European Union officials published a revised timeline for the implementation of the Entry/Exit System (EES) and the European Travel Information and Authorization System (ETIAS).

Key Points:

  • On March 5, EU Home Affairs ministers endorsed a revised timeline for the EES to become operational in October 2025, with ETIAS expected to follow in the last quarter of 2026.
  • ETIAS travel authorization is an entry requirement that certain non-EU visa-free nationals must acquire to visit any of the 30 European countries implementing ETIAS for a short-term stay.

Additional Information: As BAL reported, the European Council announced a general approach had been reached on a regulation that would allow member states to gradually introduce the EES system over a period of six months. Once the regulation on the progressive start of operations of the EES is adopted and the remaining member states declare readiness, the commission will decide on the specific date of the progressive start of the EES, guided by the timeline endorsed by the Home Affairs ministers. BAL will continue to monitor developments and will provide more information as it becomes available.

For more information, check out BAL’s in-depth breakdown of these significant travel systems as well as our expert analysis reviewing the growing digital trend in immigration and the two separate but interconnected systems that will soon have a tremendous impact on non-EU citizens traveling to most EU countries.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Council announced a general approach has been reached on a regulation that would allow member states to gradually introduce the Entry/Exit System (EES) system over a period of six months.

Key Points:

  • Euronews reported that interior ministers reached an agreement in Brussels that does not set a fixed implementation date but aims for October as a potential start date, according to Tomasz Siemoniak, Poland’s minister for internal affairs and administration.
  • The Entry/Exit System is currently not in operation. According to its official site, the launch date is listed as “later in 2025.”

Additional Information: The announcement from the council states that an established position for the progressive launch of a new digital border management system had been reached. Poland is the country currently holding the EU Council’s rotating presidency, and negotiations with the European Parliament for a final agreement on the amended law are still in process. Once adopted, the EES Regulation will enter into force, allowing member states and eu-LISA to prepare for the progressive start of operations.

The EES has been delayed several times. Officials stated the European Union will announce the start date of the EES several months prior to its launch. BAL will continue to monitor developments and will provide more information as it becomes available.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2025 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Council agreed to lift land border controls in Bulgaria and Romania, paving the way for the two countries to fully join Europe’s Schengen area.

Key Points:

  • In March, checks were abolished on persons at EU internal air and maritime borders between Bulgaria and Romania and the other countries in the Schengen area.
  • Effective Jan. 1, 2025, checks on persons at internal land borders will be lifted and Bulgaria and Romania will fully join the Schengen area.

Background: The Schengen area will now cover 29 countries (25 of the 27 member states, as well as Iceland, Liechtenstein, Norway and Switzerland) and grow to 4.5 million square kilometers with a population of 450 million people. The Schengen area is the largest free travel area in the world.

BAL Analysis: The Schengen area is an important component of the EU’s legal framework, and an enlarged Schengen area should spur economic growth and increase travel opportunities. The full integration into Europe’s ID-check-free travel zone should also be significantly positive for Bulgarian and Romanian nationals, who will now have additional access to the world’s largest free travel zone.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Commission proposed a progressive start of operations for the new digital border Entry/Exit System (EES).

Key Points:

  • As BAL reported, the European Commission announced in October the implementation date for the EES would be further delayed.
  • The proposal for progressive start would give EU member states six months to deploy the EES.
  • The proposed plan still needs to be approved, and then a date for the start of the system will be set by the Commission.

Additional Information: The proposal allows EU member states to progressively benefit from advantages and capabilities of the system, while border authorities and the transportation industry have more time to adjust to the new procedures.

BAL Analysis: The proposal will now be submitted to the European Parliament and the Council. Once adopted, the EES Regulation will enter into force, allowing member states and eu-LISA to prepare for the progressive start of operations.

The EES has been delayed several times. It is intended to more easily identify travelers who have stayed in the EU longer than allowed, who do not have the right to enter the EU or who are involved in criminal or terrorist activity. The EU hopes to modernize border control and replace passport stamping with a digital record linking passports to biometric data.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Commission announced the implementation date for the Entry/Exit System (EES) will be further delayed.

Key Points:

  • As BAL previously reported, the official commencement date for the EES was scheduled for Nov. 10. The new border control system is part of a “Smart Borders” initiative originally scheduled to take effect during the first half of 2022.
  • EU Home Affairs Commissioner Ylva Johansson announced that the Nov. 10 launch date is no longer viable, as Germany, France and the Netherlands have expressed unreadiness within their border computer systems.
  • Johansson announced during a meeting of the EU interior ministers on Oct. 10 that “it’s clear that we’re not going to be ready for the 10 November,” adding “we will be going for a phased approach, step by step.”

What is it?

The EES is an automated IT system for registering non-EU nationals (those who do not hold the nationality of any European Union country or the nationality of Iceland, Liechtenstein, Norway or Switzerland) traveling for a short stay each time they cross the external borders of any of the following European countries using the system:

  

The EES applies to non-EU nationals who are traveling for a short stay to any of the European countries above who either possess a short-stay visa or do not need a visa to stay for a maximum of 90 days in any 180-day period.

What does it do?

The system will collect travel document data and other personal data and register it electronically in the system, facilitating border crossing. The EES collects, records and stores data listed in travel documents, dates and places of each entry and exit, facial image and fingerprints (“biometric data”) and any history of refused entry. The biometric identifiers that the EES stores are dependent on whether an individual needs a short-stay visa.

The EES is designed to replace passport stamping and requires travelers to have biometric data recorded upon entry. Registration is completed at the external border of any of the 29 European countries using the system, including the 27 Schengen countries and Bulgaria and Romania, which are both in the process of officially joining the Schengen area.

To whom does the EES apply/not apply?

Exemptions to registration in the EES do apply, and more information can be found here. The EES will not affect people traveling within the Schengen area; it only applies to third-country nationals as they enter the area.

When the new EES is implemented, non-EU nationals, including United Kingdom citizens, will need to register biometric data rather than entering via a stamped passport. All foreign travelers entering the Schengen area for short stays, whether they are eligible for visa-free travel or not, will be required to provide their biometric data. The EES will apply at airports, ports, road borders, train stations and all external EU borders. The EES does not apply to nationals of the European countries using the EES, as well as Cyprus and Ireland.

Are biometric passports now required?

Biometric and non-biometric passports are accepted for traveling in the European countries using the EES if valid and if all other entry conditions are fulfilled. Biometric passports will only be required for individuals who wish to use automated ways to cross the borders (“self-service systems”). European countries using the EES have the discretion to further automate their processes in the future for this purpose.

Additional Information: The implementation of the EES will be in tandem with the requirement to register for the European Travel Information and Authorization System (ETIAS) visa waiver scheme, which the EU says will be introduced in the first half of 2025. ETIAS will concern visa-exempt non-EU nationals and will require travelers from the 63 countries currently approved to travel into the EU visa-free to register for a visa waiver before arriving in the Schengen area. ETIAS will contain information dealing with travel authorizations for non-EU nationals traveling visa-free to the 30 European countries implementing ETIAS.

BAL Analysis: Facial image and fingerprint collection at EU borders will not be required beginning Nov. 10. The EES has been delayed several times but is intended to more easily identify travelers who have stayed in the EU longer than allowed, who do not have the right to enter the EU or who are involved in criminal or terrorist activity. The EU hopes to modernize border control and replace passport stamping with a digital record linking passports to biometric data.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

EU Commissioner Ylva Johansson announced the official commencement date for the Entry/Exit System (EES) is Nov. 10, 2024.

Key Points:

  • As BAL previously reported, EU authorities have repeatedly delayed the new border control EES, part of a “Smart Borders” initiative, which was originally expected to take effect during the first half of 2022.
  • EES is an automated system for registering non-EU nationals traveling for a short stay — up to 90 days in a 180-day period — that will record each time they cross external Schengen area borders. It will replace passport stamping and requires travelers to have biometric data (facial images and fingerprints) recorded upon entry.
  • Registration is completed at the external border of any of the 29 European countries using the system, including the 27 Schengen countries as well as Bulgaria and Romania, which are both in the process of officially joining the Schengen area.

Background: EES differs from the European Travel Information and Authorization System (ETIAS), which will require travelers from the 63 countries currently approved to travel into the EU visa-free to register for a visa waiver before arriving in the Schengen area. The registration will cost €7 (free for travelers under 18 or over 70) and will last three years. ETIAS is expected to launch in 2025.

BAL Analysis: EES is intended to more easily identify travelers who have stayed in the EU longer than allowed, who do not have the right to enter the EU or who are involved in criminal or terrorist activity. It will not affect people traveling within the Schengen area; it only applies to third-country nationals as they enter the area.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Council announced an extension of the temporary protection for Ukrainian refugees until March 4, 2026.

Key Points:

  • The temporary protection mechanism was originally enacted on March 4, 2022, and was due to expire on March 4, 2025.
  • The extension does not change the qualification categories and more information can be found here.

Additional Information: Temporary protection is an EU emergency mechanism which was originally adopted in 2001 and is designed to provide immediate protection to a large group of displaced persons who arrive in the EU and are not in a position to return to their country of origin. The actual level of assistance varies within each individual member state, but the EU temporary protection law sets a minimum standard of protection that aims to alleviate pressure on national asylum systems and provide refugees the same rights across the EU.

BAL Analysis: Member states will adopt implementation acts according to their national procedures to formalize the directive extension. The European Council has extended the temporary protection to provide continued support and stability for Ukrainians who have sought refuge in Europe amid the ongoing conflict.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Commission has announced a 12% global increase to the short-stay Schengen visa fees, effective June 11.

Key Points:

  • The European Commission stated the new Schengen visa fee will be 90 euros (about US$98) for adults and 45 euros for children aged 6 to below 12 years of age.
  • The current visa application fees are currently set at 80 euros for adults and 40 euros for children aged 6 to below 12 years of age.

Additional Information: Under the EU visa code, countries in the Schengen area are authorized to modify visa fees every three years. In 2020, the price of an adult Schengen visa was increased from 60 euros to 80 euros.

BAL Analysis: The European Commission has stated that the increase is designed to align with the rising costs associated with processing visas, which include background checks, data processing and maintaining secure entry systems.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Commission adopted updated rules on Schengen visas for nationals of Bahrain, India, Oman and Saudi Arabia.

Key Points:

  • The standard rules of the EU visa code have been updated for Indian nationals who reside in India and who have already obtained and lawfully used two Schengen visas within the preceding three years. These individuals are now eligible for a multiple-entry, two-year Schengen visa.
  • Additionally, Indian nationals who have held that multiple-entry, two-year visa can now apply for a multiple-entry, five-year Schengen visa with a valid passport.
  • It was also announced that nationals from Bahrain, Oman and Saudi Arabia can now apply for a multiple-entry, five-year Schengen visa as well.

Background: The Schengen area consists of 29 European countries (25 EU states), and Schengen visas allow for free travel within the area for short stays of a maximum of 90 days within any 180-day period.

BAL Analysis: The updated visa code should provide easier access for nationals with an established travel history and the ability to obtain multi-year validity during which holders enjoy travel rights equivalent to visa-free nationals.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The European Council adopted a revision to the 2011 single-permit directive, paving the way for an improved single work and stay permit for non-EU nationals.

Key Points:

• The directive currently in place was designed to attract additional skills and talent to the EU to address shortcomings within the legal migration system. It provides an application process for EU countries to issue this single permit and establishes common rights for workers from third countries.

• The new revised law will shorten the application procedure for a permit to reside for the purpose of work in a member state’s territory and aims to strengthen the rights of third-country workers by allowing a change of employer and a limited period of unemployment.

• Member states have two years to transfer the directive into national law and will maintain the ability to decide which and how many third-country workers to admit to their labor market.

• The directive will enter into force on the 20th day following that of its publication in the Official Journal of the European Union.

Background: The Single-Permit Directive is directed at non-EU nationals working in the EU and aims to create an environment where these individuals are treated equally regarding their working conditions, social security and tax benefits, and recognizing their unique qualifications. The Commission originally proposed an update to the current single-permit directive in 2022. The new agreement is part of the “skills and talent” package, which addresses shortcomings in legal migration policy and aims to attract greater foreign skilled talent.

BAL Analysis: The EU faces persistent labor shortages in a variety of sectors at all skill levels, and the updated regulation should boost international recruitment of talent. In addition, the updated rule provides third-country workers with more rights and equal treatment to EU workers to reduce labor exploitation.

This alert has been provided by the BAL Global Practice Group.

Copyright © 2024 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.