EUROPEAN COMMISSION 
Brussels, 12.12.2011 
SEC(2011) 1536 final 
  
COMMISSION STAFF WORKING PAPER 
Impact Assessment accompanying the Prop osal for a Regulation  of the European 
Parliament and of the Council establishing the European Border Surveillance System 
(EUROSUR) 
{COM(2011) 873 final} 
{SEC(2011) 1537 final} 
{SEC(2011) 1538 final}  
 
EN 1   EN Accompanying document to the 
PROPOSAL FOR A REGULATION OF THE EUROPEAN PARL IAMENT AND OF 
THE COUNCIL ON 
Establishing the European Bord er Surveillance System (EUROSUR) 
  
 
IMPACT ASSESSMENT  
 
               
This report commits only the Commission's servic es involved in its preparation and does not 
prejudge the final form of any deci sion to be taken by the Commission. 
 
 
 
 
EN 2   ENTable of contents 
1. Introduction................................................................................................................ ...3 
2. Procedural issues and consulta tion of interested parties...............................................5 
3. Problem definition ........................................................................................................7 3.1. Border surveillance....................................................................................................... 7 
3.2. General problems faced in border surveillance ............................................................8 3.3. Specific problems faced in border surveillance............................................................9 3.4. Does the EU have the right to act? .............................................................................11 3.5. Subsidiarity.............................................................................................................. ...11 
3.6. What is the baseline situa tion for implementing EUROSUR?...................................12 
4. Objectives .................................................................................................................. .18 
4.1. General objectives ......................................................................................................18  
4.2. Specific and operational objectives ............................................................................18 5. Policy options .............................................................................................................1 9 
5.1. Overview of policy options ........................................................................................19 5.2. Policy options for setting up the national coordination centres..................................22 5.3. Policy options for setting up the EUROSUR network ...............................................24 
5.4. Policy options for cooperating w ith neighbouring third countries .............................26 
5.5. Policy options for the common application of surveillance tools at EU level............27 
6. Assessment of the impacts of policy sub-options.......................................................28 6.1. Assessment criteria .....................................................................................................28  
6.2. Sub-options 1.1 to 1.3 for nati onal coordination centres............................................29 
6.3. Sub-options 2.1 to 2.3 for the EUROSUR network....................................................31 6.4. Sub-options 3.1 to 3.3 for coope ration with third countries .......................................33 
6.5. Sub-options 4.1 to 4.3 for the common application of surveillance tools ..................35 7. Comparison of options and identifi cation of preferred policy option ........................38 
8. Monitoring and evaluation..........................................................................................40 
 
 
EN 3   EN Lead DG:  Home Affairs 
Associated DG: Maritime Affairs 
1. INTRODUCTION  
This impact assessment report is prepared by DG HOME to accompany the legislative 
proposal on the establishment of a European  Border Surveillance System (EUROSUR). 
EUROSUR can be described as a set of measur es enhancing the cooper ation and information 
exchange of border control authorities at na tional and European level as well as when 
cooperating with neighbouring thir d countries, with the result th at the situational awareness 
and reaction capability of these authorities woul d be considerably increased when combating 
irregular migration and cross-bo rder crime. Hence EUROSUR should be seen in the context 
of the progressive establishment of a European  model of integrated border management.  
The works carried out between 2008 and 2011 fo r the development, testing and gradual 
establishment of EUROSUR are based on a roadmap presented in a Commission Communication in 2008.
1 This roadmap has been endorsed by the Justice and Home Affairs 
Council in its conclusions of June 2008 a nd February 2010 and by the Stockholm Programme 
and the Action Plan implementing the Stockholm Programme. In its conclusions of June 2011 
the European Council stated that EUROSUR "will be further developed as a matter of priority 
in order to become operational by 2013 and allo w Member States' authorities carrying out 
border surveillance activ ities to share operational information and improve cooperation."  
In its 2008 EUROSUR roadmap the Commission proposed to establish EUROSUR in three 
phases, consisting of eight steps: 
Phases  Steps  
Step 1:  Setting up of national coordination centres  (NCCs)  for border 
surveillance in the Member States lo cated at the eastern and southern 
Schengen external borders.  
Step 2 : Setting up of the EUROSUR network .  Phase I  
Interlinking and 
streamlining existing 
surveillance systems 
at national level  Step 3:  Cooperation with neighbouring third countries  to enhance their 
capacity to manage their own borders, fight cross-border crime and fulfil 
their search and rescue responsibilities.  
Step 4:  Exploitation of R&D (FP7)  to improve and test the performance of 
surveillance tools, e.g. to detect small boats.  
Step 5:  Setting up of a  service for the  common application of surveillance 
tools  (satellites, ship reporting systems, etc.).  Phase II  
Development of 
common tools for 
border surveillance at 
EU level  Step 6:  Setting up of the Common Pre-frontier Intelligence Picture  
Step 7:  Creation of a common information sharing environment  for 
internal security purposes covering the southern maritime borders.  Phase III  
Creation of a 
common information 
sharing environment 
for the EU maritime 
domain  Step 8: Creation of a common information sharing environment for the 
EU maritime domain, covering all mar itime activities (border control, law 
enforcement, customs, maritime safety, marine environment, fisheries 
control, defence).  
Steps and phases identified in the 2008 EUROSUR roadmap 
                                                 
1  COM(2008) 68 final of 13.2.2008 (‘EUROSUR roadmap’). This Communication was elaborated on the 
basis of the MEDSEA and BORTEC studies carried out by Frontex. For further details see Annex 1.1. 
 
EN 4   EN 
 
Table illustrating the 7 St eps of the EUROSUR roadmap
 
EN 5   EN The eight separate, but interlinked steps are being developed and implemented in parallel, 
thereby reducing the risk in case one step is  delayed or even fails. The development of 
EUROSUR also takes into account that Member  States are responsible for their national 
security and for controlling their external bor ders. Therefore the aim is not to set up a 
centralised border surveillance sy stem at EU level which would replace national systems, but 
to make best use of existing structures and modern technology. 
The 2008 roadmap was accompanied by an impact assessment2 identifying several 
shortcomings3 and three objectives4, which remain valid for the current impact assessment, 
and presenting four policy options:  
Policy Option 1  No changes are made to the current situation.  
Policy Option 2  Phase 1 (Steps 1 to 3)  
Policy Option 3  Phases 1 and 2 (Steps 1 to 6)  
Policy Option 4  Phases 1, 2 and 3 (Steps 1 to 7)  
Policy options of the 2008 EUROSUR impact assessment  
Under the 2008 impact assessment,  the preferred policy actions we re Steps 1 to 7 as proposed 
under policy option 4. In its conclusions of June 2008 and February 2010 the Justice and Home Affairs Council gave a cl ear political mandate to devel op and implement Steps 1 to 7, 
while Step 8 is being devel oped in the framework of the EU Integrated Maritime Policy. 
Under the leadership of the Commission the rele vant concepts for Steps 1 to 7 have been 
defined between 2008 and 2011, thereby determini ng the technical and operational framework 
of EUROSUR.
5 In parallel, Frontex launc hed pilot projects to test  and validate selected 
EUROSUR components. Furthermore, several Memb er States have established their national 
coordination centres with EU funding rece ived under the External Borders Fund.  
While the impact assessment presented in 2008 assessed the different components proposed in 
Steps 1 to 7 of the EUROSUR roadmap, thereby identifying 'what'  should be done, the current 
impact assessment assesses 'how'  these components should be  implemented until 2013 on the 
basis of the works carried out between 2008 and 2011.  
2. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
The Commission has taken into account the opinions  and concerns of the stakeholders – the 
border control authorities of Member Stat es. In the two progre ss reports on EUROSUR 
published by the Commission the public has been informed on the development of EUROSUR. In 2008-2011, DG Home Affairs and Frontex gave several presentations on the 
EUROSUR development to the Council,
6 the European Parliament7 and EU agencies.8  
                                                 
2 SEC(2008) 151. 
3 The following shortcomings had been listed: lack of interagency cooperation and of exchange of 
relevant information, in particular when it comes to maritime border surveillance; current technical limitations in detecting and tracking small vessels; lack of preparedness to quickly respond to changing 
routes and methods used for irregular migration and cross-border crime etc. 
4 1) Reduce number of irregular migrants entering the Schengen area undetected; 2) Reduce loss of lives 
of migrants at sea; 3) Increase  the internal security of the EU  by combating cross-border crime. 
5  See also Commission Staff Working Paper determining the technical and operational framework of 
EUROSUR and actions to be taken for its establishment, SEC(2011) 145 final of 28.1.2011. 
6  E.g. Council Working Group on Frontiers, Standing Committee on Operational Cooperation on Internal 
Security (COSI), EU Military Staff etc. 
 
EN 6   EN During this time EUROSUR has also been pres ented and discussed during conferences and 
meetings with other stakeholders, such as non -governmental organisations and academia, the 
research community9 and the private sector organisations.10 As a result, hundreds of people 
with personal and profe ssional interest in border surveillance  have been informed in detail 
about the EUROSUR initiative and their input and expertise have been taken into account. 
Since 2008 the Commission and Frontex have se t up technical expert groups, carried out 
technical studies and initiated pilot projects to develop, te st and validate the different 
components of EUROSUR.11 The active participation of Member States in these actions 
clearly demonstrates their full support and dedication to EUROSUR both at political and 
operational level. 
1) Technical expert groups 
Since 2008, six different technical expert groups have b een established in or der to develop the 
technical and operational  framework of EUROSUR,12 with the EUROSUR Member States' 
expert group  being the most important one . Having met 13 times since June 2008, this group 
is chaired by DG Home Affairs of the Eu ropean Commission and consists of border 
surveillance experts from the Member States, Frontex a nd the Commission.  
2) Technical studies 
Between January 2009 and January 2010, the EUROSUR technical study  was carried out by 
an external contractor in order to develop the key concepts of EUROSUR.13 These included 
technical and management concepts for nati onal border surveillance systems and national 
coordination centres, the system architectur e for the EUROSUR comm unication network as 
well as the system architecture for the Common Pre-frontier Intelligence Picture. 
Furthermore, between June and September 2011, the technical study  assessing the financial 
impact of establishing EUROSUR  was carried out, which provided detailed cost estimates for 
the policy options identified in this impact assessment.14 
3) Testing and validation 
Thirdly, the different technical components of EUROSUR need to be tested and validated 
among Member States and Frontex before ma king them operational. For example, the 
EUROSUR network is currently being tested on  a pilot basis between Frontex and selected 
Member States.15 Furthermore the 7th EU Framework Programme for research and 
                                                                                                                                                         
7  E.g. European Parliament Seminar on Collabor ation in Space for International Global Maritime 
Situational Awareness (C-SIGMA), Brussels, 16.11.2010.  
8  European Maritime Safety Agency (EMSA), EU Satellite Centre (EUSC), European Defence Agency 
(EDA), European Space Agency (ESA). 
9  E.g. 2008 and 2010 EU S ecurity Research Conferences. 
10  E.g. in the context of the Euro pean Security Research and Innova tion Forum (ESRIF) and the European 
Organisation for Security (EOS). 
11  Summaries of the most relevant documents can be found in Annex 1. 
12  An overview these groups can be found in Annex 2. 
13 Technical study on developing concepts for border  surveillance infrastructure, a secure communication 
network and a pre-frontier intelligence picture within the framework of a EUROSUR (EUROSUR 
technical study). Main contractor: ESG. Subc ontractors: EADS, SELEX, Thales. Consultants: 
SECUNET, University of the German Army. Budget: M€ 1, 8, funded under External Borders Fund. 
14  Technical study assessing the financial impact of establishing EUROSUR. Main contractor: GHK. 
Subcontractors: UNISYS and Euroconsult. Budget: € 144 150, funded by DG Home Affairs. 
15  For this purpose, Frontex uses an external contractor (GMV; budge t: M€ 1,5) and is supported by the 
Member States' expert group on the EUROSUR pilot project as a platform  for technical discussions. In 
2011, Finland, France, Italy, Pola nd, Slovakia and Spain will be c onnected to the EUROSUR network. 
 
EN 7   EN development (FP7) is being used since 2008 to improve the performance and test the 
combination of surveillance tools in clos e cooperation with the private sector.16  
4) Links to other EU policies 
EUROSUR will enhance interagency cooperation between national law enforcement 
authorities (border guards, police,  customs, etc.). It is therefore intrinsically linked to the 
Internal Security Strategy of the EU. By im proving the cross-sectoral  information exchange 
between different authorities with interests in  the EU maritime domain, it also supports and 
forms part of the Integrated Maritime Policy of the EU, which is coordinated by DG Maritime 
Affairs (MARE). 
Since 2008 DG HOME has worked closely with  DG Enterprise and Industry (ENTR), DG 
Maritime Affairs (MARE), DG Mobility and Transport (MOVE), DG Justice (JUST), DG 
External Relations (RELEX) and the Joint Rese arch Centre (JRC) in developing EUROSUR. 
This cooperation was formalised in an inte r-service steering group  with these General-
Directorates on 14 September 2011, involving also the Legal Se rvice (SJ), th e Secretariat-
General (SG) and DG Taxation and Customs Union (TAXUD). This interservice group, to 
which the European External Action Service (EEAS) has also been invited, met again on on 20 September 2011 and 6 October 2011, discussing le gal and technical issues linked to the 
establishment of EUROSUR, such as the protec tion of personal data and the access to ship 
reporting systems.  
The Impact Assessment Board  (IAB) reviewed the draft impact assessment and delivered its 
opinion on 21 October 2011. The recommendations  for improvement were accommodated in 
the final version of this document. In part icular, the following changes were made:  
Firstly, in Chapters 3.2 and 3.3 the problem driver s have been more fully described to clarify 
how a lack of rules hinders cooperation and ho w irregular migration and cross-border crime 
could evolve in future. In Chapter 6, when asse ssing the different options a closer link to the 
baseline scenario has been established. Second ly, in Chapter 6.5 a deeper analysis of the 
impacts of third country cooperation options to underpin the choice of the option in this 
regard. Thirdly, monitoring indicators haven been included ub Chapter 8. Fourthly, the 
scoring of the options in Chapter 6 has been  revised, systematically taking the baseline 
scenario as a reference.  
Finally, it was clarified that the selected options  were also the ones supp orted by a majority of 
Member States during the process of devel oping the different components of EUROSUR in 
the relevant technical expert groups in 2008-2011.  
3. P
ROBLEM DEFINITION  
As explained further below, the absence of a common regulatory basis fo r Member States to 
exchange information and cooperate in the ar ea of border surveillance,  especially at the 
external maritime borders of the EU, means that unauthorised border crossings and cross-
border crime may go undetected. Moreover the already unacceptable death toll of migrants 
drowning when trying to reach EU shores might even further increase. 
3.1. Border surveillance 
The EU has some 7 400 km of external la nd borders and 57 800 km of external maritime 
borders and coastlines According to EU law,  border control consists of border checks and 
                                                 
16  See Annex 1.5. 
 
EN 8   EN border surveillance. Border surveillance covers the control of land and maritime borders 
between  the border crossing points where border checks are carried out. Whereas border 
checks are specifically regulated in the Schengen Border Code , the code and accompanying 
guidance contains only general pr ovisions for border surveillance.17 According to Article 
12(1) of the Schengen Borders Code, the main purpose of border surveillance is to prevent 
unauthorised border crossings, to counter cross-border criminality and to take measures against persons who have cr ossed the border illegally.
18 
3.2. General problems face d in border surveillance19 
3.2.1. Irregular migration 
The EU faces pressure from irregular migr ation at its external borders. Over 100 000 
unauthorised border crossings were detected at the land and maritime external borders of the 
EU in 2009 and in 2010. During the first si x months of 2011, 74 300 unauthorised border 
crossings were detected, of wh ich over 96 % took place at the external borders of Spain, 
Greece, Italy and Malta. There is currently no estimate of the annual flow of irregular 
migrants managing to cross the external borde rs undetected. However, certain indicators may 
provide guidance. In 2009, the number of ill egally staying third country nationals 
apprehended inside the Member States was ab out 570 000 and Member States returned about 
250 000 persons.20 Furthermore, it is assumed that the majority of migrants illegally present in 
the EU Member States, which are estimated to vary between three to six million, are overstaying after having entered legally. 
No matter whether migrants cross the external  borders of the Member  States legally or 
irregularly, the reasons for leavi ng one's country of origin are often similar, ranging from war 
and persecution to natural disasters, famine, pollution and poor living conditions. In addition, 
there are a number of correspond ing pull-factors, which make Member States attractive for 
these migrants, such as better job opportunitie s and living conditions, political and religious 
freedom, superior education an d medical care, security and also family links. For these 
reasons irregular migration canno t be regarded as an isolated  problem, but must be embedded 
into a comprehensive European migration polic y, as pursued for instance by the Union under 
the 'Global approach to migration'.  
Taking into account differences in political stability, living conditions and demographic 
developments in the EU compared to several other regions in the world, it is likely that the numbers of persons seeking international protection or simply a better life will rise in the future. A better capability to manage migr ation flows and prevent unauthorised border 
crossings could also raise the willingness of EU  citizens to accept increased numbers of legal 
migrants, taking also into account that many EU Member States ar e facing shrinking and 
ageing populations. 
On the basis of EU and nati onal legislation, border guard, police and other law enforcement 
authorities are taking measures against irregular migration both at the external borders as well 
as inside the territories of Member States. Irre gular migration is largely facilitated by criminal 
networks, which are highly innovative and fl exible in finding new methods and quick in 
redirecting migration routes. As a result, during the last years relatively short stretches of the 
                                                
 
17 References to and excerpts of these legal acts can be found in Annex 1.1. 
18  For further details see Annex 1.1.  
19  For further details see the impact assessmen t accompanying the EUROSUR roadmap, SEC(2008) 151 
final of 13.2.2008, 6-16. 
20  Commission Communication on Migration, COM(2011) 248final of 4.5.2011, 8-9. 
 
EN 9   EN external borders, such as the Straits of Gibra ltar, the Canary Islands, Lampedusa, Malta and 
the Greek land border with Turkey have received thousands of i rregular migrants within a few 
weeks or months. Despite the c oordination efforts of Frontex Member States' border control 
authorities often face difficu lties to agree on a common approach and usually need 
considerable time to find an a ppropriate operational response. 
3.2.2. Loss of life at sea 
Many irregular migrants and persons in need of international protect ion are travelling in 
conditions of extreme hardship and are taking gr eat personal risks in their attempts to cross 
the Schengen external borders clandestinely. In particular  the practice of using small 
unseaworthy boats, which are overcrowded and w ithout any safety equipment or illumination, 
has increased dramatically the number of migrants and refug ees drowning in the Atlantic 
Ocean between Africa and the Cana ry Islands and in the Mediterra nean Sea. It is impossible 
to determine the total number of migrants ha ving lost their lives when trying to reach the 
shores of the EU Member States. However, it can be assumed that over the years their 
numbers has grown into the thousands.21  
3.2.3. Cross-border crime  
Criminal networks involved in the smuggling of migrants are often using the same routes and 
methods for cross-border crime activities, such as trafficking in human  beings, illicit drug 
trafficking, illicit arms traffi cking, trafficking in radioactiv e and nuclear substances, and 
terrorism. An effective border surveillance system both at national and European level as well as an improved interagency cooperation between  border control and po lice authorities should 
contribute significantly to fighting such se rious crimes at the external borders. 
3.3. Specific problems faced in border surveillance 
There are a number of reasons why criminal netw orks are often faster and more flexible in 
changing their routes and methods for irregu lar migration and cross-border crime than 
Member States' authorities in becoming aware of and reacting to thes e changed situations. 
3.3.1. Insufficient interagency cooperation and information sharing at national level 
Member States’ authorities involved in bo rder surveillance have set up different 
organisational structures at land and maritime borders. Whereas at the external land borders professional border guards, occasionally closel y cooperating with police and customs, are 
responsible for border surveilla nce, different solutions have  been found in each of the 
Member States for the question of who is re sponsible for the surveillance of maritime 
borders.
22  
In some Member States, up to six different author ities are directly involved in the surveillance 
of maritime borders, including various police forces, coast guards, customs, navies and air forces. In addition, other national agencies such  as fisheries control and maritime authorities 
have strong interests in maritim e surveillance. Consequently, st ructures and systems used for 
maritime surveillance are different in every Memb er State. While some Member States have 
established a single national maritime surveillance system serving all involved national 
                                                
 
21 A list of press reports can be found on http://fortresseurope.blogspot.com/2006/02/immigrants-dead-at-
frontiers-of-europe_16.html  , estimating that around 12 943 migran ts died in the Mediterranean Sea and 
around the Canary Islands between 1988 and the end of July 2011, with 1931 alone in 2011.  
22  An overview can be found in Annex 4.2. 
 
EN 10   EN authorities, in other Member States different  authorities such as border guards, maritime 
authorities and navies ha ve established parallel systems and control centres. As a result of the 
EUROSUR development, many Member States ar e in the process of establishing a joint 
coordination centre for maritime surveillance, fr om which the different national authorities 
coordinate their activities. However, in seve ral Member States, national authorities still 
operate two or more surveillance systems a nd corresponding control centres in parallel, 
without clearly determined ru les and workflows for cooperatio n and information exchange 
among them. Due to the absence of binding rules at  EU level, the pressu re to streamline and 
interlink such historically grown administrative structures could be too low for leading to the 
necessary adaptations. 
3.3.2. Insufficient information exchange between  Member States, leading to a reduced 
reaction capability 
In the field of border surveillanc e there is not only a lack of coordination inside some Member 
States, but also in between Member States, due to the absence of prope r procedures, networks 
or communication channels to ex change information. For example,  in several Member States 
national authorities do not automatically share the location of their patrols with each other, in 
particular when it comes to maritime surveillance operations. The same applies to patrols of different Member States operati ng in neighbouring border sections or maritime areas, so that 
it can happen that in ca se of an incident no proper coor dination of the patrols nearby takes 
place. Appropriate communication channels, wo rkflows and operating procedures should 
therefore be established to enhance th e cooperation between Member States.  
3.3.3. Insufficient cooperation with  neighbouring third countries 
The migration pressure presents considerable challenges not only for the Member States on 
the northern, but also for the third countries located on the southern shores of the Mediterranean Sea in terms of detection, appr ehension, reception and further processing and 
readmission of migrants. It is  therefore necessary to includ e these areas into surveillance 
activities and to support and to cooperate more closely with the countries of origin and the 
countries of embarkation of irregular migrants. 
3.3.4. Insufficient situational aw areness in the maritime domain, and in particular to detect 
and track small boats used for irregular migration and illicit drug smuggling 
From a technical point of vi ew, maritime border surveillance is more demanding than land 
border surveillance. The maritime borders are a vast space, which is filled with a huge 
number of legitimate activities such as fi shing, commercial shipping and pleasure boating. 
The fact that traffickers are currently using small wooden and glass-fibre boats for smuggling 
irregular migrants and illicit drugs poses a major challenge to  law enforcement authorities 
because it is extremely difficult to detect, iden tify and track such small, non-metallic boats on 
the high seas. Technical solutions have to be fo und to improve the situational awareness in the 
maritime domain and detect these small boats, such  as the use of earth observation satellites 
and unmanned aerial vehicles in combination with ship reporting sy stems. Taking into 
account that the practice  of using small, unseaworthy boats is the main reason for the huge 
loss of lives of migrants at sea, such a cap ability would also contribute to considerably 
reducing the loss of lives at  the external borders.  
 
EN 11   EN 3.4. Does the EU have the right to act? 
The EUROSUR legislative proposal would be based on Article 77 of  the Treaty on the 
Functioning of the European Union (TFEU). A ccording to Article 77(1)(b) and (c) TFEU the 
EU shall develop a policy with a view to effi cient monitoring of the crossing of external 
borders and the gradual introduction of an integrated management system for external 
borders .23 According to Article 77(2)(d) TFEU th e European Parliament and the Council, 
acting in accordance with the ordi nary legislative procedure, shall adopt measures concerning 
any measure necessary for the gradual establishment of an integrated management system for 
external borders .24 Article 12 of the Schengen Borders Code deals in general terms with 
border surveillance and delegates implementi ng powers to the Commission. The mandate of 
Frontex covers border management in general and therefore provides that Frontex can take 
measures related to operational coordination, excha nge of information, risk analysis as well as 
research and development for border surveillance. 
The establishment of EUROSUR will not result in the development of a new area of EU 
policy but it forms part of a policy aimed at reinforcing the management of the external 
borders of the Member States. Hence EUROSUR will constitute a new policy instrument which will streamline cooperatio n and enable systematic information exchange between 
Member States on border surveillance, something which currently does not exist at EU level. 
Once adopted, the legislative act  on EUROSUR would constitute a development of provisions 
of the Schengen acquis, in which the United Kingdom and Ire land are not par ticipating, but 
which is applicable to four associated  countries (Norway, Iceland, Switzerland and 
Liechtenstein
25). Schengen states are committed to maintaining common standards for 
external border controls. 
3.5. Subsidiarity 
In line with the principle of subsidiarity , EUROSUR follows a decentralised approach, with 
the national coordination centres for border surveillance forming the backbone of the 
EUROSUR cooperation. This mean s that in quantita tive terms most information would be 
managed in the national coordination centres, without Frontex being able to see this 
information. Only selected information of st rategic relevance would be shared with and 
analysed by Frontex. Hence EUROSUR does not a ffect the division of competences between 
the EU and its Member States. The intention is  to make best use of  existing national border 
control infrastructures in combination with operational international and European systems 
(e.g. AIS, SafeSeaNet) as well as recent technol ogical developments (e.g. use of satellites). 
By interlinking existing national and Europ ean systems and developing new capabilities, 
EUROSUR enables Member Stat es' border control authoritie s and Frontex to communicate 
and exchange information in order to have bette r situational awareness at  the external borders, 
thus bringing true added value to border survei llance. Better information sharing will help to 
identify targets such as boats used for i rregular migration and cross-border crime more 
accurately and therefore allow a more targeted timely and cost-efficient use of available 
equipment for interception. This  is an objective which cannot be sufficiently achieved by the 
Member States alone and which can be  better achieved at Union level.  
                                                 
23 Compare also Article 3 of the Treaty on European Union (TEU) and Article 67 TFEU. 
24  Compare also Article 79 TFEU on developing a common immigration policy aimed at ensuring the 
efficient management of migration flows and the prevention of illegal immigration and trafficking in 
human beings and Article 87 TFEU on police cooperation.  
25  Liechtenstein is expected to join the Schengen area until the end of 2011. 
 
EN 12   EN 3.6. What is the baseline situatio n for implementing EUROSUR? 
The EUROSUR project has been on-going since 2008, based on its roadmap agreed by the 
Council and taken forward at technical level in  relation to each step of that roadmap. 
Significant progress has already been made and this development is expected to continue. 
Against this background the baseline scenario described below takes into account the progress 
already made in developing EUROSUR so far in ge neral as well as the current state-of-play in 
relation to each of the specific problems identif ied. The baseline scenario with regard to the 
specific problems identified in sections 3.3.1 to 3.3.3 is described in sections 3.6.3 to 3.6.6. 
3.6.1. Technical and operational  framework of EUROSUR 
The 'technical and operational framework of EUROSUR' presented by the Commission in 
January 201126 interlinks the different steps identif ied in the 2008 EUROSUR roadmap in a 
coherent manner and identifies the short-term a nd long-term actions which still need to be 
taken for establishing EUROSUR. Therefore th is framework represents the baseline for 
implementing EUROSUR.  
The key components of the EUROSUR technical framework  are the following: 
– A national coordination centre (NCC) , to be set up and properly managed by each Member 
State participating in EUROSUR, shall coor dinate 24/7 the activities of all national 
authorities carrying out extern al border surveillance tasks an d exchange information with 
the national coordination centres in other Member States, as well as with Frontex. Similar 
centres should also be set up in neighbouring third countries, communicating with Member 
States via regional networks. 
– The Frontex Situation Centre (FSC)  shall provide the national coordination centres with 
pre-defined services such as the comm on application of surveillance tools. 
– The EUROSUR network  shall provide communica tion tools and enable secure exchange of 
security sensitive data and information between the national coordination centres and Frontex, which should technica lly administer the network. 
The EUROSUR operational framework  should consist of rules for collecting and sharing 
information via the following common  'situational pictures'  and services : 
– Each national coordinati on centre shall manage a National Situational Picture (NSP),  
which consists of information collected from local situational pictures and from different national authorities, as well as intelligence gathered, for example, from the Common Pre-
Frontier Intelligence Picture and the cooperation with third countries. 
– Frontex shall manage the European Situational Picture (ESP) , which shall consist of 
aggregated information from e.g. open-sour ce intelligence, the National Situational 
Pictures, the Common Pre-Frontier Intelligen ce Picture and the service for the common 
application of su rveillance tools. 
– Frontex shall also manage the Common Pre-Frontier Intelligence Picture  (CPIP), which 
should include information and intelligence on the pre-frontier area which is of relevance 
for the prevention of irregular mi gration and cross-border crime. 
 
                                                
 
26  Compare SEC(2011) 145 final of 28.1.2011. 
 
EN 13   EN 
NCC
NCCNCCNCC
NCCNCCNCC
NCCNCCNCC
NCC
NCCNCC
NCCNCC
TECHNICAL 
FRAMEWORK
OPERATIONAL 
FRAMEWORK
European 
Situational 
Picture
shared via Frontex
NCCs
National 
Situational 
Picture
shared via NCC
Common Pre-
frontier Intelli-
gence Picture
shared via Frontex
 EUROSUR
NetworkCommon 
application of 
surveillance tools
via Frontex
 
 
EN 14   EN – Via the service for the common application of surveillance tools  (e.g. satellites, ship 
reporting systems), Frontex shall provide natio nal coordination centres with surveillance 
information on their borders and on the pre-fr ontier area on a frequent, reliable and cost-
efficient basis. 
This common technical and operational fr amework shall considerably improve the situational 
awareness  and the reaction capability  of national authorities surv eying the Schengen external 
borders.  
By merging the different components into one common framework, it sha ll lead over time to a 
unified approach of actors at tactical, operati onal and strategic levels, allowing for informed 
and timely decision making and coherent exec ution based on the seamless and efficient 
sharing and exploitation of information by properly tailored processes and networks. 
3.6.2. Scope of EUROSUR27 
The EUROSUR framework should allow to focu s on the relevant needs of border control 
authorities and on the information to be exch anged between them. This ensures that the 
measures adopted for the establishment of EUROSUR do not go beyond what is necessary in 
order to achieve the objectives identified in the next section. 
Initially EUROSUR should be li mited to the 18 Member States  and associated countries 
located at the eastern and southern Schengen external borders,28 because problems with 
irregular migration and cross- border crime mainly occur at these borders. Once EUROSUR 
has been established in 2013, it should be quick ly extended to all 24 Schengen countries with 
land and maritime external borders,29  taking into account that rout es might shift as a result of 
improved surveillance at the southern and easte rn borders. Air border surveillance and border 
checks shall be out of scope of EUROSUR for the time being.30 
When carrying out border surveillance activitie s at the external borders, Member States' 
authorities have to fulfil their obligations which arise from international instruments,31 
including the prohibition on sending a person back to a country where he or she risks being 
exposed to torture or to inhuman or degrad ing treatment or punishment (principle of non-
refoulement).32 Therefore EUROSUR aims in partic ular at improving the detection, 
identification and tracking of small boats, th ereby supporting search and rescue missions 
without prejudice to the functions  and tasks of the responsible  Rescue Coordination Centres.33  
                                                 
27  An overview table on the scope of EUROSUR can be found in Annex 3. 
28  Norway, Finland, Estonia, Latvia, Lithuania, Po land, Slovakia, Hungary, Romania, Bulgaria, Cyprus, 
Greece, Slovenia, Malta, Italy, France, Spain and Portugal.  
29  Thus also including Sweden, Germany, Denmark, Netherlands and Belgium. 
30  Thus Austria, Czech Republic, Liechtenstein, Luxem bourg and Switzerland woul d not actively take part 
in EUROSUR. 
31 United Nations Convention on the Law of the Sea (U NCLOS), 1982; Convention for the Safety of Life 
at Sea (SOLAS), 1974; International Convention on Maritime Research and Rescue (SAR), 1979. 
32 Articles 4 and 19(2) of the Charter of Fundament al Rights of the EU; Article 3 of the European 
Convention on Human Rights, Article 3 of the UN Convention against Torture; Article 33 of the  UN 
Convention Relating to the Status of  Refugees and the 1967 Protocol thereto. 
33  Compare also Council Decision 2010/252/EU of 26 April 2010 supplementing the Schengen Borders 
Code as regards the surveillance of the sea external borders in the context of operational cooperation 
coordinated by Frontex, OJ L 111 of 4 May 2010, 20. See Annex 1.1. 
 
EN 15   EN 3.6.3. Baseline scenario for national coordina tion centres and the Frontex situation centre 
Since 2008, Member States have been using the External Borders Fund (EBF) for setting up 
their national coordination centres (NCCs). In order to "support the development and 
implementation of the nationa l components of EUROSUR", the EBF foresees up to 75% 
EU funding for "investments in establishi ng or upgrading a single national coordination 
centre, which coordinates 24/7 the activities of all national authorities carrying out external border control tasks (detection, id entification, and intervention) a nd which is able to exchange 
information with the national coordination centers in other Member States".
34 It is up to each 
Member State to determine the authority responsible for the NCC, which sometimes requires 
intensive negotiations between different  national authorities and ministries. 
Table: Overview of current and planned responsibilities of NCCs35 
Responsibilities of NCCs 
of 24 Member States located 
at land and maritime external 
borders with regard to  Responsible Planned Not 
responsible No 
reply Not  
applicable 
Maritime border surveillance 13 5 - 4 2 
Air border surveillance 6 6 8 4 - 
Land border surveillance 7 3 1 1 12 
Border checks 12 2 6 4 - 
Other national authorities 17 3 - 4 - 
Third countries 12 4 4 4 - 
Local/regional centres 14 2 4 4 - 
Other national 
coordination centres 12 6 2 4 - Coordination Frontex 12 5 3 4 - 
Command and control 12 3 5 4 - 
Up to the level of EU 
Top Secret 2 1 - 4 - 
EU Secret 3 - - 4 - 
EU Confidential 1 5 - 4 - 
EU Restricted 5 5 - 4 - 
Unclassified, but 
protected 6 - - 4 - 
Unclassified 3 - - 4 - Information exchan ge 
Handling personal data 9 - 6 9 - 
Following a detailed questionnaire sent by the Commission in 2008, Member States and 
Frontex elaborated a first description of th e tasks of NCCs in 2009. In parallel, Frontex 
carried out an assessment determ ining those parts of the extern al borders that should be 
covered by a stationary border surveillance system.36 On the basis of these works, a technical 
study  was carried out by an external contract or in 2009-2010 in order to develop the key 
concepts of EUROSUR, such as technical a nd management concepts for NCCs and national 
border surveillance systems, leading to a revise d version of the description of the tasks of 
NCCs in 2010.  
                                                 
34  Commission Decision 2007/599/EC of 27 August 2007 (EBF strategic guidelines, priority 2). 
35  A more detailed overview can be found in Annexes 4.1 to 4.5. 
36  This assessment also included a comparison with the plans presented by th e Member States in the 
context of the External Borders Fund, showing th at they generally match with the assessment. 
 
EN 16   EN These 'EUROSUR guidelines'  are currently being used by Member States and Frontex on a 
voluntary basis for setting up the relevant co mponents of EUROSUR. Using the financial 
support given under the External Borders Fund, between 2008 and 2010 13 out of the 18 
Member States located at the southern and easte rn Schengen external borders have established 
their NCCs, with the majority  of them becoming operationa l in 2011. This number will 
increase to 16 by the end of 2011.37  
The table above shows that the basic responsibi lities of NCCs differ widely between Member 
States which is a considerable obstacle in the daily cooperation and information exchange. 
With regard to the 18 Member States located at  the southern and eastern  external borders, the 
table above can be summarised as follows: 
As far as the responsibilities and competencies  of the 18 NCCs located at the southern and 
eastern Schengen external borders are concerned,38 10 NCCs are already responsible and 
5 NCCs are planned to become responsible for maritime border surveillance .39 7 of these 
18 NCCs are by now responsible and 3 NCCs are intended to become responsible for land 
border surveillance .40 5 NCCs out of the 18 NCCs are responsible for air border surveillance  
and another 6 NCCs planned to become responsib le for air border surveillance. However, in 
641 out of the remaining 7 Member States this is not envisaged. Furthermore, out of the 18 
NCCs 10 are responsible and another 2 are planned to become responsible for border checks , 
while for 5 NCCs nothing is planned in this regard.42 Finally, 11 out of these 18 NCCs have 
already command and control  functions, and 3 are planning to get them, while 3 Member 
States43 exclude this possibility.  
M€ 40 have been spent between 2007 and 201 0 in setting up and upgrading the 13 NCCs 
established until the end of 2010, using national funding, but also funding from the External 
Borders Fund and the Schengen Facilities.44  
The counterpart for the NCCs in Frontex is the Frontex Situation Centre  (FSC) which has 
been set up in 2008. In the context of EUROSUR, the FSC shall serve as the single point of 
contact in Frontex for the information exchan ge and cooperation with the NCCs. The total 
cost of establishing the FSC amount ed to M€ 2.2 between 2008 and 2010.  
3.6.4. Baseline scenario for the EUROSUR ne twork and the sit uational pictures 
The goal is to set up a secured communicatio n network which will provide communication 
tools and enable electronic data exchange in order to send, receive and process information 
24/7 close-to-real time between the national coor dination centres as well as with Frontex. In 
2009-2010 the system architecture of the EUROSU R network as well as the content of the 
National and European Situational Pictures and the Common Pre-Frontier Intelligence Picture 
have been defined in the EUROSUR techni cal study and in the EUROSUR guidelines.  
                                                 
37  Greece plans to make its NCC operational in 2013 . Norway could not provide a reply at this stage. 
38  See overview in Annex 4.1. 
39  Of the 4 remaining Member States, 2 (Hungary and Slovakia) do not have any maritime borders. One 
country (Norway) could not provide a reply at this stage.  
40  Of the remaining 8 Member States, 6 do not have any land border, while one (Romania) replied that its 
NCC is not planned to become responsible for land  border surveillance and another country (Norway) 
could not provide a reply at this stage. 
41  Cyprus, France, Malta, Romania, Slovenia and Slovakia. Norway could not provide a reply at this stage. 
42  Norway could not provide a reply at this stage. 
43  France, Italy and Poland . Norway could not provide a reply at this stage. 
44  The costs ranged from € 22 514 in Romania to M€ 18,8 in Slovakia. An overview of the 2007-2010 
NCC costs can be found in Annex 4.4. 
 
EN 17   EN Between November 2010 and May 2012, based on  a Memorandum of Understanding Frontex 
carries out a pilot project in order to test the network and the information exchange via 
situational pictures with initially six Member States45 in daily practice. This pilot project is 
being funded by Frontex with M€ 1, 5, using an external contractor. 
3.6.5. Baseline scenario for the coope ration with third countries 
A well-structured and permanent cooperation and information exchange with neighbouring 
third countries, in particular in the Mediterranean region, is a key factor for the success of 
EUROSUR, but also a goal which will be  achieved neither quickly nor easily.  
In 2011 the EU has made EUROSUR a targeted initiative in the Thematic Programme for 
Migration and Asylum,46 reserving considerable funding fo r 2011-2013 for the third countries 
situated along the southern and south-eastern  maritime borders of the EU which accept to 
cooperate in the framework of EUROSUR.  
A concrete example how such support could le ad to an enduring and steady cooperation and 
information exchange between Member Stat es and neighbouring third countries are the 
following three existi ng regional networks:47 
o SEAHORSE  is a network between border contro l authorities in Spain, Portugal, 
Mauretania, Morocco, Senegal, Gambia, Gu inea Bissau and Cap Verde for exchanging 
information on irregular migration and crim inal activities at the Western and North-
Western African coasts (Canary Islands). 
o The Baltic Sea Region Border Control Cooperation  (BSRBCC) is a regional tool for daily 
inter-agency (police, customs, coast guards and border guards) interaction in the Baltic Sea to combat cross-border crime. In the BSRBCC Denmark, Estonia,  Finland, Germany, 
Latvia, Lithuania, Norway, Poland, Russia and Sweden are exchanging relevant information via a dedicated network called COASTNET.  
o Within the framework of the Black Sea Littoral States Border/Coast Guard Cooperation 
Forum (BSCF), border and coast guards from Bu lgaria, Romania, Ukraine, Russia, 
Georgia and Turkey are exchanging information with regard to illegal activities via the Black Sea Border Coordination and Information Center  (BBCIC) at Bourgas/Bulgaria.  
The BSRBCC/COASTNET and BSCF/BBCIC have been gradually esta blished since 2005 
and SEAHORSE since 2006.
 The overall costs for setting up, upgrading and maintaining the 
technical infrastructure of  these regional cooperation centres is M€77 in 2007-2010. 
3.6.6. Baseline scenario for the common applica tion of surveillance tools at EU level 
In 2008-2009, the GMES48 border surveillance working group elaborated the GMES concept 
in support to EUROSUR ,49 focusing in particular on the use of satellites and other 
surveillance tools for the tracking of vessels  and the punctual monitoring of neighbouring 
                                                 
45  Spain, France, Italy, Slov akia, Poland and Finland. 
46  Commission Decision C(2011)2304 of 7.4.2011 ad opting the Multiannual Indicative Programme 2011-
2013 for the Thematic Programme 'Cooperation with Third Countries in the areas of Migration and Asylum". 
47  For further details see Annex 6.1. 
48  GMES (Global Monitoring for Environment and Security) is the European Initiative for the 
establishment of a European capacity for Earth Observation. More information can be found at 
http://ec.europa.eu/gmes/index_en. htm and http://www.gmes.info.  
49  See Annex 1.6. 
 
EN 18   EN third country ports and coasts, which are known as departure points for irregular migration 
and narcotics trafficking.  
Due to the high costs and the lack of rea dy-made solutions only a few Member States50 
currently use satellites, unmanned aerial vehicles  and aerostats on an occasional, usually test 
basis for border surveillance purposes. Since uncertainty as to the performance and 
operational reliability of such technologies is high, a number of FP7 funded research projects 
are currently going on in order to improve and verify the technological capabilities for using 
such surveillance tools for border security purposes.51 
4. OBJECTIVES  
4.1. General objectives 
By establishing an information exchange and cooperation mechanism, which allows national 
authorities carrying out border su rveillance activities and Front ex to exchange information 
and to cooperate at tactical, operationa l and strategic level, EUROSUR shall 
1) Contribute to the management of migrati on flows by reducing the number of irregular 
migrants entering the Schengen area undetected; 
2) Protect and save lives at the external borders by diminishing considerably the 
unacceptable death toll of migrants at sea; 
3) Increase the internal security of the Europ ean Union and of the pe ople residing in the 
EU by preventing serious crime at the ex ternal borders of the Schengen area; 
The general objectives 1 and 3 should be seen as  a contribution to providing EU citizens with 
an area of freedom, security and justice  without internal frontiers, in which the free 
movement of persons is ensured in conjunction with measures for external border controls 
and the prevention and combating of crime .52 
4.2. Specific and operational objectives 
In order to achieve the general objectives, EU ROSUR has two specific objectives, namely to 
significantly increase the situational awareness  and reaction capability  of the Member States' 
border control authorities and Frontex, so that in  a best case scenario any new route or method 
for irregular migration and cross- border crime is identified and disrupted shortly after it has 
been established. 
1) Situational awareness  measures how the authorities are capable of detecting cross-border 
movements and finding reasoned grounds fo r control measures.53 This can be 
accomplished by achieving the following operational objectives at national and European level: 
a. Improved interagency cooperation by stream lining structures and interlinking 
systems in the law enforcement domain; 
                                                
 
50  E.g. Spain, Italy, Malta. 
51  See Annex 1.5. 
52  Article 3(2) TEU and Article 67(2)TFEU. Compar e also Article 77(1)(b) and (c) and 77(2)(c) TFEU. 
53 Full situational awareness is only needed at tactical and operational level (e.g. in the local and regional 
coordination centre) in order to take real-time operational decisions. At strategic level (e.g. in the NCC 
and in Frontex) only a subset of the data is needed to take decisions. 
 
EN 19   EN b. The use of data fusion combined with modern technological capabilities for 
detecting and tracking cro ss-border movements, in pa rticular (small) vessels;54 
c. Cross-sectoral information exchange with other actors in the maritime domain, 
such as transport, customs, fisheries control and defence; 
d. Improved information exchange wi th neighbouring third countries. 
2) The reaction capability  measures the lapse of time requi red to reach any cross-border 
movement to be controlled and also the time and the means to react adequately to unusual 
circumstances. The following operational objec tives should therefore be attained at 
national and European level: 
a. Exchange of data, information and intelligence in close-to-real time and - 
whenever needed - in a secure manner, thereby moving from a patrolling driven to a more intelligence driven  approach based on risk analysis; 
b. Effective management of personnel an d resources, includ ing sensors and 
patrols; 
c. Effect measurement, evaluating the eff ect of border surveillance activities, 
thereby providing a new baseline for risk assessment and re-arrangement of priorities.  
Table interlinking problems, objectives and actions 
Specific problems Specific objectives Actions envisaged 
Insufficient interagency 
cooperation and information exchange at national level. 1a - Streamlining structures and interlinking systems 
at national level. 
2a - Effective management of personnel & resources. 2c – Effect measurement. Establishment of a national 
coordination centre  (NCC). 
Insufficient information 
exchange between Member States. 2a - Exchange of data, information and intelligence in 
close-to-real time. Setting up of the EUROSUR 
network,  interlinking NCCs 
and Frontex. 
Insufficient cooperation with neighbouring third countries. 1d - Improved information exchange with 
neighbouring third countries. 
 Interlinking EUROSUR with 
regional networks  set up 
between Member States and 
neighbouring third countries. 
Insufficient situational 
awareness in the 
maritime domain (e.g. 
detection of small boats). 1b - Use of data fusion combined with technological 
capabilities for detecting and tracking cross-border 
movements. 
1c - Cross-sectoral information exchange with other 
actors in the maritime domain Setting up of a service for 
the common application of 
surveillance tools  at EU 
level. 
5. POLICY OPTIONS  
5.1. Overview of policy options 
The first option to be addressed is not to take any further action at EU level. As described in 
the baseline in section 3.6, not ta king any coordinated action at EU level would mean that the 
different steps identified in the 2008 EUROSUR roadmap will continue to be implemented in 
a non-coherent manner, resulting in overlaps and reduced efficiency when addressing the 
problems described in section 3.2. Furthermore, the problems described in sections 3.3 would 
be insufficiently addressed, because there would no clear rules on the criteria for 
                                                 
54  E.g. by combining data and information derived from different civilian and military ship reporting 
systems, patrol assets, satellites and other surveillance tools. 
 
EN 20   EN implementation of the individual steps as well as on the obliga tions of Member States and 
Frontex, including on how they should contribute to  and benefit from EUROSUR. Hence, this 
option is being discarded as ineffective for ach ieving the objectives out lined in section 4.  
The question to be answered in this impact assessment is not which , but how the different 
components of EUROSUR as identified in Steps 1, 2, 3, 5, 6 and 7 of the EUROSUR roadmap
55 should be implemented. To this end, thr ee policy options have been identified, 
following a  
 fully  decentralised  (policy option 1),  
 partly  centralised  (policy option 2) and  
 fully centralised  (policy option 3) approach.  
In line with Step 1 of the EU ROSUR roadmap and the specific problems identified in section 
3.3.1, the responsibilities to be given in th e EUROSUR legislative proposal to the national 
coordination centres  could include:56 
 Coordination of the surveillance of land and maritime borders ( Policy Option 1.1 ); 
 Command & control  competencies for the surveillance of land and maritime borders 
(Policy Option 1.2) ; 
 Command & control  competencies for border control57 (Policy Option 1.3).  
With regard to Step 2 of the EUROSUR road map and the specific problems identified in 
section 3.3.1, the different polic y options for setting up the EUROSUR network  are being 
assessed, taking into account whether the NCCs and Frontex use it for: 
 Decentralised and unclassified  information exchange ( Policy Option 2.1 ); 
 Decentralised and classified  information exchange ( Policy Option 2.2 ); 
 Centralised and classified  information exchange ( Policy Option 2.3 ). 
In line with Steps 6 and 7 of  the EUROSUR roadmap, Policy Option 2.2 assesses also the 
impact of costs for including the informati on exchange on cross-border crime and of 
providing the Common Pre-frontie r Intelligence Picture (CPIP). 
In line with Step 3 of the EU ROSUR roadmap and the specific problems identified in section 
3.3.3, it is assessed whether information between the EUROSUR network and 
neighbouring third countries  could be exchanged via 
 National coordination centres,  serving as a 'hub' for regional networks  and bilateral 
information exchange  with neighbouring third countries ( Policy Option 3.1 ); 
 National coordination centres, serving as a 'hub' for regional networks  with 
neighbouring third countries, with a new regional network to be set up in the 
Mediterranean region ( Policy Option 3.2 ); 
 Frontex only ( Policy Option 3.3 ). 
 
                                                 
55 Step 4 on research for border surveillance is focusi ng on the development, testing and validation of the 
other steps before them being implemented. Step 8 is being carried out in the framework of the EU 
Integrated Maritime Policy and does not form part of this impact assessment.  
56  Policy Options 1.1 and 1.2 shall be understood as minimum requirements. 
57  Surveillance of land, maritime and air borders and border checks at border crossing points. 
 
EN 21   EN 2008 IA: WHAT?  2011 Impact Assessment: HOW?   
Step Objective:  
Setting up of  Policy option 1  
Decentralised approach  Policy option 2  
Partly decentralised approach  Policy option 3  
Centralised approach  
1 National 
Coordination 
Centres (NCC)  1.1 NCC coordinates the surveillance of 
land & maritime  external borders 1.2 NCC  has command & control  (C2) 
competencies for the surveillance of land & 
maritime  external borders 1.3 NCC has C2 competencies for border 
control  (maritime, land & air border 
surveillance and border checks). 
2 EUROSUR network  
. 2.1 Network is used for decentralised & 
unclassified  information exchange on 
 Irregular migration at external 
borders; 
 Info is shared in decentralised 
manner , using internet without 
encryption ; 
 Frontex  administers the network. 
 Frontex provides services  (audio/ 
video conferencing). 2.2 Network is used for decentralised & 
classified  information exchange (up to EU 
Restricted) on 
 Irregular migration  & serious crime  at 
external borders; 
 Info is shared in decentr alised manner, 
using internet with encryption ; 
 Frontex  administers the network;  
 Frontex provides in a centralised manner 
services  (CPIP, satellite imagery). 2.3 Network is used for centralised & 
classified  information exchange (up to EU 
Restricted) on 
 Irregular migration  & serious crime  
at external borders; 
 Info is shared in centralised manner, 
using a central data base and intranet ; 
 Frontex  administers the network; 
 Frontex provides products & services  
like in 2.2. 
3 Cooperation with 
neighbouring third 
countries 3.1 NCCs act as a 'hub' for exchanging 
information between the EUROSUR 
network, existing regional networks and 
the bilateral cooperation of Member 
States with third countries. 3.2 NCCs act as a 'hub' for exchanging info 
between EUROSUR network and regional 
networks. An additional network is established in 
the Mediterranean region, complementing 
bilateral cooperation. 3.3 Frontex acts as a hu b for exchanging 
info between NCCs and third countries, 
by connecting third countries directly to 
the EUROSUR network. 
4 Research & 
development  Using FP7 funding, Step 4 is used for developing and te sting the technical capabilities envisaged in the other steps. 
5 Common 
application of 
surveillance tools  4.1 This service is provided by external 
service providers  directly to each NCC 
on basis of bilateral contracts. 4.2 This service is provided by Frontex in 
cooperation with EMSA and EUSC and funded 
by GMES. 4.3 This service is provided by Frontex  
alone (without other EU agencies). 
6 CPIP58 The impact of the CPIP is assessed under Step 2. 
7 CISE59 for internal 
security The impact of the exchange of information on combating serious crime at the EU external borders between border guards and other  law 
enforcement authorities is assessed under Step 2. 
                                                 
58  Common Pre-Frontier Intelligence Picture. 
59  Common Information Sharing Environment. The CISE for the EU maritime domain (Step 8) is developed in the framework of the EU Integrated Maritime Policy. 
 
EN 22   EN With regard to Step 5 of the EUROSUR ro admap and the specific problems identified in 
section 3.3.2, it is scrutinized whether the service for the common applications of 
surveillance tools at EU level should be provided by 
 External service providers to each concerned NCC directly ( Policy Option 4.1 ); 
 Frontex together with other European agencies and GMES ( Policy Option 4.2 ); 
 Frontex alone ( Policy Option 4.3 ). 
The three policy options are examined in the context of each component (national 
coordination centre, EUROSUR network etc.) and then compared with each other. 
5.2. Policy options for setting up the national coordination centres 
With a view to streamlining the interagency cooperation at national level, the goal is to 
establish one national c oordination centre (NCC) for border surv eillance first in each of the 
18 Schengen countries located at the eastern an d southern external borders of the Schengen 
area and later on in all 24 Sc hengen countries with external land and maritime borders.  
Table illustrating Policy Options 1.1 to 1.3 
 
 
EN 23   EN The existing or planned NCCs c ould be categorised as follows:60 
Policy options applied to 18 NCCs  
Policy Option 1.1  
NCC coordinates (at least) 
the surveillance of land and 
maritime surveillance Policy Option 1.2  
NCC has command & 
control competencies for (at 
least) land and maritime 
surveillance Policy Option 1.3 
NCC has command & 
control competencies for 
border control 
Italy, France, Netherlands, 
Belgium and Poland Cyprus, Spain, Hungary, 
Malta, Romania, Greece, 
Slovenia and Slovakia Bulgaria, Estonia, Germany, 
Latvia, Lithuania, Portugal 
and Finland 
Since responsibilities and competencies of NC Cs differ considerably from one Member State 
to another, there is a need to clarify and ha rmonise the responsibilities and competencies of 
NCCs and Frontex, in this manner facilita ting and streamlining th eir daily cooperation. 
5.2.1. Policy Option 1.1: NCC coordinates land and maritime border surveillance 
Giving the NCC a coordination  function for all national au thorities involved in border 
surveillance would in particular increase the si tuational awareness at maritime borders, taking 
into account that in some Member States up to  six different national authorities are involved 
in maritime border surveillance, sometimes  running parallel systems and centres. The 
question of who should manage the NCC is to  be decided by each Member State. This 
question might be answered more easily in case the NCC has only a coordination role. 
Making the NCC responsible for land and maritime border surveillance  would take into 
account that routes can change quickly between  land and maritime borders, as demonstrated 
at the Greek-Turkish border. 
5.2.2.  Policy Option 1.2: NCC has command & contro l competencies for the surveillance of 
land and maritime borders 
Under this policy option, the NCC does not onl y provide situational aw areness of conditions, 
activities and developments along the external  land and maritime borders, but has also 
command and control  functions to ensure an immediate reaction. Command and control (C2) 
is the common term for the effective manageme nt of personnel and resources. Command and 
control functions are performed through an  arrangement of personnel, equipment, 
communications, facilities and procedures employed by a comma nder in planning, directing, 
coordinating, and controlling forces and ope rations in the accomplishment of the mission. 
5.2.3. Policy Option 1.3: NCC has command & cont rol competencies for border control61 
Including air border surveillance  would also cover th e use of small planes for cross-border 
crime. In particular Spain is recently facing a growing number of small low-flying planes 
coming from Northern Africa, either landing on unmarked airfields or dropping drugs while 
flying over its territory. There is the risk that th is practice could spread also to other Member 
States. 
Including border checks  would have the advantage of giving the NCC full situational 
awareness and reaction capability fo r all aspects of border control. 
                                                 
60  Based on replies r eceived from 20 Member States in August 2011. 
61  Surveillance of land, maritime and air borders and border checks at border crossing points. 
 
EN 24   EN 5.3. Policy options for setting up the EUROSUR network 
Table illustrating Policy Options 2.1 to 2.3 
 
5.3.1. Policy Option 2.1: Network used for decentra lised & unclassified information exchange  
Setting up the EUROSUR network in a decen tralised manner would mean that the 
information would be physically managed by each  NCC. From a technical point of view, the 
parameters of the pilot project mentioned in th e baseline scenario w ould apply to Option 2.1, 
meaning that the network is  
• Technically administrated by Frontex; 
• Used for unclassified and decentralised info rmation exchange on irregular migration,  
• Using internet without encryption;62 
• Providing communication services, such  as audio/video conferencing.  
However, there would be three major differences: 
o The information exchange in the EUROSUR network would be based on EU legislation , 
providing a firm and permanent legal basis instead of the Memorandum of Understanding  
signed between Frontex and the Member Stat es participating in the pilot project. 
o Not only six, but in 2012 the 18 Schengen countries  located at the southern and eastern 
external borders and in 2014 all 24 Schengen countries  with land and maritime external 
borders would connect their NCCs to the network to exchange information. 
                                                 
62  But password protected and using https. 
 
EN 25   EN o Not only Frontex, but another 4 EU agencies63 would be connected to  the network in 2012 
and an additional 2 European agencies64  in 2014. 
5.3.2. Policy Option 2.2: Network used for decentr alised & classified information exchange  
Option 2.2 would be an extended  version of Option 2.1 and theref ore using the same technical 
parameters. In addition, under Option 2.2 the netw ork would be used also for exchange of 
• classified information via internet with encryption tools  (up to the level EU Restricted); 
• information concerning cross-border crime ; 
• the Common Pre-Frontier Intelligence Picture (CPIP ).65 
Including the possibility  of exchanging classified information in a secure manner allows 
exchanging sensitive information related to cros s-border crime and intelligence as envisaged 
under the CPIP. 
5.3.3. Policy Option 2.3: Network used for centralis ed & classified info rmation exchange  
While again using similar technical parameters, Option 2.3 would be a fully centralised  
version of Option 2.2 for 
• Sharing unclassified and classified inform ation via Frontex (NCC – Frontex – NCC); 
• Sharing information up to th e level of EU Restricted. 
Making Frontex responsible for a centralis ed information exchange, including the 
management of hardware and software, would fac ilitate the daily management and also future 
technical upgrades of the network. 
In addition to the above mentione d sup-options, one could also c onsider to give  the technical 
administration of the EUROSUR ne twork to the Large Scale IT Agency, which is expected to 
become operational in autumn 2012 in order to  manage the Schengen Information System II, 
the Visa Information System and EURODAC. Task ing this agency to administrate also the 
EUROSUR network could, howev er, considerably slow dow n the daily operation of 
EUROSUR, because the situational pictures used for exchanging information in EUROSUR 
need to be updated permanently and in close to-real-time. This would the task of Frontex, which might loose precious time and resources in coordinating with the Large Scale IT 
Agency, also taking into account that in EU ROSUR information would be exchanged in a 
decentralised manner and not be stored centr ally. Hence this option has been discarded. 
                                                
 
63  EU Satellite Centre, European Maritime Safety Agency, European Fisheries Control Agency, 
EUROPOL.  
64  Centre de Coordination pour la lutte antidrogue en Méditerranée (CeCLAD-M) and the Maritime 
Analysis and Operations Ce ntre – Narcotics (MAOC-N). 
65  The National Situational Pictures are supposed to be managed by the NCCs and the European 
Situational Picture by the Frontex Situation Centre (FSC). Therefore they are not assessed separately. 
Their costs have been included in the cost estimates for the NCCs and the FSC. 
 
EN 26   EN 5.4. Policy options for cooperating with neighbouring third countries 
Table illustrating Policy Options 3.1 to 3.3 
 
5.4.1. Policy Option 3.1 (bilateral approach) 
Under Option 3.1, the Member States' NCCs woul d act as a 'hub' for exchanging information 
between the EUROSUR network on the one ha nd and the Member States' information 
exchange with neighbouring third countries on the other hand, car ried out on a bilateral basis 
as well as in the framework of the th ree regional networks mentioned above. 
In comparison to the baseline scenario, Op tion 3.1 would bring the three existing regional 
networks (SEAHORSE, CoastNet, BSCF), which have been set up by Member States on their 
own initiative, into the EU framework, allowi ng to exchange information between EUROSUR 
and neighbouring third countries vi a the national coordination centres. 
5.4.2. Policy Option 3.2 (regional approach, includ ing the setting up of a new network) 
Like under Option 3.1, the national coordination cen tres would act as a 'hub' for exchanging 
information between the EURO SUR network and regional netw orks. In addition, a new 
regional network called 'SEAHO RSE Mediterraneo' would be set up, enabling the Member 
States in the Mediterranean region, which for the time bei ng exchange information with 
neighbouring third countries  only on a bilateral basis, to intensify the regional cooperation.  
5.4.3. Policy Option 3.3 (centralised approach) 
Under this option, Frontex would centralise the information exchange with neighbouring third 
countries by connecting them directly to th e EUROSUR network, there by replacing bilateral 
cooperation and the above me ntioned regional networks. 
 
EN 27   EN 5.5. Policy options for the common applicatio n of surveillance t ools at EU level  
Table illustrating Policy Options 4.1 to 4.3 
 
5.5.1. Policy Option 4.1 (bilateral approach) 
Policy Option 4.1 assumes that Member States w ould 'work in isolation' when using tools 
such as earth observation satell ites for border surveillance. Whereas in the baseline scenario 
Member States cooperate with private sector providers and national sp ace agencies, under this 
option they would also take adva ntage of the capabilities provi ded by the EU Satellite Centre 
(EUSC) and the European Maritime Safety Agency (EMSA): 
• EMSA provides technical assistance a nd support on maritime safety, pollution by 
ships and maritime security. Fo r this purpose, EMSA operates inter alia  systems on 
vessel traffic reports (LRIT, SafeSeaNet) and satellite monitoring (CleanSeaNet). 
• The EUSC is an Agency of the European External Action Service. The staff of the 
Centre consists of image an alysts, geospatial specialist s and supporting personnel from 
EU Member States. 
Under this option each NCC would have to nego tiate separately with EMSA and the EUSC, 
which could be difficult due to the fact that border surveillan ce is not covered by the mandate 
of these two agencies. The NCCs would also have to fully cover the costs for using the 
services, including the setting up of dedicated  communication lines. The processing of the 
information and the updating of the National Situational Picture would be undertaken at 
national level. 
 
EN 28   EN 5.5.2. Policy Option 4.2 (cooperative approach) 
Policy Option 4.2 would envisage th at Frontex would provide for a common application of 
surveillance tools  (e.g. satellites, unmanned aerial vehicl es, aerostats, ship reporting systems 
etc.) at EU level. This option ha s been described in detail in the Concept of operations 
(CONOPS) for the common application of surveillance tools , which has been finalised by the 
GMES border surveillance group in July 2011.66 The service described in the CONOPS 
would allow Frontex to provide NCCs vi a the EUROSUR networ k with surveillance 
information on a frequent, reliable and cost-effi cient basis. Frontex would closely cooperate 
with EMSA and the EUSCmaking best use of already existing operati onal capacities, thereby 
avoiding duplication and extra co sts. The financial costs for this European service would be 
covered initially by Frontex and later on by GMES. 
5.5.3. Policy Option 4.3 (centralised approach) 
Under this option, the services  described in the CONOPS woul d be provided only by Frontex. 
Frontex would contract directly private sector  service providers, b ecause it would not be 
cooperating with the EUSC and EMSA. 
6. ASSESSMENT OF THE IMPACTS OF POLICY SUB -OPTIONS  
6.1. Assessment criteria 
Each sub-option in the policy options is sc reened according to the following criteria: 
1. Effectiveness:  The extent to which the proposal can be expected to ac hieve the general, 
specific and operational objectives. 
2. Consistency:  The extent to which options are consistent with the overall EUROSUR 
approach, other EU policies and activities, including their acceptance by Member States. 
3. Costs:  The extent to which the ge neral policy objectives can be achieved for a given level 
of resources/at the least cost (cos t-effectiveness) as well as the extent to which costs could be 
covered by EU financial progr ammes and by Member States. 
4. Impact on fundamental rights , in particular on the pr otection of personal data. 
Taking into account that the different compone nts of EUROSUR concern mainly interagency 
cooperation and information, the environmental imp act is only marginal. No legal information 
obligations except the ones menti oned in Chapter 8 are envisaged. 
As far as the economic impact is concerned, the decentralised step-by-step approach in 
EUROSUR could possibly have a favourable impact on small and medium sized entreprises, 
because the implementation is done largely by th e individual Member States and the Frontex, 
with the result that a multitude of smaller cont racts will be concluded in line with the EU 
public procurement rules. Since this appro ach has been followed for all suboptions, the 
economic impact is similar for all of them.  
For each of the sub-options described in section 5, the anticipated impact has been assessed 
against these criteria on a nine-point scale, using the following symbols: 
 
- - Negative impact/cost 
                                                 
66  See Annex 1.6. 
 
EN 29   EN - Slightly negative impact/cost  
0 Baseline or equivalent to baseline 
+ Slightly positive impact/savings 
++ Positive impact/savings 
The cost estimates provided herein have been developed on the basis of data provided by 
Member States, EU agencies and the private sector  and verified by the ex ternal contractor for 
the technical study assessing the financial impact of EUROSU R (GHK). They constitute a 
best estimate of costs of implementing the polic y options under consideration on the basis of 
their description in the 2008 EUROSUR roadmap and subse quent technical documents. 
Adjustments to the scope, organisational and governance structures, technical requirements, 
nature of the provision of services and phasi ng of implementation of the EUROSUR roadmap 
would be expected to lead to changes in  the costs of providi ng those services. 
6.2. Sub-options 1.1 to 1.3 for nati onal coordination centres 
Comparative assessment of  Policy Options 1.1 to 1.3 
The NCCs and Frontex have the 
following functions:  Effectiveness Consistency  Costs  Fundamental 
rights  
Baseline scenario: Different 
functions in each Member State  
1.1. Coordination of land and 
maritime border surveillance  
1.2. Command & control for land 
maritime border surveillance  
1.3. Command & control for 
border control67 0 
+ 
++ 
++ 0 
++ 
-.- 
-.- 0 
++ 
-  
- -  0 
+ 
+ 
+ 
6.2.1. Effectiveness 
In comparison to the baseline scenario, all thre e sub-options have a positive impact because 
they clearly contribute to achieving the general objectives of reducing irregular migration, the 
loss of migrants at sea and cross-border crime. However, there are differences with regard to 
improving the situational awareness  and the reaction capability : 
Taking into account the multitude of nationa l authorities involved in maritime border 
surveillance, limiting the role of the NCC to coordination  functions - as envisaged in 
Option 1.1  - would be more easily accepted by compe ting authorities and would improve their 
willingness to participate in or cooperate with such a centre, in particular when it comes to 
civil-military cooperation. Therefore Option 1 .1 would the preferred option for promoting 
interagency cooperation and cr oss-sectoral information ex change, thereby increasing 
considerably the overall situational awareness .  
On the other hand, Option 1.2  would have clear advantages ov er Option 1.1 when it comes to 
the reaction capability : Giving all NCCs command & control  functions would allow for a 
more rapid, efficient and cost-e ffective response to an identifi ed threat than  giving the NCC 
only a coordination role.  
                                                 
67  Land, maritime and air border surveillance as  well as checks at border crossing points. 
 
EN 30   EN For example, putting the NCC on top of a centralized command structure, combined with a 
decentralized execution, would ensure that all available national personnel and resources 
would be used in the most efficient manner to r eact in a crisis situation. Finally, a NCC with 
such functions would be in a better position for evaluating the effects of the measures taken. 
However, during the discussions in 2008-2011 seve ral Member States have clearly expressed 
their concern that in case the NCC would have command & control  functions, not all 
authorities in border surveillance (e.g. navies) would agree to cooperate, which the result that 
the objectives of EUROSUR would be undermined. 
Including air border surveillance  and border checks  as proposed in Option 1.3  would have in 
principle the advantage of giving the NCC a better situational awareness  for all aspects of 
border control. However, air border surveillance is usually a military competence. Furthermore, a some Member States rejected this option during the di scussions in 2008-2011, 
because in their national administrations the co mpetencies for border surveillance (e.g. navy, 
coast guard) and border checks (e .g. police) are strictly  divided, making it di fficult to improve 
interagency cooperation and cross-sectoral information exchange when the NCC has 
command & control functions.
68 
6.2.2. Consistency 
Option 1.1  is fully consistent with the overall EUROSUR approach, which aims at 
establishing an information exchange and coope ration mechanism for all authorities involved 
in border surveillance. Giving the NCCs co mmand & control functions  as envisaged in 
Options 1.2 and 1.3  could not only undermine this aim,  but could also be regarded as 
interfering into the competenci es of other policy fields.  
This is also one of the main reasons why during the discussions in  the EUROSUR Member 
States' expert group in 2008-2010 several Member St ates fiercely rejected the option of giving 
NCCs command and control  competences.  
However, Option 1.1 should be seen as a mi nimum requirement, which would not prevent 
Member States from giving their command and control  competencies as it was already done 
or is planned in a majority of Member States. 
6.2.3. Costs 
With regard to the baseline scenario, Member States estimated that the costs for setting up, 
upgrading and maintaining their N CCs amount to M€ 309 in 2011-2020.69 However, these 
figures do not provide a firm basis for proper co st estimates, because Member States have 
given or are planning to give different responsibilities and comp etences to their NCCs, which 
are in different stages of implementation. Taking into account that  they have provided 
complete and well-justified cost estimates, for Option 1.1  the NCCs of France and Belgium, 
for Option 1.2  the NCCs of Cyprus and Slovakia and for Option 1.3  the NCC of Finland have 
been selected as a basis for calculating the ove rall cost estimates. The cost estimates for the 
Frontex situation centre (FSC) have been provided by Frontex.70 
                                                 
68  A fourth option – giving the NCC a coordination function for border control, including border checks – 
has not been assessed, because in all Member Stat es border guards/police, which always have a 
centralised command structure, ar e responsible for border checks.  
69  For the NCC cost estimates provided by Member States in August 2011 in the framework of the 
technical study assessing the financial impact of establishing EUROSUR, see Annex 4.6. The 2017-
2020 figures have been based upon the 2016 figures as provided by Member States. 
70 For the calculation of the NCC cost estimates see An nex 4.7. For the FSC cost estimates see Annex 4.8. 
 
EN 31   EN Cost comparison between policy options 1.1 to 1.3 (2011-2020) 
 Policy Option 1.1 
Decentralised 0ption Policy Option 1.2 
Partly centralised 
option Policy Option 1.3 
Centralised option 
NCC costs71 M€ 99,7 M€ 271,6 M€ 610,4 
FSC costs M€ 95,5 M€ 129,8 M€ 136,9 
Total costs M€ 195,2 M€ 401,4 M€ 747,3 
The financial costs  needed in 2011-2020 for setting up, upgrading and maintaining such 
centres in the 24 Member States and associated countries located and land and maritime Schengen external borders and for the FSC are estimated to amount to M€ 195,2 for option 1.1, M€ 401,4 for option 1.2 and M€ 747,3 for option 1.3. 
6.2.4. Fundamental rights 
The information exchange and cooperation mechanism as envisaged under EUROSUR does 
not involve the handling of personal data . However, several NCCs intend to handle personal 
data, in particular when the NCC is also ma de reponsible for border checks as proposed under 
Option 1.3
. But also NCCs set up in line with Options 1.1 and 1.2  might - in the context of 
border surveillance - handle personal data at na tional level, for instance when collecting data 
on people related to a suspicious vessel bein g tracked (ownership, operators, passengers, 
crew, agents, etc.).  
However, under all three sub-options it might be  difficult to guarantee that the any handling 
of personal data is fully exclud ed, in particular when inform ation is being sent from the 
national to the European level. To ensure that  the principles of personal data protection law 
applicable in the European Union are being observed72, safeguards should be introduced to 
guarantee that persona l data is processed fair ly and lawfully, collected for specified, explicit 
and legitimate purposes and not further processed in a way inco mpatible with those purposes. 
It also has to ensured that the processing of  personal data is adequate, relevant and not 
excessive in relation to purposes for which they  are collected and processed. For Frontex the 
given legal limitations apply.73  
6.3. Sub-options 2.1 to 2.3 for the EUROSUR network 
Comparative assessment of  Policy Options 2.1 to 2.3 
The EUROSUR network is being 
used by the NCCs and the FSC for:  Effectiveness Consistency  Costs  Fundamental 
rights  
Baseline scenario  
2.1. Decentralised and unclassified 
information exchange  
2.2. Decentralised and classified 
information exchange  
2.3. Centralised and classified 
information exchange  0 
+ 
++ 
++ 0 
+ 
++ 
- - 0 
- 
- - 
- -  0 
0 
+ 
++ 
                                                 
71  For all 24 Schengen countries with land and maritime external borders. 
72 Cf. Directive 95/46/EC (OJ L 281, 23.11.1995, p. 31); Regulation (EC) No 45/2001 (OJ L 8, 12.1.2001, 
p. 1); Council of Europe Convention of 28.1.1981 (ETS 108).  
73  For Frontex the given legal limitations apply. See Ar ticles 11a ff of Regulation (EU) No …/2011 of … 
amending Council Regulation No 2007/2004 establishing Frontex, OJ …  
 
EN 32   EN 6.3.1. Effectiveness 
In comparison to the baseline scenario, under wh ich a network is curre ntly being set up on a 
pilot basis between Frontex and six Member States, all three options would improve the 
effectiveness of this pilot network by further developing it. When comparing Option 2.1 with 
Option 2.2, the following can be concluded: 
The limitation to unclassified information exchange in Option 2.1  would largely exclude the 
information exchange on cross-border crime, which is usually regarded as sensitive 
information. This means that  the general objective of preventing cross-border crime  would 
not be met under Option 2.1, which can therefore be discarded. 
The encryption of the data flow under Option 2.2  would allow the Member States to share 
more sensitive information including, once the system is accredited, EU Restricted data, thereby improving the situational awareness  at the external borders. The possibility for a 
classified information exchange is also a pre-condition for exchanging intelligence on 
developments and events occurring in the pr e-frontier area, as e nvisaged under the Common 
Pre-Frontier Intelligence Pictur e (CPIP). Adding the CPIP serv ices and products enables the 
sharing of information and intelligence on threat s emerging in the pre-frontier area, thereby 
giving the border control aut horities additional time for c oordinating necessary counter-
measures, which would considerably improve their reaction capability . 
However, Option 2.2 is more demanding and tim e consuming to manage than Option 2.1, 
requiring Frontex to set up and maintain a numb er of services in cl ose-to-real time. The 
benefits of Option 2.3
 over Option 2.2 are mainly linked to its effectiveness: A centralised 
system allows a better control of the data flow between Member States. It is also easier to query one centralised database than to broad cast a query to all NCCs, thereby enabling the 
exchange and fusion of data, information and intelligence in close-to-real time. 
6.3.2. Consistency 
The disadvantages of Option 2.3 in comparison to Option 2.2. are the lack of consistency: 
The overall system architecture of  EUROSUR follows a decentralised federation of systems 
approach. The decentralised approach in Option 2.2
 promotes the cooperation between 
Member States at operational and regional level, wh ile avoiding an information overload in 
Frontex, thereby possi bly slowing down the reaction capability . Even with considerably 
increased human and financial resources, Frontex might not be able to deliver such the 
centralised network solution envisaged under Option 2.3  (and also under Option 3.3), thereby 
putting at risk achieving the general objectives. Several Member States have difficulties to 
accept to store their information centrally  on a system that they do not manage.74  
6.3.3. Costs 
The financial costs  in 2011-2020 for setting up and main taining the EUROSUR network in 
line with the decentralised Option 2.1  are estimated to amount to M€ 42. These costs would 
increase to M€ 46 for the partly centralised Option 2.2  and to M€ 49 for the centralised 
Option 2.3 .75  
Cost comparison between policy options 2.1 to 2.3 (2011-2020) 
 Policy Option 2.1 Policy Option 2.2 Policy Option 2.3 
                                                 
74  Instead of a centralised repository the central part could be limited to a central repository of indexes. 
Such a system would require a lower volume of data  transfer and lower central database capability and 
it could still be regarded as a decentralised system.  
75  For detailed cost estimates see Annexes 5.1 to 5.3. 
 
EN 33   EN Decentralised option Partly centralised 
option Centralised option 
Network costs M€ 42,4 M€ 46,74 M€ 49,32 
CPIP costs 
(Frontex 
RAU76) €0 M€29, 29 M€ 29,29 
Total costs M€ 42,4 M€ 76,03 M€ 78,61 
These estimates include the costs for sett ing up, upgrading and maintaining the EUROSUR 
network and extending it from 6 to 18 NCCs in 2012 and to another 6 NCCs in 2014. 
Furthermore, the estimate takes al so into account the costs for an  extension from 1 EU agency 
(Frontex) to 4 other EU agencies77 in 2012 and additional 2 European agencies78 in 2014.  
The network cost estimates between the thr ee options differ only slightly, which makes 
Options 2.2 and 2.3 more interesting, since they  provide considerable  added value with 
relatively little additional costs. 
The Common Pre-Frontier Intelligence Picture  (CPIP) will consist of  an event, operational 
and analytical layer managed by Frontex :79 The costs for the FSC in providing the event and 
operational layers of the CPIP are already included in the cost estimates for the FSC under 
Policy Options 1.1 to 1.3. Therefore only the estimat ed costs of the analytical layer of the 
CPIP, which will be provided by Risk Analysis Unit (RAU) of Frontex, are shown under Options 2.2 and 2.3, amounting to M€ 29.
80 
6.3.4. Fundamental rights 
The handling of personal data under Option 2.1  is excluded, because the network is 
unclassified. The accreditation process of a pr otected network as envisaged under Options 2.2  
and 2.3  ensures that rules and procedures would be in place not only for the handling of 
security sensitive data, but sensitive data in ge neral, such as the handling of personal data.  
In the context of EUROSUR the focus is on exchanging operational information, whereas the 
exchange of personal data is not envisa ged. In case the EUROSUR network would 
exceptionally be used for exchanging personal da ta on the basis of existing legislation, the 
limitations and safeguards for the handling of personal data mentioned in Section 6.2.4 would 
fully apply. From a data protec tion standpoint, centralis ing the data as envisaged under Option 
2.3 has advantages because it means that there is no need to duplicate it on multiple national 
systems. 
6.4. Sub-options 3.1 to 3.3 for cooperation with third countries 
Comparative assessment of  Policy Options 3.1 to 3.3 
                                                 
76  Risk Analysis Unit. 
77  EU Satellite Centre, European Maritime Safety Agency, European Fisheries Control Agency, 
EUROPOL.  
78  Centre de Coordination pour la lutte antidrogue en Méditerranée (CeCLAD-M) and the Maritime 
Analysis and Operations Ce ntre – Narcotics (MAOC-N). 
79  For CPIP concepts see Annex 1.7. 
80  For detailed cost estimates on the CPIP see Annex 5.4.  
 
EN 34   EN Information between the 
EUROSUR network and third 
countries is exchanged via:  Effectiveness Consistency  Costs  Fundamental 
rights  
Baseline scenario: 3 regional 
networks outside EU framework  
3.1. NCCs as 'hub' to the regional 
networks  
3.2. Like 3.1, plus a new regional 
network for the Mediterranean  
3.3. Frontex only, replacing the 
regional networks  0 
+ 
++ 
++ 0 
++ 
++ 
- -  0 
0 
- 
- - 0 
0 
0 
0 
6.4.1. Effectiveness 
In comparison to the baseline scenario, Option 3.1  would lead to a considerable improvement 
of the situational awareness in the Baltic Sea,  the Black Sea and in the Atlantic Ocean around 
the Canary Islands, because the three existi ng regional networks SEAHORSE, CoastNet and 
BSCF, which have been established outside the EUROSUR framework, would be interlinked 
with the EUROSUR network in an  indirect manner, with the N CCs serving as a 'hub' for the 
information exchange. 
Option 3.1 is also the easiest on e to establish in the short-te rm, since it builds on these three 
existing networks and does not reconsider these cooperation mechanisms established by 
Member States with third count ries since 2005-2006. Especially it would also respect the fact 
that different solutions have been found with regard to the question which centre in these regional networks should be res ponsible for ensuring the inform ation exchange with one or 
several third countries: For SEAHORSE and the BSCF, regiona l coordination centres have 
been established for this purpose, which w ould be linked under Option 3.1 to the NCC in 
which they are located. In the CoastNet netw ork, no such centre exists , but information is 
being exchanged in a decentral ised manner between the NCCs. 
However, Option 3.1 would enta il a less coherent appro ach in the cooperation with 
neighbouring third countries in the Mediterranean region, wh ich would undermine the three 
general objectives of EUROSUR in this region.  
Option 3.2
 is the preferred option with regard to effectiveness, because it delivers the 
capability required for EUROSUR to exchange surveillance information and cooperate with 
third countries also in the Mediterranean region while being the most cost-efficient. Under the 
leadership of Spain, Italy, Malta, Portugal an d Cyprus are currentl y preparing a project 
proposal for a 'SEAHORSE Mediterraneo' networ k, which would enable the northern African 
countries and Member States to exchange info rmation on irregular migr ation and cross-border 
crime in the Mediterranean region. Option 3.2 is  more challenging than  Option 3.1, because it 
requires the agreement of the northern African countries to join the 'SEAHORSE Mediterraneo network'.  
Option 3.3
 would offer more potential than the other two options in terms of information 
management, allowing for a centralised and possibly classified information exchange. 
However, Option 3.3 would be even more difficult to achieve than Option 3.2, because Frontex would have to re-negotia te also all the agreements co ncluded between Member States 
 
EN 35   EN and ten third countries under the netw orks CoastNet, BSCF and SEAHORSE.81 
Consequently, it would achieve the general objec tives of EUROSUR only in the long-term.  
6.4.2. Consistency 
Options 3.1 and 3.2  build largely on existing capabiliti es, allowing Member States and third 
countries to take into account regional  priorities and specificities. Option 3.3  is not in line 
with the EUROSUR approach of making best us e of existing infrastructures and systems. 
Furthermore, making Frontex the 'hub' for the information exchange between Member States 
and third countries – as envisaged under Optio n 3.3 - has been rejected by Member States 
when discussing this issue in the relevant working groups in 2010-2011. 
6.4.3. Costs 
Cost comparison between policy options 3.1 to 3.3 (2011-2020) 
 Policy Option 3.1 
Decentralised option Policy Option 3.2 
Regional option Policy Option 3.3 
Centralised option 
Total costs M€ 0,0 M€ 5,37 M€ 25,29 
There is no cost related to Option 3.1 , because from a financial point of view it does not 
constitute a change from the baseline, since a connection from all th ree regional networks 
with their respective NCCs was established before the end of 2011. Concerning Option 3.2 , 
the costs for establishing and maintaini ng the SEAHORSE Medite rraneo in 2011-2020 
between three third countries and Member Stat es in the region are estimated at M€ 5,37.82 
With regard to Option 3.3 , the costs for replacing the th ree regional networks by the 
EUROSUR network are around M€ 25,29, taking into  account the cost estimates elaborated 
for Policy Option 2.2 and assuming that about 15 th ird countries would be connected directly 
to the EUROSUR network. The decommissioning co sts for the existing networks have been 
estimated to 10% of the annual average baseline costs of the three networks83. 
6.4.4. Fundamental rights 
Under Option 3.1  Member States' authorities are exchanging in the regional networks 
SEAHORSE, CoastNet and BSFC operational information, but no personal data with 
neighbouring third countries.  
The same would apply to Options 3.2 and 3.3 . Cooperating with third c ountries on in order to 
prevent irregular migrants from entering the Schengen area undetected could have a 
significant negative impact on f undamental rights in case the third country au thorities use 
such information to identify pers ons or groups of pers ons which are likely to be subject to 
torture, inhuman and degrading treatment or a ny other violations of fundamental rights.  
The legislative proposal on EUROSUR must ther efore provide the appr opriate safeguards in 
order to prevent such a situation.  
6.5. Sub-options 4.1 to 4.3 for the common application of surveillance tools 
Comparative assessment of  Policy Options 4.1 to 4.3 
                                                 
81  Russia, Ukraine, Georgia, Turk ey, Morocco, Mauretania, Senegal, Cape Verde, Gambia and Guinea 
Bissau. For details see Annex 6.1. 
82  The concerned countries are not named, because negotiations are still going on. 
83  This assumption is in line with the standard assumption for calculation decommissioning costs in the IT 
industry, 
 
EN 36   EN The service for the common 
application of surveillance tools at 
EU level is provided by:  Effectiveness Consistency  Costs  Fundamental 
rights  
Baseline scenario  
4.1. External service providers to 
each concerned NCC directly  
4.2. Frontex together with EMSA 
and EUSC  
4.3. Frontex alone  0 
+ 
++ 
++ 0 
- - 
++ 
- 0 
- -- 
- 
- 0 
- 
+ 
+ 
6.5.1. Effectiveness 
As described in the baseline scenario, due to  the high costs and the lack of ready-made 
solutions only a few Member States currently use satellites for border surveillance purposes, 
utilizing private sector providers and national sp ace agencies. Due to a di versified approach of 
Member States the overall coverage and therefor e detection and response to relevant threats 
would be less effective.  
Option 4.1  would envisage that Member  States use existing capabi lities established by the EU 
Satellite Centre (EUSC) and the European Mar itime Safety Agency (EMSA). The benefits of 
cooperating with the EUSC and EMSA would be  as follows: The EUSC could help in 
particular with regard to the detection and identification of sm all boats leaving third-country 
coasts, which requires very high resolution imag ery. The availability of such imagery is 
restricted, because it is often collected for national defence purposes. Therefore it is not 
always available and if so, under strict license conditions. The added value of EMSA is that it 
manages ship reporting systems, such as SafeS eaNet, containing AIS data that can be to a 
large extent commercially purchased, but (unlike in SafeSeaNet) does not have quality control. LRIT data is owned by Flag States (governments) and is  not commercially available. 
This means that the remote maritime traffic pi cture cannot be composed in a similar way by 
commercial companies since access to data is limited. 
However, under Option 4.1 there would be still a c onsiderable risk of duplication of efforts, 
both between the two agencies which have developed operational services for the use of satellite imagery as well as between Member States, because they would task EMSA and the 
EUSC in parallel and without coordination among them. 
Option 4.2
 would be even more efficient than Op tion 4.1, because Frontex would coordinate 
the requests coming from the national coordination centres as well as the services to be provided from the EUSC and EMSA, while combin ing it with other surveillance activities, 
such as Frontex joint operations and the use of Frontex owned technical equipment. Such a coordinated approach could in particular improve the capability  to detect and track small 
vessels used for irregular migra tion and cross-border crime.  
Member States have shown a clear preference for Option 4.2, which the result, that a Concept 
of Operations for the common application of surveillance tools has b een elaborated in 2011,
84 
which shall be tested between Fr ontex, EMSA and the EUSC in 2012. 
                                                 
84  See Annex 1.6. 
 
EN 37   EN In Option 4.3  Frontex would not take advantage of existing capabilities set up by the EUSC 
and EMSA, but establish the service for the co mmon application of su rveillance tools on its 
own. Since it is likely to take considerab le time for Frontex to accumulate the same 
knowledge and expertise as the EUSC and EMSA, it would be difficult to implement 
Option 4.3 and to achieve full operational e ffectiveness in the short to mid-term. 
6.5.2. Consistency 
The biggest advantage of Options 4.1 and 4.2 w ould be that it takes into account that 
substantial investments in space infrastr ucture and know-how already undertaken by 
GMES/ESA, EMSA and the EUSC. Option 4.2 woul d be more consistent with the objective 
of promoting interagency cooperation than  Options 4.1 and 4.3, envisaging a European 
capability for the common application of surveillance tools  which could not only be used for 
border surveillance, but also for other purposes, such as law enforcement and defence and thereby representing an important component in  establishing the common information sharing 
environment for the EU maritime domain
85. Due to its multi-purpose and cross-sectoral 
approach, EU funding provided by the GMES program me for such a servi ce can be justified.  
6.5.3. Costs 
Cost comparison between policy options 4.1 to 4.3 (2011-2020) 
 Policy Option 4.1 
Decentralised option Policy Option 4.2 
Partly centralised 
option Policy Option 4.3 
Centralised option 
Total  M€ 80,5 M€ 62,1 M€ 62,3 
The total costs in 2012-2020 for Option 4.1 are es timated at M€ 80, with almost similar 
amounts for Option 4.2 (M€ 62,1) and Option 4.3 (M€ 62,3). 86  
The costs of Option 4.1  are not only higher, but  this option is not cost-efficient, since the 
processing of data would be undertaken at na tional level, which implies a multiplication of 
staff, activities and associated fixed costs (i .e. buildings, offices and equipment), with the 
result that the different NCCs  would replicate what could be done better at EU level. 
Option 4.2  would build not only on the existing experience, know -how and capabilities of 
EMSA, EUSC and GMES, but existing contracts w ith service providers a nd data distributors 
could be used, involving cost re ductions. In the long-term, Option 4.3  provides potential in 
benefiting from significant economies of scale because of having a single centralised actor 
(Frontex), which also explains why the cost estimates are almost identical with Option 4.2, 
which largely builds on existing capabilities. 
6.5.4. Fundamental rights 
Option 4.1 would also have the disadvantage that legal frameworks may not be established to 
enable commercial operators to monitor activitie s in third countries and store information in 
line with data protection laws. 
                                                 
85  Step 8 of the 2008 EUROSUR roadmap. Compare Commission Communications COM(2009) 538 final 
of 15.10.2009 and COM(2010) 584 final of 20.10.2010. 
86  For detailed cost estimates see Annexes 7.1 to 7.3.  
 
EN 38   EN 7. COMPARISON OF OPTIONS AND IDENTIFICATION OF PREFERRED POLICY OPTION  
In line with the assessment in section 6, the following options would be the preferred ones: 
With regard to the establishment of NCCs, Option 1.1  is the preferred option, because it does 
not require Member States to restructure thei r national administrations and thus could be 
easily implemented. However, Option 1.1, giving the NCCs coordination functions for land 
and maritime border surveillance, should be re garded only as a minimum requirement, not 
preventing Member States from giving their NCCs additional competencies as discussed 
under Options 1.2 and 1.3. 
Following the decentralised approach for set ting up EUROSUR, the preferred policy option 
for the EUROSUR network is Option 2.2 . Frontex is already setting up the EUROSUR 
network on a pilot basis with se lected Member States, focusing currently on the exchange of 
unclassified information. The security accreditati on for exchanging information at the level of 
EU Restricted is a long proces s, which might lead to delays . This choice al so takes into 
account the relatively small difference in networ k costs and the need for exchanging sensitive 
information when setting up the Common Pre-Frontier Intelligence Picture.  
Taking into account the urgent need for enhancing the situat ional awareness and reaction 
capability for border control in the Mediterranean region, Option 3.2  provides the best answer 
on how to promote the cooperation with ne ighbouring third countries. However, the 
willingness of northern African countries to  cooperate is a pre-condition for the 
implementation of Option 3.2. 
For the common application of surveillance tools, Option 4.2  is the option providing most 
added value. The testing and validation of the cooperation between Frontex, EMSA and the 
EUSC is planned for 2012 as well as foreseen in a number of FP7 projects starting in 2013. It 
is envisaged for this service to be funded by the GMES programme as of 2014. 
The options selected above have also been the ones preferred by Member States when 
developing the different steps and compone nts of EUROSUR in 2008-2011. Taking into 
account that EUROSUR is supposed to be set up in a decentralised manner, EU legislation 
would guarantee that each of the steps and co mponents would be implemented in the same 
way. Furthermore, it would ensure that the diffe rent steps would complement each other in a 
coherent manner, thereby increa sing their overall efficiency.  
With regard to Options 1.1 and 2.2, the EU legisl ation should focus in particular on the tasks 
and functions of national coordination centres , Frontex and the EUROSUR network as well as 
on common rules for the exchange of inform ation between the NCCs and Frontex. When 
being consulted in 2008-2011, Member States clear ly expressed the need for EU legislation 
on EUROSUR, because the Updated EU Schengen Catalogue on External borders control, 
Return and readmission  includes only recommendations a nd best practices on border 
surveillance, but no binding rules.87  
With regard to Options 3.2, the legal basi s for the establishment of the SEAHORSE 
Mediterraneo network would be an agreemen t between the countries. Concerning Option 4.2, 
Frontex, EMSA and EUSC would regulate the cooperation with regard to the common 
application of surveillance tools  in a service-level agreement. 
                                                 
87 References to and excerpts of these legal acts can be found in Annex 1.1. 
 
EN 39   EN  
Costs, responsibility and source of funding for the preferred option  
PO x.1 PO x.2 PO x.3 Preferred option  
Step   
Component Decentralised 
approach Partly 
centralised 
approach Centralised 
approach To be 
set up 
by Funding 
via 
1 NCCs M€ 99,6 M€ 271,6 M€ 610 Member 
States EBF 
1 FSC M€ 95,6 M€ 129,8 M€ 137 Frontex Frontex 
2, 7 Network M€ 42,4 M€ 46,7 M€ 49,3 Frontex Frontex 
6 CPIP (RAU) € 0,0 M€ 29,3 M€ 29,2 Frontex Frontex 
3 3rd countries € 0,0 M€ 5,4 M€ 25,3 Member 
States DCI, 
EBF 
5 Common 
application of 
surveillance tools M€ 80,5 M€ 62,1 M€ 62,3 Frontex 
EUSC 
EMSA Frontex 
and FP7/ 
GMES 
Total M€ 318,1 M€ 544,9 M€ 913 
Preferred Option M€ 338,7   
Combining the preferred options, the co sts of EUROSUR would amount to M€ 338,7. 
EUROSUR will not require additio nal EU funding. Member States would continue using the 
EBF in this regard. Furthermore, considerable  FP7 funding is being used for developing and 
testing selected EUROSUR components. 
In line with the principle of subsidiarity, EU ROSUR would be a decentralised system, leaving 
Member States fully in charge of controll ing the external border s and cooperating with 
neighbouring third countires, while selected components, such as the EUROSUR network, 
would be provided centrally by Frontex, ther eby generating added value for all EUROSUR 
stakeholders.  
Most Member States already have the minimum in frastructure in place and therefore it is not 
envisaged that they would encounter difficulti es in upgrading and connecting their national 
infrastructures. The difficulties which some  Member States may meet are more of a 
organisational than technical na ture, e.g. when determining wh ich national authority should 
be responsible for the national coordination centre.  
The role of Frontex in EUROSUR would grow  steadily when administering the EUROSUR 
network as well as providing the common applic ation of surveillance tools. Frontex would 
fulfil these tasks in li ne with its mandate as amended in  2011, which allows the Agency to 
purchase and own its own technical assets, to process under certain conditions personal data 
obtained during operations and to provide te chnical assistance to third countries. 
 
EN 40   EN 8. MONITORING AND EVALUATION  
Frontex shall ensure that methods are in place to monitor the functioning of EUROSUR 
against the main policy objectiv es. Two years after EUROSUR is  fully operational and every 
year thereafter, Frontex shall submit to the Comission a report on the technical and operational functioning of EUROSUR, taki ng into account the following indicators: 
Impact indicators
88 
1. Reduced number of irregular migran ts entering the Schengen undetected; 
2. Reduced death toll of migrants at sea; 
3. Reduced cross-border crime, in particular of  drugs smuggled across the external borders. 
Result and output indicators  
1. Increased situational awareness at the extern al borders and in the pre-frontier area; 
2. Improved interagency cooperation at national level; 
3. Improved cooperation between Member States as well as with Frontex; 
4. Increased cooperation with neighbouring third countries. 
5. Increased technical and operational capabi lity to detect and track small boats; 
6. Increased exchange of unclass ified and classified information in close-to-real time; 
7. Increased capability to react to  alerts, incidents and other events at the external borders. 
Moreover three years after the EUROSUR system  would have started all its operations and 
every four years thereafter, the Commissi on shall produce an overall evaluation of 
EUROSUR, including examining results agai nst objectives and assessing the continuing 
validity of the underlying rationale. The fist eval uation is expected to take place in 2016 under 
the condition of EUROSUR becoming opera tional as of 2013. The Commission should 
submit the reports on the evaluation to th e European Parliament and the Council, 
accompanied, where necessary, by appropriate proposals to amend the Regulation establishing EUROSUR.  
                                                
 
88  These indicators will also dependent on factors outs ide of EUROSUR, such as changes in the political 
and economic situation in neighbouring third countries.