The European Union has recently announced that the long-awaited implementation of the Entry/Exit System (EES) is scheduled for October 2025.1 The specific launch date will be published well in advance of October 2025, according to the authorities.
WHY THIS MATTERS
The EES will introduce automated border checks of travelers to and from the Schengen area via e-gates.
The primary objective of the EES is to automatically identify non-EU travelers who violate the terms of their visas by staying longer in the Schengen area than allowed, including holders of short-term business visas and visa-exempt travelers who are allowed to travel to Schengen countries up to 90 days within any 180-day period.
Context
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, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and Switzerland.
Ireland and Cyprus are EU member states that are not party to the Schengen area and will not implement automated border checks. Travelers to Ireland and Cyprus will continue to get stamps in their passports.
What Will Happen under EES?
The EES is meant to replace manual border checks by implementing an IT system that will collate information such as name, type of travel document, biometric data (fingerprints and photographs), and the date and place of entry and exit.2
EES is a biometric system. This means that the first time a traveler from a non-EU country – including the U.K.3 – crosses a Schengen Zone external border, rather than the manual stamping of passports, he/she will be required to supply his/her fingerprints and have his/her photo taken at the border crossing. This will be kept on file for three years, so the person will not need to do this extra step each time. Refusal to comply will result in a denial to enter the Schengen area.4
Non-EU Nationals
As noted in the FAQs5, EES applies to individuals who are non-EU nationals traveling for a short stay to a European country using the EES and they 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.
Six-Month Rollout
On 5 March, the EU's Home Affairs minister said that there would be a “progressive start of operations,” whereby the Schengen Zone’s 29 countries would gradually introduce the system over a period of six months.6
KPMG INSIGHTS
The commencement of EES has been subject to numerous delays. But now that a date has been set, employers with travelers from outside the Schengen Zone traveling into the Schengen Zone can start planning for the upcoming changes.
Violations of visa conditions or conditions for an exemption from the visa to the EU are serious offenses that can impact possibilities for future travel to the EU.
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 make an effort 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.
FOOTNOTES:
1 See the EU's website "Entry/Exit System (EES)" (10 March 2025) for additional information.
See the European Commission News article (6 March 2025), Directorate-General for Migration and Home Affairs, "Revised timeline for the EES and ETIAS" at: https://home-affairs.ec.europa.eu/news/revised-timeline-ees-and-etias-2025-03-06_en.
For prior coverage of EES (and ETIAS), see GMS Flash Alert 2023-019 (24 January 2023), GMS Flash Alert 2024-229 (19 November 2024).
2 See the EU's website "Entry/Exit System (EES)" (10 March 2025) for additional information.
3 For guidance for U.K. travelers, the U.K. government has created a webpage "EU Entry/Exit System: Information about changing requirements for UK nationals travelling to countries in the Schengen area" at: https://www.gov.uk/guidance/eu-entryexit-system .
4 See the EU's website "Entry/Exit System (EES)" (10 March 2025) for additional information.
5 Ibid.
6 See the European Commission News article (6 March 2025), Directorate-General for Migration and Home Affairs, "Revised timeline for the EES and ETIAS" at: https://home-affairs.ec.europa.eu/news/revised-timeline-ees-and-etias-2025-03-06_en.
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* Please note the KPMG International member firm in the United States does not provide immigration or labor law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.
The information contained in this newsletter was submitted by the KPMG International member firm in the United States.
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