES has not yet been determined; the European Commission will set the date in a separate decision.Ìý

Suspension

During the progressive commencement of operations of the EES, countries may choose to fully or partially suspend the operation of the EES at certain border crossings in exceptional circumstances, such as high-traffic intensity resulting in excessively long waiting times.

Upon completion of the gradual implementation process, countries, again under exceptional circumstances, may suspend operation of the EES at a specific border point for up to six hours.Ìý

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The implementation of the EES will have significant implications for various stakeholders. Business travelers who do not hold EU citizenship will experience changes in border-crossing procedures, and businesses involved in international travel and trade may need to adapt to new processes associated with the EES. Additionally, border authorities will benefit from enhanced capabilities to detect over-stayers, improving overall border security and management.

Serious offenses occur when there are violations of visa conditions or conditions for an exemption from the visa to the EU, which can impact possibilities for future travel to the European Union.

Companies may not be aware of all the traveling a relevant employee undertakes to the Schengen area, for example, when the relevant employee is on holiday in the Schengen area, and therefore may not know when a business trip to the Schengen area may violate visa conditions and result in an over-stay.

Companies should therefore consider taking steps to inform relevant employees about the upcoming changes and the importance of tracking travel and stay in the Schengen area to help ensure the legality of their stay in the Schengen area. ÌýÌýÌý

FOOTNOTE:

1 ÌýEuropean Council: (19 May 2025).

Contacts

Daida Hadzic
Daida Hadzic

Director, Washington National Tax � Global Mobility Services

ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø in the U.S.

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