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      On 31 July 2025, the European Commission (EC) published a decision1 that the phased implementation of the European Union’s Entry/Exit System (EES) will be implemented over a six-month period, expected to commence on 12 October 2025.

      The EES is designed to digitise the external border crossing (e-gates) of 29 European countries2 by systematically recording the entry and exit data of non-EU nationals travelling for a short stay, such as a U.S. national visiting the EU for business and/or leisure.  (For prior coverage see the following issues of GMS Flash Alert: 2025-101 (22 May 2025), 2025-072 (8 April 2025), 2024-229 (19 November 2024), and 2024-173 (27 August 2024).) 

      WHY THIS MATTERS

      The introduction of the EES represents a significant modernisation of the border management infrastructure in Europe.  It is relevant for frequent business travellers, and global mobility professionals, as it will change the way non-EU nationals are processed at Europe’s external borders.  The main objective of the EES is to automatically identify the so-called “over-stayers,” including non-EU nationals travelling to Europe who are visa exempt for up to 90 days within a 180-day period.  The EES will automatically determine if such travellers are violating the conditions of their visa exemption.  The same applies to holders of short-term business visas.

      Potential Impacts

      • For Employers: The EES will require employers to carefully plan and track all travels by non-EU nationals to the EU precisely to avoid consequences of immigration rules violations, including denial to access a country.
      • For Travelers: Non-EU nationals will experience changes in border crossing procedures, including biometric data collection and automated checks.  The automation of border-crossings will require non-EU travellers to be transparent about all travel to the EU to help ensure compliance with relevant immigration conditions.
      • For Compliance: Companies with non-EU nationals travelling to the EU must make sure that their internal policies and record-keeping align with the new system to avoid inadvertent breaches, especially in relation to short-term assignments and business travel.

      Key Highlights

      Countries in the Scope of EES

      The countries that will be within the scope of 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.

      System Features and Objectives

      • Enhanced Border Management: The EES will automate the registration of entry and exit data for non-EU nationals crossing the EU’s external borders.
      •  Efficiency and Security: The system aims to improve the efficiency of border controls and strengthen the security and integrity of the Schengen Area.3
      • Unchanged Deployment Conditions: All previously announced features and phased deployment conditions remain in effect (for prior coverage see KPMG GMS Flash Alert 2025-101 (22 May 2025)).

      Employer and Stakeholder Guidance

      Employers are encouraged to monitor EES-related developments and review internal mobility and travel policies.

      KPMG INSIGHTS

      Taking Action

      Considering the upcoming changes, the following may provide employers with some guidance:

      • Employers may wish to consider reviewing and updating travel policies, informing relevant employees about the upcoming changes, and establishing processes for monitoring entry and exit records.
      • Mobility and HR teams may wish to consider coordinating with immigration advisers to assess the impact on short-term assignments, business travel, and posted worker compliance.
      • Compliance teams may wish to consider monitoring EU announcements for the confirmed start date and any additional guidance and consider steps to update internal compliance protocols accordingly.

      Considerations

      The EES is expected to increase transparency, reduce illegal overstays, and streamline border checks, but it will also introduce new compliance risks for employers and travellers.  The system’s reliance on biometric and digital records will require organisations to foster data accuracy and privacy compliance. 

      What’s Next?

      The EES is part of a broader digital transformation of EU border management, with further initiatives such as the European Travel Information and Authorisation System (ETIAS) expected to start operations in the last quarter of 2026.4  

      Organisations should anticipate ongoing changes in EU mobility and immigration requirements and remain agile in their compliance strategies.

      Contacts

      Daida Hadzic
      Daida Hadzic

      Director, Washington National Tax – Global Mobility Services

      KPMG in the U.S.

      heleen-snieders
      Heleen Snieders

      Partner, Immigration

      KPMG in the Netherlands

      More Information

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      Disclaimer

      * Please note the KPMG International member firm in the United States does not provide immigration or labour 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 firms in the United States and The Netherlands.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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