26 July 2022: ERA participated on 14 July at a high-level meeting organised by DG HOME following the informal Justice & Home Affairs Council where ministers agreed on a new timeline for the implementation of EES.

The meeting was the opportunity for DG HOME to stress that EES implementation will enable the EU to better manage its external borders, and is therefore high on the Commission’s priority list.

DG MOVE supported the industry call for a smooth implementation – as demonstrated with the challenges this summer even without reaching 2019 numbers in terms of passengers, hence proposed a postponement of the implementation and a progressive entry into force to manage passenger flows and avoid disruptions.

New timeline:

• EES: mid-May 2023
• New Schengen system: November 2023
• ETIAS: November 2023
• Interoperability of all systems by June 2024 (relevant for enforcement authorities)

DG HOME proposal for a progressive approach

When EES enters into force, there will need to be an individual file for each traveller, recording information from their travel document, as well as biometric information, i.e. fingerprints and facial image.

100% of passengers will need to be registered at the beginning, but subsequent border crossings would become easier.

DG HOME is looking at different options to avoid long queues at EU border at the beginning of implementation of the EES system:

• Allow for incomplete files to be created, solely based on the travel documents logs (without biometrics) during peak times. This would only be allowed for roughly 9 months, until February 2024.
• Member States could be required to continue stamping passports for three months, in order to offer a fall-back solution to carriers in case the IT system is not fully set up. In this case, the information on the travel document would trump that of the EES system.
• Carriers would still be required to query the euLISA system during the transition period.
• Regarding off-airport registration, DG HOME is considering the development of a mobile app, which would capture travel document and facial image information before border crossing – fingerprints would still need to be collected manually at arrival, especially for the first time the person is travelling to the EU

• These elements will be further detailed in the Commission Decision to be adopted in spring 2023.

DG HOME committed to work with all stakeholders, Member States but also industry in order to draft this decision.

• A follow-up high-level meeting will be convened again before 2023 if necessary

euLISA update

In June, the euLISA Management Board acknowledged that there is mounting/high political pressure to implement EES.

Some of the challenges in the timeline are due to the euLISA subcontractors. However, aiming at mid-May is now feasible, and euLISA will have everything technically ready by March 2023 in order to be able to answer challenges.

All technical requirements are already available on the euLISA website so that carriers can prepare themselves. Only 900 carriers have registered so far, roughly 50 per cent EU, 50 per cent non-EU.

euLISA will share with the associations the list of registered carriers so that we can liaise with those who are not registered in priority.

euLISA will also establish an “escalation point” after which a lack of response or incomplete response from the subcontractors could be addressed to higher level within euLISA.

FRONTEX update

A first FAQ document is available on the euLISA website, and a second version is being finalised. This document will be updated regularly, in order to build on the common experience of the carriers.

The central unit and the assistance center are being set-up, with currently 12 staff working on the project website. FRONTEX will be ready to support the travellers when the system enters into force, in particular when ETIAS is implemented.

50 people are already working on this, with new colleagues joining the team in September and October.

ERA and EBAA emphasised the fact that many business aviation operators and regional carriers that are not members of their associations might not have been properly informed about the upcoming IT changes.

• DG MOVE and DG HOME committed to reach out to national CAAs in order to continue spread the word about EES.