Entry/Exit System (EES): What companies and travelers need to know

The Schengen area has introduced a new border control system called the Entry/Exit System (EES). The EES electronically registers the entry and exit of third-country nationals traveling to the Schengen area, including Norway, for short stays of up to 90 days. It replaces manual passport stamping, records biometric data such as fingerprints and facial images, and applies to both visa-exempt travelers and those who require a visa to enter.

For businesses that send employees or contractors across Schengen borders, the EES means longer processing times, new biometric requirements, and updated recordkeeping at the border. Norway participates in the EES as part of the Schengen-wide system, so the changes apply here as they do across the rest of the area. Below, we explain who is covered by the EES, how the registration process works, what rights travelers have over their data, and what businesses should do to prepare.

What countries are using the EES system?

The following 29 countries will use the entry/exit system:

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

Note: Cyprus and Ireland will continue to stamp passports manually.

Who is registered in the EES?

EES applies to third-country nationals (non-EU/EEA nationals) travelling to the Schengen area for short stays of up to 90 days. This applies to both visa-exempt travelers and those who require a visa to enter.

Who is exempt from EES registration?

The following groups are exempt from EES registration:

• EU/EEA nationals benefiting from free movement rights, including Norwegian citizens

• Third-country nationals holding a residence permit or residence card issued by a Schengen country

• Certain other categories of travelers may also be exempt under applicable EES rules
  
  

How does the EES work at the border?

First-time registration

When a third-country national enters the Schengen area for the first time, their identity, travel document details, and biometric information (facial image and fingerprints) are registered. Entry may be refused if a third-country national subject to EES registration refuses to provide the required biometric data.

Later entries and exits

On later entries and exits, biometric data is used to verify identity. EES records the time and place of entry and exit, as well as any refusals of entry. Both entries and exits are registered in EES. In practice, border control procedures remain broadly similar, but third-country nationals may be required to provide fingerprints and a facial image. Manual passport stamping is replaced by electronic registration.

The EU’s related travel authorization scheme, the European Travel Information and Authorisation System (ETIAS), is expected to follow EES. While EES records travelers’ entries and exits at the border, ETIAS will require visa-exempt third-country nationals to obtain travel authorization online before travelling to the Schengen area.

How long does EES registration take?

Businesses should be prepared for potentially longer processing times at border control, particularly during first-time registrations, as fingerprints must be collected and facial images captured in addition to passport scanning. For larger crew changes, additional time must therefore be allocated.

What rights do travelers have over their personal data stored in the EES?

Everyone has the right to request access to the personal data registered about them during border control. They can also request that inaccurate or incomplete information is corrected, ask for their data to be deleted in certain circumstances, or request restrictions on how their data is processed in EES. If they believe their data has been mishandled, they have the right to file a complaint with the relevant supervisory authorities.

What should companies do to prepare for the EES?

Based on feedback received during the implementation process and official guidance, businesses should:

• Plan for extended processing times, as third-country nationals, especially those undergoing first-time registration, may experience longer border control procedures than before

• Maintain current notification procedures by continuing to submit notification forms for mobile installations as required under existing procedures

• Inform employees and contractors so that third-country nationals understand that they must provide biometric data and that entry may be refused if they decline to provide the required information

Summary

EES applies across the Schengen area, including Norway, and applies to third-country nationals travelling for short stays of up to 90 days. EU/EEA nationals benefiting from free movement rights and certain residence permit holders are exempt. Registration requires biometric data at first entry, with later crossings verified against the registered data and both entries and exits recorded. Manual passport stamping has been replaced by electronic registration.

Companies should expect potentially longer border processing times, particularly for first-time registrations, while affected individuals retain rights to access, correct, and in certain circumstances delete their registered data.

The related ETIAS travel authorization, which will require visa-exempt travelers to obtain online approval before entering the Schengen area, is expected to follow. Companies should continue current notification procedures, plan for extended processing times, and ensure employees understand the biometric requirements.

For guidance on immigration matters affecting your business or to discuss your specific needs, please contact us for an initial consultation.