EUROPEAN COMMISSION Brussels, 27.4.2022 SWD(2022) 658 final COMMISSION STAFF WORKING DOCUMENT



IMPACT ASSESSMENT REPORT

Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 767/2008, (EC) No 810/2009, and (EU) No 2017/2226 of the European Parliament and of the Council, Council Regulations (EC) No 1683/95, (EC) No 333/2002, (EC) No 693/2003 and (EC) No 694/2003 and Convention implementing the Schengen Agreement, as regards the digitalisation of the visa procedure {COM(2022) 658 final} - {SEC(2022) 202 final} - {SWD(2022) 659 final}



Table of contents 1.Introduction: Political and legal context 1.1.General Background 1.2.Scope of the initiative 2.Problem definition 2.1.What are the problems? 2.2.What are the problem drivers? 2.3.How will the problem evolve? 3.Why should the EU act? 3.1.Legal basis 3.2.Subsidiarity: Necessity of EU action 3.3.Subsidiarity: Added value of EU action 4.Objectives: What is to be achieved? 4.1.General objective 5.What are the available policy options? 5.1.What is the baseline from which options are assessed? 5.2.Description of the policy options 5.3.Options discarded at an early stage

6.What are the impacts of the policy options? 6.1.Economic impact 6.2.Social impact 6.3.Environmental impact 6.4.Impact on EU tourism and GDP 7.How do the options compare? 7.1.Effectiveness 7.2.Efficiency 7.3.Other impacts 8.Preferred option 8.1.Why O4 is preferred policy option 8.2.Sub-options 8.3.Application of the one-in-one-out approach 8.4.Sensitivity analysis on the preferred option 8.5.REFIT (simplification and improved efficiency) 9.How will actual impacts be monitored and evaluated? Annex 1 – Procedural information Annex 2 – Targeted and public consultation 1. Stakeholder consultation 2. Analysis of the consultation with the Member States

3. Questionnaires: Consultation with Member States and Public Consultation Annex 3 – Who is affected and how? Annex 4 – Methodological note on costs and benefits Annex 5 – Global trends on visa process digitalisation Annex 6 – Sensitivity analysis on the preferred option 1.Decrease in number of visa applications 2.Increase in number of visa applications 3.Delay in the roll-out of the application platform 4.Change in time needed to intake a visa application 5.Gradual realisation of administrative benefits over the 2025-2029 period Annex 7 – Comparison of the policy options Option 2: Minimal EU legislative changes on the application & digital visa Option 3: Optional EU digital application platform & digital visa Option 4: Mandatory EU digital application platform & digital visa Option 5: Online biometric enrolment & digital visa



Glossary Term or acronym Meaning or definition BCP Border control post CBA Cost-benefit analysis EBCGA European Border and Coast Guard Authority EDPS European Data Protection Supervisor EES Entry-Exit System ESP External Service Provider ETIAS European Travel Information and Authorisation System EU European Union eu-LISA European Union Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice FRA Fundamental Rights Agency GDPR General Data Protection Regulation IT Information Technology Member States EU Member States applying the common visa policy in full (all EU Member States with the exception of Bulgaria, Croatia, Cyprus, Ireland and Romania) as well as the Schengen associated countries: Iceland, Liechtenstein, Norway and Switzerland. As in the Visa Code, “Member States” in this report will designate Member States MEV Multiple-entry visa (short-stay visa allowing for an unlimited number of entries to the Schengen area during its period of validity and respecting the overall maximum period of stay, i.e. 90 days in any 180-day period) N/A Not available Privacy enhancing Privacy-enhancing computation refers to a group of various technologies that help to achieve the highest level of private data protection. Schengen evaluation periodical evaluations of Member States on the application of the Schengen acquis in the field of the common visa policy, in accordance with Council Regulation (EU) No 1053/2013 Service fee Fee paid to the ESP for collecting the application and biometric identifiers SIS Schengen Information System TCN Third Country National (i.e. citizen of a country outside the Schengen area) TFEU Treaty on the Functioning of the European Union VAC Visa Application Centre (i.e. the facility operated by external service providers) VIS Visa Information System VIS Regulation Regulation (EC) No 767/2008 of the European Parliament and the Council of 9 July 2008 concerning the Visa Information System (VIS) and the exchange of data between Member States on short-stay visas (VIS Regulation) Visa Code Regulation (EC) No 810/2009 of the European Parliament and the Council of 13 July 2009 establishing a Community Code on Visas (Visa Code) and Regulation (EU) 2019/1155 of the European Parliament and of the Council of 20 June 2019 amending Regulation (EC) No 810/2009 establishing a Community Code on Visas (Visa Code) Visa fee fee paid to the consulate for processing the visa application Visa short-stay visa as defined in Article 2 (2)(a) of the Visa Code (authorising its holder to stay in the Schengen area for up to 90 days within any 180-day period)





1.Introduction: Political and legal context 1.1.General Background The March 2018 Commission communication on visa policy took on board the idea of “e-visas” following earlier discussions in 2017 under the Estonian Presidency. The communication announced a feasibility study on digital visa procedures and the intention to assess options and promote pilot projects which would prepare the ground for future proposals. When revising the EU Visa Code in 2019, the EU co-legislators explicitly stated the aim of developing a common solution in the future to allow Schengen visa applications to be lodged online, thereby making full use of the recent legal and technological developments. The COVID-19 pandemic, which led to the slowing down of Schengen visa operations worldwide partly due to the difficulty of receiving visa applicants in consulates, prompted Member States to call upon the Commission to speed up work on digitalisation of visa procedures. The New Pact on Migration and Asylum proposed by the Commission on 23 September 2020 set the objective of making the visa procedure fully digitalised by 2025, with a digital visa and the ability to submit visa applications online. Given the various advantages offered by digitalisation of visa procedures (increased security, reduced administrative costs, growing trend toward digitalisation), large visas-issuing countries, such as Australia, New Zealand, UK, India or Russia, have already implemented digital visas for short stays on their territories as shown in Annex 5. The majority of these digital services are however more similar to the European Travel Information and Authorisation System (ETIAS). They have been introduced to either pre-screen visa exempt travellers prior to travel (Electronic Travel Authorisations) or to facilitate certain foreign nationals subject to visa requirements, in quickly and easily obtaining a short stay visa for specific purposes. Only Australia and New Zealand have fully digitalised the visa procedures for all applicants, irrespective of nationality or travel purpose. The initiative on visa digitalisation is included in the Commission Work Programme for 2021 (Annex I). The initiative also fits with the general EU approach to encourage the modernisation and digitalisation of public services and the Commission communication on the 2030 Digital compass: the European way for the digital decade. In this context, a decision was taken by the Commission to consider the proposal for the digitalisation of visa procedures as a new initiative and not as a revision of the Visa Code and of the VIS regulation. The initiative aims at modernising and simplifying the implementation of visa policy and is part of a broader effort to digitalise public administrations. The study on the digitalisation of visas procedures carried out in 2019 by the Commission highlighted the potential benefits of simplified and more modern visa procedures. To do so, the initiative will only modify certain articles of the Visa Code and the VIS regulation as far as it is necessary to implement this initiative and will not touch other aspects of the Visa code and the VIS regulation not concerned by this initiative. The digitalisation of the visa application procedure and the implementation of a digital visa would benefit from several major developments in the field of visa and border policy: §The revision of the Visa Code in 2020 made it easier for regular travellers to apply for multiple-entry visas, and allowed electronic visa applications (used by a few Member States) and electronic signature (not used by Member States so far). §The revised VIS Regulation agreed by the co-legislators in December 2020. §The European Travel Information and Authorisation System (ETIAS) is part of the Smart Border and Interoperability framework and introduces an online travel authorisation for third country nationals who are not visa-required. This travel authorisation differs from the visa procedure which requires submission of the biometrics and physical presence of applicants to mitigate the higher security risks of visa-required third countries. §The Entry-Exit System (EES) will be operational in 2022. The EES will require every traveller visiting the Schengen area for short stays to record his/her entry and exit at the external border crossing points allowing to detect over-stayers. However, with the exception of the VIS, the harmonised rules governing the common visa procedures still largely relies upon physical presence of the applicant and physical documents. In spite of partial digitalisation efforts by Member States, applicants still have to print and sign the form and submit it in paper together with the supporting documents and travel document. The physical dimension of the visa sticker, which has to be affixed on the holder’s travel document or on a separate sheet in case the travel document is not recognised by a Member State, entails another set of challenges. 1.2.Scope of the initiative The initiative focuses on the short-stay visas application process and the visa sticker. Although the examination and decision on the visa application are an important part of the visa application process, they fall outside the scope of this impact assessment. This initiative is focused on short-stay visas, but due to the existence of a common legal basis on the format of short-stay visas and long-stay visas, this initiative will also explore the material scope, i.e. whether to extend the two novelty of this initiative, the application platform and the digital visa, to long-stay visas, which are national visas allowing to stay on the territory of the issuing Member State for a period longer than 90 days. The possibility to include long-stay visas in the material scope of this initiative is analysed in section 8.2 of this impact assessment. 2.Problem definition

2.1.What are the problems? Citizens of 102 third countries are currently required to hold a valid visa in order to cross the EU external borders. Visas are issued by Member States through a network of consulates in third countries. The figure below shows the total number of short-stay and long-stay visas applications submitted and issued by Member States in 2019. In the projections used in this impact assessment, the number of short-stay visas would increase until 2025 and stabilise at 17.8 million visas applied per year. Item Figure Schengen visa applications submitted 16 955 541 Long-stay visa applications submitted 2 642 538 Schengen visas issued (including LTVs, MEVs) 15 022 255 Long-stay visas issued 2 448 004 The amended Visa Code has created the possibility for the digital submission and processing of visa applications (e.g. electronic signature for applicants), but most Member States only digitalised parts of the Schengen visa process and still rely heavily on paper-based procedures. This is because the whole visa process as envisaged by the Visa Code remains largely paper based and the obligation to issue a visa sticker has also constrained digitalisation efforts of Member States. The figure below describes the causes, problems and effects in relation to visa procedures identified in the context of this impact assessment. Figure 1: The causes, problems and effects 1.1.1.Problems identified in relation to Member States The main problems identified in relation to Member States authorities dealing with visa application and visa issuing are: §The lengthy process and accumulating costs for consulates to manage, process and archive (and eventually destroying) paper documents. This problem is linked to practices of Member States which have not or have only partially digitalised their application procedure. Additionally, current short-stay visas rules at EU level still allow the use of paper documents and do not impose any digitalisation obligation to Member States. This contributes to a fragmented use of digitalisation tools by Member States and high costs associated with handling paper applications that need to be archived for at least two years before they can be destroyed. It is estimated that Member States would spend EUR 638.5 million on administrative burden in the period 2025-2029 under the baseline scenario (see table 4). §The dependence of Member States on external service providers (ESPs) to fulfil their obligations relating to visa management in a context of increase of visa applications and the obligation for third country nationals to visit the consulate or the Visa application centre (VAC) each time they need to apply. On average, 90% of short-stay visas application are submitted through ESPs, which automatically triggers exposure of personal data to third parties. This involves large-scale contracts and monitoring costs and additional costs for visa applicants. This also means that Member States largely rely on ESPs to deal with questions from applicants not only regarding their application and its status, but in addition answering questions on general procedures for applying, which can lead to different interpretation of the rules by ESPs and heterogeneous information provided to applicants. §The paper-based process is not threat/risk proof. The COVID-19 pandemic had a substantial impact on visa procedure as it requires systematic physical displacement of the applicant when applying for a Schengen visa. Visa holders who were already in the Schengen area during the outbreak of the pandemic but were not able to travel back due to worldwide travel bans, had difficulty obtaining an extension of their visa. Because of the pandemic control measures taken by Member States (lockdowns, reduction of public services, teleworking, etc.), applying for an extension and affixing a visa sticker in the passport was a challenge for both visa holders and Member States. This experience shows the vulnerability of the current visa procedure to unexpected events such as large-scale health crises, localised emergencies or other disruptions as it still relies heavily on visits of applicants to the consulate or VAC. §The physical visa sticker is prone to falsification and fraud (e.g. forgery and counterfeiting), which represents a security risk. Since their introduction in 1995, the visa sticker has been counterfeited or falsified. The visa sticker is vulnerable to fraud, and this is substantiated by the fact that over time more security features have been introduced, the latest being the introduction of a signed 2D-barcode on the visa sticker which will enter into force on 1 May 2022. In recital 2 of the Commission Implementing Decision of 30.4.2020 introducing a digital seal on the uniform format for visa it is expressly mentioned that “The newest generation of the visa sticker has already been compromised, with many counterfeits detected in Member States. Additional rules should therefore be laid down to enhance the security of the visa sticker and to prevent further forgery”. Although visa stickers security features enable border and police officers to check whether the sticker is authentic, there is no guarantee that officers will systemically detect counterfeiting. Moreover, stickers may be lost or stolen and reused illegally (washed and re-written). Furthermore, at the border, the examination of the sticker itself is a time-consuming task for border authorities.

§Increased risk of visa shopping by applicants: While the very large majority of visa holders follow the rules, abuses can also take place. Visa shopping has taken different forms over the years. Before the implementation of VIS, visa shopping mainly involved applying for a visa from several Member States. Since the VIS came into force, this is no longer possible as Member States are able to see if an applicant has also lodged an application for another Member State when they register it in the VIS. However, the differences in taking and processing applications also give rise to visa shopping. When applying for a visa, an applicant may be attracted by short waiting times or the issuing policy of a Member State (validity of a visa, e.g. single/multiple entry). The revised Visa Code contains new provisions to further harmonise these issues. In addition, heterogeneity in the way an application can be submitted can potentially create a risk for visa shopping as applicants may choose to lodge an application at a Member State with a more digitalised application procedure. For instance, applicants might be tempted to apply for a visa to a Member State that offers an expeditious or digital visa application process instead of the Member State they intend to travel to, thereby providing misleading information on their destination(s) and/or first entry. This can result in additional burdens on Member States where visa shopping is taking place. 1.1.2.Problems identified in relation to visa applicants §Frequent travellers need to repeat the same lengthy procedure to be able to travel to the Schengen area each time they apply. Repeat applicants must still visit the consulate or VAC to apply for a short-stay visa as application procedures are currently partially digitalised. They generally still need to print and sign the application form as no Member State is currently offering third country nationals the possibility to sign the application form using an electronic signature. They must submit it together with the supporting documents in paper and/or pay the visa fee at the consulate or VAC (only four Member States offer the possibility to upload supporting documents online whereas only three offer the possibility to pay the visa fee online). In addition, applicants might be requested to provide more information by means of additional documents or interviews which might entail another visit to a VAC or consulate. Whereas travel costs for first-time applicants are justified by the enrolment of biometrics in a controlled environment, the same does not apply to repeat applicants as their biometrics are already enrolled in the VIS and valid for five years. In nearly all cases, applicants (first time and repeat applicants) have to make another visit to the consulate or VAC to collect their travel document with the visa sticker (or refusal) or pay courier costs to have it returned. All this is exacerbated by limited consular coverage requiring sometimes extensive travels by applicants. §The complexity and the fragmentation of the application process can discourage third country nationals from applying. Today, the way applicants submit their application differs across Member States, resulting in a fragmented application landscape with Member States offering the possibilities to carry out none or a few application steps online. Several travel and tourism operators mentioned that practical modalities sometimes differ between (a) consulates of different Member States in the same third country; (b) consulates of the same Member State in different third countries; and (c) consulates of the same Member State in large third countries (such as Russia, China, or India). According to the travel and tourism industry representatives consulted in preparation to the impact assessment, the Schengen visa process is often considered as more complex than the processes operated by other third-countries, which might lead operators to undersell travel to the EU, with a potential negative economic impact for Member States. In addition, non-EU nationals exempted from the visa requirement will be able to apply for a travel authorisation to the EU through a common web portal (ETIAS) from 2023. These developments and the increasing use of e-government tools and online payment worldwide will make the current Schengen visa procedure appear increasingly outdated and fragmented. §Issues linked to the physical dimension of the current visa sticker. The “physical” dimension of the visa sticker generates a certain number of problems for visa applicants: -Visa applicants need to travel to the nearest consulate/VAC and leave their travel document there. The fact that the visa sticker must be affixed to the travel document still requires first-time applicants and repeat applicants to come to the consulate or VAC to provide the travel document and collect it with the visa sticker. Although the latter group, according to the amended Visa Code, would not have to appear in person as their biometrics are already enrolled in the VIS, the current practice by Member States linked to the absence of or the very partially digitalised processes requires them to travel to the consulate or VAC to submit their travel document, pay the visa fee and sign the application form. This practice results in the same lengthy procedure, which may entail costs and a time-consuming journey, especially if the applicants live far away from the nearest consulate or VAC. For repeat applicants this means re-visiting a consulate/VAC to lodge an application and collect their travel document . The cost of travel per person per application is estimated at EUR 74 (see table 4). -The unavailability of the travel document during the application and examination procedure. The applicant has to leave his or her travel document at the consulate/VAC during the examination procedure. This means that applicants cannot travel abroad during this period or even go back to their home country in case they applied in a neighbouring country because the Member State of destination neither has a consulate nor is represented by another Member State in the country of the applicant. This problem can be especially critical for those third country nationals who need to travel regularly for professional purposes. 33% of the respondents to the public consultation mentioned this limitation to mobility as a key shortcoming. -The physical link between the visa sticker and the travel document. When the travel document is stolen or lost, the visa sticker needs to be revoked in the VIS. A new application has to be submitted to obtain a new visa whereas an existing digital visa could be easily linked to a new travel document. §Applicants need to pay a service fee each time their application is submitted through an ESP. This service fee, which may not exceed half of the visa fee , increases the overall costs of visa applications by up to 50% and can discourage applicants from applying for a short-stay visa. In third countries where the Member State of destination has no consulate and is not represented by another Member State, the service fee may, by way of derogation from this provision, amount to a maximum of 120 EUR. This dependency makes the visa procedure more costly for applicants and also exposes applicants’ personal data to third parties. 1.1.3.Impact of the problems identified All the above-mentioned problems have three main negative effects on the Schengen area: §Higher costs for Member States resulting from the management of the paper based application procedure and of the visa sticker; §Challenges to security and trust in the Schengen area resulting from undetected forged or counterfeit visa stickers, the risk of identify fraud and the non-systematic check of biometric data against the VIS at the border; §Reduced attractiveness and incentive to travel to the EU as a destination, due to the time and costs linked to the current visa application process for visa applicants, which result in reduced mobility of potential travellers to the EU and a fragmented image of the EU to third-country nationals.

2.2.What are the problem drivers? The root causes of the problem are: §The legal requirement for Member States to issue a paper visa sticker. This requirement provided for by Article 29 of the Visa Code applies to all Member States. It prevents the issuance of dematerialised visas. §Member States reliance on in-person/paper-based practices. Current EU legislation does not impose any digitalisation efforts on Member States as they are free to digitalise some aspects of the visa procedure or not. The amended Visa Code allows applicants to sign applications electronically if Member States recognise the electronic signature, but this possibility has not been used by Member States so far. Such digitalisation efforts were also constrained by the Visa Code provisions relying largely on paper-based procedures and consequently physical presence of the applicant (e.g. going to the consulate/visa application centre). In most cases, applicants still have to put their signature on the paper application form and submit it together with paper copies of supporting documents. §Heterogeneous levels of digitalisation and fragmented visa procedures across Member States. So far EU law regulating the visa application procedure has introduced the possibility for Member States to use some digital features (e.g. electronic signature) but has left the development of any digital tools to their discretion. Without any harmonisation, Member States have digitalised their visa processes to different degrees, for various reasons. Firstly, fully digitalising the visa process requires substantial investment at national level. While some Member States have only digitalised some of the steps of the application procedure, none have digitalised the entire process (see Figure 2 below). For Member States issuing a limited number of visas, the incentive to digitalise is lower as the initial costs incurred are not offset by the number of applications processed. Additionally, as the Commission announced an initiative on digitalisation already in 2018, several Member States prefer to wait for a proposal from the Commission before investing further in it. Indeed, most Member States who have invested in digitalisation, have done so for the easiest and least expensive steps of the procedure (e.g. uploading the application form online) . Therefore, applicants are confronted with very different practices depending on the Member State for which they apply . For many third country nationals wanting to travel to the EU, visa policy is the first EU policy they are confronted with and this fragmentation risks damaging the coherence and visibility of the common visa policy and has a negative impact on the image of the EU. §Suboptimal and fragmented guidance provided to applicants with information scattered across multiple sources (websites operated by different national authorities or on the websites operated by ESPs) and information with very different levels of quality and details often without automated guidance available. This can lead to applications having to be corrected which has a cost for Member State and is not efficient for applicants. In addition, the image of the EU to travellers worldwide comes across as fragmented. In addition to these internal issues linked to the heavy paper-based application procedure and the legal requirement to issue a paper visa sticker, external factors also contribute to make these problems more acute: §The increased flows of visa-required travellers to the EU. The estimated number of short-stay visas applications submitted is difficult to predict for the 2021-2029 period, given the disruption caused by the COVID-19 crisis and its longstanding impact on travels. In the context of this impact assessment, a conservative a cautious approach has been chosen. It is reflected in the table below. After the substantial decrease due to the COVID-19 situation in 2020-2021, the number of visa applications is expected to recover in 2023 to pre-COVID-19 levels (16.9 million visas applied for in 2019). Afterwards, the number of visa applications would continue to grow slightly (+3% /year) and stabilise at 17.8 million per year from 2025. 2021 2022 2023 2024 2025 2026 2027 2028 2029 Total short-stay visas (million) 7.5 11.6 16.9 17.3 17.8 17.8 17.8 17.8 17.8 §The inadequacy between the current visa application procedure and the trend in public sector digitalisation. In its Communication 2030 Digital Compass: the European way for the Digital Decade, the Commission has set the target for 2030 to provide 100% of key public services online for European citizens and businesses. Even if not addressed to EU citizens but to third country nationals, the current digitalisation of visa procedure, relying heavily on paper would appear more and more inadequate and lagging behind the current digitalisation trend in the delivery of public services, including other key tourist destinations that EU Member States compete with. §The increasing demand for a seamless traveller experience. Offering the possibility to third country nationals to travel without undergoing a cumbersome administrative procedure will contribute to the attractiveness of the EU as a travel destination. The results of the public consultation have shown that more than 50% of respondents found that the current process for applying to a Schengen visa was time consuming and 29% too complicated. Difficult and complex procedures discourage potential travellers, especially if they come for tourism and have the choice between several travel destinations. 2.3.How will the problem evolve? The status-quo would have long-term macro-economic impact on the Schengen area as the promotion of the EU as a travel destination would be hampered by this situation. Member States would continue to develop (or not) their own online tools for visa application, resulting in a fragmented landscape of portals/tools with different levels of digitalisation which could ultimately lead to increasing visa shopping by visa applicants. Depending on their Member State of destination and its degree of digitalisation of the visa application process, third country nationals would have in some cases to continue to use the current paper-based process, repeat applicants would have to incur travel (and potentially accommodation) costs to reach the consulate/VAC and would most likely still be obliged to sign the application form on paper. Regarding security, the lack of harmonisation across Member States in the way supporting documents are to be submitted, would imply that consulates would continue to work with documents of different quality and reliability. The use of paper visa stickers would continue to entail a certain security risk, including blank visa stickers being stolen. Despite the recently adopted and more secure sticker format, visa stickers may still be subject to counterfeiting and not address identity fraud adequately. Regarding data protection, a status-quo would not require additional data or different data and would be neutral on data protection. As regards other impacts, the present fragmentation would continue to negatively affect the perception of the European Union as a single geographical entity applying a common visa policy. Third country nationals travelling to the consulates or VAC would continue to have an impact on the environment (CO2 emissions) and paper-based procedures and the use of the visa sticker would still have an effect on paper consumption.

3.Why should the EU act? 3.1.Legal basis Article 77(2)(a) TFEU empowers the Union to develop measures concerning ‘the common policy on visas and other short-stay residence permits’. Article 77(2)(b) TFEU empowers the Union to develop measures concerning ‘the checks to which persons crossing external borders are subject’. 3.2.Subsidiarity: Necessity of EU action As the Schengen visa procedure is harmonised at EU level and regulated in great detail in the Visa Code, the VIS Regulation and the uniform format for visas Regulation, the shortcomings described above are inextricably related to existing legislation. The problems elaborated in the previous sections are unlikely to disappear in the near future and they are directly related to the current legal provisions. For both aspects of the initiative (visa application procedure and format of the visa) by reason of scale, effects and impact of the envisaged actions, action to solve these problems can only be taken efficiently and systematically at EU level. Since the objectives of this Regulation, namely, the establishment of a European online visa application platform and the introduction of a digital visa builds on other initiatives aiming, on the one hand, at streamlining and harmonising the procedures in the context of the common visa policy and, on the other hand, at aligning the travel, entry and border policy of the Schengen Area with the new digital era, the amendments of the related legislation (mostly the Visa Code and the VIS regulation) are only possible at Union level and are part of the Schengen acquis. The subsequent analysis of the options will further demonstrate how non-EU action cannot sufficiently address the problems identified. 3.3.Subsidiarity: Added value of EU action The initiative builds on ongoing initiatives looking, on the one hand, to streamline and harmonise as much as possible the procedures in the context of the common visa policy, and on the other hand, to align the travel, entry and borders policy of the Schengen Area with the new digital trends. As described below, the continuation of the baseline scenario is not going to solve the problems identified, neither in relation to Member State authorities, nor the visa applicants. Only at EU level changes can be implemented in a way that would lead to the benefits illustrated in this report. The measures that are described under the policy options are examined to make sure they do not go beyond what is needed to achieve the general and specific objectives, in order to respect the proportionality principle (see Section 7.3.3). 4.Objectives: What is to be achieved? 4.1.General objective The general objective of the initiative is to simplify, harmonise and reduce the administrative burden to apply for a Schengen visa to improve the security and safety of the Schengen area. 1.2.General and Specific objectives The following general and specific of this initiative have been identified: General objectives Specific objectives §To simplify, harmonise and reduce the administrative burden to apply for a Schengen visa §To improve the security and safety of the Schengen area §To streamline and make more efficient the visa application procedure for applicants and MS through digital means (SO1) §To increase the security of the Schengen area through the digitalisation of the visa sticker and digitalised application procedures (SO2) Simplifying, harmonising and modernising the visa application process through digital means would allow addressing the problem drivers identified in section 2.2. This process of simplification, harmonisation and modernisation through digitalisation would put an end to Member States reliance on in-person/paper based practices and inconsistent levels of digitalisation. The harmonisation of procedures would address the fragmentation and complexity of visa procedures across Member States and reduce current disparities in Member States digital visa procedures (as shown in fig. 2). Achieving this objective would also contribute to address the issue of suboptimal and fragmented guidance provided to applicants and increased visa shopping by applicants through a harmonised, modern and digitalised application procedure, as visa shopping could potentially increase if ways of applying for a short-stay visa differ too much. Giving all third country nationals the possibility to apply online would decrease the reliance of Member States on ESPs and would allow third country nationals to be less dependent on ESPs services and spend less time, money and efforts to apply for a short-stay visa. Reducing the risks of fraud, forgery and facilitating the verification process at the border through the digitalisation of the visa would virtually end the practice of attempting to enter or transit through the Schengen area with a forged or falsified visa sticker. It would further improve the security of the visa whose features have been regularly upgraded to fight counterfeiting and forgery (as explained in section 2.1.1 above). It would also put an end to the issue of blank visa stickers being stolen from consulates which is frequently reported by Member States. In addition, abolishing the visa sticker and consult the VIS database to check whether a visa was granted and with what validity (also available for carriers via read only VIS) would further enhance the security of the Schengen area and facilitate the verification process at the border. The number of forged visas detected at the border should be close to zero when the digital visa is implemented. The achievement of these two specific objectives will be measurable. In a time horizon of seven years following the adoption of an initiative at EU level on digitalisation of visas procedures, all third country nationals should have the possibility to apply for a short-stay visa through digital means following the same, simple, modern and easy procedure independently on the Member State of destination. They should be able to access easily the same updated information and benefit from guidance to apply. The cost incurred by third country nationals to apply should be reduced to the minimum and they should not be obliged to travel for a repeat application or to collect their travel documents. They should be less dependent on ESPs services for their applications. All third country nationals receiving a positive decision following their visa application would receive a digital visa. Member States should spend less resources on collecting visa applications and issuing short-stay visas and should be less dependent on ESPs to collect applications.

5.What are the available policy options? 5.1.What is the baseline from which options are assessed? Member States would continue to develop (or not) their own online tools for visa application, possibly with non-binding recommendations and support from the Commission (soft law measures), resulting in a fragmented landscape of portals/tools with different levels of digitalisation which could ultimately lead to increasing visa shopping by visa applicants. Member States would still have to manage supporting documents and physical stickers with associated costs (EUR 16.06 million per year for managing the visa sticker for all issuing Member States). Maintaining the status-quo would have no impact on EU institutions. Third country nationals applying for a short-stay visa with little digital skills would continue to use the current paper-based process, incur travel (and potentially accommodation) costs to reach the consulate/VAC, as well as other travel/courier costs needed to collect the travel document with the visa sticker. Applicants would incur such costs because they would have to provide their travel document for the purpose of affixing the visa sticker. They would most likely still be obliged to sign the application form on paper. Third country nationals applying through a national digital application platform could benefit from its features, but it remains to be seen how many more Member States will digitalise their application process independently and to what extent. Regarding impact on security, the lack of harmonisation across Member States in the way supporting documents are to be submitted, would imply that consulates would continue to work with documents of different quality and reliability. The use of paper visa stickers would entail security risks. Despite the recently adopted and more secure sticker format, visa stickers may still be subject to counterfeiting and not address identity fraud adequately. The status-quo or baseline scenario analysed below could also potentially have long-term macro-economic impact on the Schengen area. If the status-quo continued until 2029, the current trend on digitalisation at global level offering potential travellers the possibility to apply online and obtain a digital visa would increase the cost of no action at EU level. The competitive disadvantage of the EU compared with other third-countries in attracting travellers might increase and the promotion of the EU as a travel destination would be hampered by this situation. Loss of income for EU companies, in particular in the travel and tourism industry, would materialise and third countries who would be perceived as more attractive for visa-required Third-country nationals would benefit from this situation. Regarding data protection, no additional data or different data will be collected and processed in this baseline option than in the current situation in all Member States. Member States will have to comply with mandatory legislation (GDPR and relevant provisions of the Schengen acquis) while implementing their own procedures and systems. From this perspective, there will be no negative or positive impact on data protection. Under the baseline scenario, it can be assumed that Member States relying on external service providers for a number of services (e.g. appointment booking, checking and registering applications, collection of biometrics and in some cases scanning paper applications) will continue to follow their own procedures, ensuring that those third parties actually comply with data protection obligations. This does not pose a threat to data protection as long as a thorough evaluation of each ESP and its compliance with the data protection requirements are frequently carried out by Member States authorities. As regards to other impacts, the present fragmentation in terms of national practices for managing the application process negatively affects the perception of the European Union as a single geographical entity applying a common visa policy. From an environmental point of view, although the effects may be marginal, the travels of third country nationals to the consulates or VAC also have an impact on CO2 emissions. The continued use of paper applications, paper-based supporting documents (including those produced digitally and subsequently printed) and visa stickers has a certain albeit limited effect on paper consumption. 5.1.1.Existing national application portals and features The current legal framework has recently included the possibility for the digital submission and processing of visa applications (e.g. filling in and signing electronically the application), but most Member States only digitalised parts of the Schengen visa process. They may encourage online visa applications, but (a) they can only do so via national online application portals, managed individually, sometimes with the help of ESPs as there is no common EU online visa application platform; and (b) their systems rarely allow applicants to upload supporting documents in digital format and to electronically sign their application which means that the applicant still needs to print and sign the form manually and submit the application on paper. Member States will continue to develop their national tools in the coming years but these initiatives are likely to cover only parts of the application process especially if the current legislation on visa issuance is maintained, requiring the applicant to visit the consulate or VAC to provide his/her travel document for affixing the visa sticker. Member States might choose for the time being to keep the submission of supporting documents paper based as well. Some Member States will not develop digital application platform due to the low number of applications they deal with versus the investments needed. See Annex 2 for more details on the levels of digitalisation in the Member States. 5.1.2.Digital visa Currently, a digital visa cannot be used by Member States as they are required by EU law to issue a paper visa sticker. Article 29 of the Visa Code provides that a valid visa shall be certified via a paper sticker affixed to the holder’s travel document or on a separate sheet in case the travel document is not recognised by the Member State. The sticker includes a unique number that is also part of the corresponding record in the VIS, allowing the verification of the holder’s identity by competent authorities. This requirement is common for all Member States. It is important to note in this regard that, while the security features of the visa stickers have been continuously increased since it was introduced, the security of the visa sticker could not be further improved through changes to the Visa Code. Security features of the visa sticker are specified and adopted in the Article 6 Committee established by the Visa Sticker regulation. Additionally, the revised Visa Code did not address the security of the visa sticker, but the responsibility regarding rules on filling in and affixing visa stickers. 5.1.3.Biometric enrolment Under the baseline scenario biometric enrolment needs to be done in person. The following biometric data of the applicant needs to be collected: §a photograph, scanned or taken at the time of application (in the future: live capture will be required) and; §10 fingerprints taken flat and collected digitally. Once the biometric identifiers are collected, they can be reused for any subsequent visa application within a period of 59 months. 5.1.4.Travel to consulate and/or courier charges In the vast majority of cases, third country nationals have to lodge the application at a consulate or VAC and - in case of first-time travellers or expiry of biometrics (after 59 months) – have their biometrics collected. They also have to go to the consulate or VAC or pay courier costs (if the consulate or VAC arranges home delivery), to retrieve their travel document with a final decision (a visa sticker affixed in the passport or a refusal to issue a visa).

5.2.Description of the policy options 5.2.1.General definition and policy changes The Impact assessment evaluates five policy options, option 1 being the baseline situation, with varying levels of EU intervention in the current visa process: Option 1 (O1): Baseline situation: Please refer to section 5.1 Option 2 (O2): Minimal EU legislative changes and digital visa (mandatory). It includes some minimal legislative changes at European level, aiming to remove legal obstacles that limit the possibility for Member States to further digitalise the visa application process. The introduction of a digital visa is also a crucial difference with Option 1 (the status quo). A mandatory digital visa would replace the paper visa sticker and a web service would be introduced to check its validity. Option 3 (O3): an EU visa application platform (optional) and the digital visa (mandatory). O3 envisages the development and building of an EU visa application platform, albeit only on an opt-in basis. Member States could choose to participate in the EU visa application platform on a voluntary basis or develop/continue to use their own national portals or to not develop any digital application solution. Visa holders would be able to check the validity of their digital visa through the EU visa application platform. During the consultation with Member States, 14 expressed preference for option 3. Option 4 (O4): the EU visa application platform (mandatory after a transition period) and the digital visa (mandatory). O4, like O3, also includes the development of an EU visa application platform. Whereas participation of the Member States to the EU visa application platform would be optional under O3, under O4 the EU platform would be mandatory for every Member State after a transitional period of e.g. five years which would begin after the two-year development period of the EU Visa application platform. The purpose of the transition period is to allow Member States to phase out smoothly and amortise their investments made in national platforms. The five-year time frame is considered sufficient to amortise the investment and prepare for the transition to the EU visa application platform. Visa holders would be able to check the validity of their digital visa through the EU visa application platform and would only be obliged to come to the consulate or VAC to provide their biometrics or when they change travel documents. During the transition period and if they apply to a Member State not using the EU Visa application platform, the applicant might be obliged to come physically even for a repeat application, depending on the procedure used by the Member State to which he/she applies. During the consultation with Member States, 10 expressed preference for option 4. In the stakeholder consultations, the travel and tourism industry unanimously supported option 4, highlighting it as the best option to facilitate the application procedure for visa applicants and increase the attractiveness of the EU as a travel destination. Option 5 (O5): The EU visa application platform (mandatory, for all Member States without transition period), fully digital procedure and the digital visa (mandatory). O5 also entails the development of an EU visa application platform with mandatory participation of the Member States, but without the transitional period envisaged under O4. In this option (full digitalisation), applicants are never obliged to come to the consulate or Visa Application centre as all application steps can be carried out online (including the provision of biometrics). The main goal of this policy option is to fully digitalise the application process. Unlike all other options, the applicant would be able to enrol his/her biometric data through a digital application, removing the need to visit the consulate/VAC in person which would still exist under all other options. Member States, the EDPS, data protection authorities, the Fundamental Rights Agency and Europol all expressed concerns regarding option 5, in particular due to the remote collection of biometrics. The figure below gives an overview of main policy changes of each option. Figure 3: Policy options The following sections describe each option closely linking them to the drivers of the problems and the identified objectives. Moreover, the Impact assessment will analyse the impact on the preferred policy option of the following technical sub-options: §Architecture of the EU visa application platform, which may be: centralised (sub-option 1) or hybrid (sub-option 2). §Material scope of the initiative with the inclusion of long-stay visas in the scope of the analysis. §The fall-back solution for the digital visa 1.Architecture of the EU digital platform: centralised or hybrid The architecture of the EU visa application platform defines what functional components are included, how they are connected, how data flows between them and where data are stored. The feasibility study identified two different potential architectures (visualised below): §Sub-option 1 - A centralised architecture: all application files are stored centrally, on the EU visa application platform; or §Sub-option 2 - A hybrid architecture: all application files are stored centrally until they are admitted. At that point they are transferred to the relevant Member State.

It is important to note that these architectures do not have an influence on what the EU visa application platform does. In other words, end-users – be they applicants, ESPs consulate staff or administrators – will not perceive the difference in architecture. The end-product remains a system allowing for the online visa application. These two architectures differentiate themselves in where the application files are persistently stored. In the centralised architecture, all temporary and completed applications will be stored in the Application Management System from where Member States can access them. Access management controls would ensure authorities can only access those applications they should be able to access. The hybrid architecture on the other hand only stores applications temporarily at central level. This includes partial applications, saved to be completed later and applications that are not yet marked as admissible, i.e. they still need to be checked by an authority for quality and completion. Once marked as admissible, the application is sent to the respective Member State and deleted from the temporary storage. 2.Material scope: only short-stay visas or short-stay & long-stay visas This dimension entails assessing the costs and benefits of extending the two limbs of the initiative – the digital application platform and the digital visa – to long-stay visas. These visas allow the holder to stay on the issuing Member State’s territory for a period longer than 90 days for different purposes (e.g. study, work, etc.). The sub-options are the following: §Sub-option 1 – This would limit the initiative to short-stay visas only; §Sub-option 2 – This would extend the initiative to long-stay visas. Extending the first limb – EU visa application platform – would mean that third country nationals would use the platform also to apply for long-stay visa to a Member State; extending the second limb – digital visa – would mean that the visa sticker for long-stay visas (“D” type) would be completely removed, and third country nationals would be issued digital long-stay visas. As it is the case for the overall study, the choice of this sub-option only concerns the application process for long-stay visas and the format of these long-stay visas, and does not assess the feasibility or implications of amending the substantive requirements for issuing this type of visa, which in any case are mostly issued on the basis of national law. 3.Fall-back solution for digital visa: simple or digitally signed barcode This dimension entails assessing the costs and benefits of two technical sub-options to complement the digital visa with a fall-back solution allowing for the verification of the visa offline. The sub-options are the following: §Sub-option 1 – Visa issuance notification: The fall-back solution would consist of an electronic notification sent by the Member State issuing the visa to the visa holder informing the latter that the visa has been granted. It can be shown either on paper (print-out) or from a digital device. §Sub-option 2 – Visa issuance notification with digitally signed 2D barcode: The fall-back solution would be the visa electronic issuance notification plus a 2D barcode containing the same data as the VIS record that has been encrypted with a digital seal by the Country Signing Certificate Authority (CSCA) of the issuing Member State. This sub-option would rely on the current Commission Implementing Decision introducing a digitally signed 2D barcode in the current version of the visa sticker as of May 2022. An analysis of the pros and cons of the different sub-options is provided in Section 8.2. 5.2.2.The legal requirement for Member States to issue a paper visa sticker O1 would not lead to the implementation of a digital visa and would not change the legal requirement for Member States to issue a visa sticker in case of a positive decision. Under O2, O3, O4 and O5 legislative changes would require Member States to issue a digital visa and to check an individual’s visa at the border through their biometrics or with a fall-back solution. As a result, the internal security of the Schengen Area would improve as it would no longer be possible for third country nationals to try entering the Schengen area holding a falsified visa sticker. During the stakeholders consultations that were held in context of this impact assessment, Frontex indicated that the introduction of a digital visa would be welcome as it will make forging visa stickers even more difficult (no more “physical” visa). In addition, the high operating costs of the visa sticker would disappear. 5.2.3.Member State reliance on in-person/paper-based practices

Under O1, it is very likely that the vast majority of applicants would still have to lodge their application at a consulate/VAC in person. Applicants would also have to go to a consulate/VAC, or pay courier costs if the consulate/VAC arranges home delivery, to get the passport with a final decision (a visa sticker affixed in the passport or a refusal to issue a visa). In addition, it would be mandatory to go to the consulate/VAC in person to provide the necessary biometrics with a first application or every 59 months. Under O2 and O3, the personal appearance at the consulate would depend on the extent to which Member States have digitalised the application process. However, it would still be mandatory in all cases to travel to the consulate/VAC to provide biometrics every five years and for identification in case the applicant will be travelling on a different travel document. Repeat applicants would no longer need to travel to collect their travel document as the digital visa would be implemented under these options. They would no longer need to travel if they apply for a visa to a Member State equipped with a national online application portal or through the EU visa application platform (in O3 and O4). Under O4 the personal appearance at the consulate/VAC would be mandatory for first time applicants and applicants who have acquired a new travel document (or every five years thereafter) for the collection of biometric identifiers. Given that the EU visa application platform would be used by all Member States in a five-year period, repeat applicants could apply fully online, provided that they apply with the same travel document. Applicants would no longer need to travel to collect their visa as the digital visa would be implemented. Under O5 the personal appearance at the consulate/VAC would only be required for a very limited number of cases, e.g. when consulates want to check the authenticity of supporting documents. In all other cases, applicants would no longer need to visit the consulate/VAC to provide biometrics and/or be identified with the travel document, as part of the application process. They would be able to identify themselves and submit their biometrics fully online. As regards collection of the biometrics, under O2, O3 and O4 there would be no changes compared to the status quo (O1) where physical presence of the applicant is required. Once the biometrics are collected, they can be reused for any subsequent visa application within a period of 59 months. O5 would include a fully digitalised procedure, including identification of the applicant and the enrolment of biometric data through a digital application, removing in principle the need to visit the consulate/VAC in person. 5.2.4.Heterogeneous levels of digitalisation and fragmented visa procedures across Member States Under O1 the development of digital tools depends on the initiative of Member States, without any support, framing or obligation from the EU which could result in the long run to improved digitalisation but in a very fragmented manner with different tools, features and processes. Even if the usage of national portals would be encouraged with non-binding standards under O1, and with mandatory minimal standards set up with legislative changes under O2, under these two options the potential development of a national visa portal by Member States would however remain fully optional. This would only partially address the problem and related effects (e.g. visa shopping). One of the consequences of these options is that applicants might have to set up an account (or other user credentials) for each Member State for which they want to apply for a visa. In policy option O2, applicants will be able to check the validity of obtained visas via a common web service, but the way they will be notified that a visa has been refused will vary from Member State to Member State. Under O3 national portals would continue to be developed and used on a voluntary basis, but some Member States might choose to use the EU platform. This diversity, however, does not address the problem of fragmentation and the complexity of the application process as they also occur in O1 and O2. It would discourage third country nationals from applying and fragmentation would persist over time. Under O4, a mandatory EU visa application platform with transitional period (e.g. 5 years) would be created and the national portals would be gradually phased out. Under O5 (no transitional period) national platforms would no longer exist after the EU visa application platform becomes fully operational. These two options would address the main problems of fragmentation and complexity of the application procedure as they would offer the applicant a single environment to apply and to view his/her visas or refusals online, regardless of the Member State of destination. This would reduce the risk of visa shopping (due to automation in the EU application platform, applicants would not be able to decide to which consulate to address the application). It would also simplify the process for frequent travellers and would encourage them to apply. 5.2.5.Suboptimal and fragmented guidance provided to applicants O1 would not lead to the implementation of an EU visa application platform, but the common, however non-binding, standards set out by the EU would provide a first step in the standardisation and harmonisation of digital application process between the different Member States from both a legal and operational point of view. With O2, legal hindrances such as the obligation of signing the application form submitted electronically would be removed and would make the digitalisation of the visa application process more straightforward. However, under these two options the process would remain complex and guidance provided to applicants would stay fragmented across different Member States as it is the case now under the baseline scenario. O3 would require EU Regulation to introduce provisions concerning the EU visa application platform (as well as for O4 and O5) and would involve the development and set-up of an EU platform, albeit only on an opt-in basis, meaning that Member States could choose to use the EU platform, their own national portals or none. This means that each Member State would have to set up and maintain systems to inform the applicant about Schengen visas and the application procedures. The fact that this information would be found in different national portals and might vary across Member States, could confuse applicants, who might decide not to use portals and continue using in-person/paper-based practices, leading to still lengthy processes for consulates to manage, process and archive paper documents. Under O4 the EU visa application platform is mandatory, but with transitional period. Whereas in O5, there is no transitional period for the mandatory EU visa application platform. These two options introduce common practice as regards digital application, which would lead to removing the issues of fragmented guidance that would persist under other options. 5.3.Options discarded at an early stage None of the options were discarded at an early stage because all options were considered to have a potential positive impact on the policy, compared to the baseline scenario. Furthermore, although the different options received varying degrees of support among stakeholders, none of the options were fully rejected. 6.What are the impacts of the policy options? The impact of the different policy options was assessed across various categories, in line with the Better Regulation guidelines. As regards social impacts, the assessment focuses on implications for security and fundamental rights, as well as data protection. Detailed assessment on the quantitative impacts of the different policy options are available in the Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment. 6.1.Economic impact

6.1.1.Impact on EU institutions and agencies The economic impact of the digital visa for EU institutions and agencies are equivalent for O2, O3, O4 and O5. However, for O2, a web service allowing third country nationals to check information on their digital visas would have to be built, whether Member States use their own national online application portal or maintain the paper process. The costs for the web service to be implemented at central level by the European Union Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice (eu-LISA), which would reuse the concept of the web service to be built for EES and ETIAS, are estimated at EUR 3.5 – 6.4 million for one-off costs related to procurement, design, development, testing, infrastructure and deployment and EUR 3.5 – 6 million yearly maintenance costs over the 2025-2029 period. The visas currently issued are already digitally stored in VIS. Therefore, digitalisation of visas would not imply any additional costs for the EU budget. In addition to the costs linked to the dematerialised visa (or digital visa) that will concern options O2, O3, O4 and O5, the set-up of the EU visa application platform envisaged by O3, O4 and O5 would trigger costs for establishing the central digital application capability. As estimated in the EU visa application platform prototype study, the one-off cost to enable this capability would range between EUR 33.8 million and EUR 41.2 million for eu-LISA (including the managed service costs and the adaptations needed for VIS). In addition to the one-off technical costs, eu-LISA is expected to need to expect 8 additional full-time equivalents for supporting the development efforts during 2024 and 2025. This amounts to an additional costs of EUR 2.5 million across these two years. Once this managed service is created, it also needs to be operated and maintained, leading to a yearly cost between EUR 10.5 million and EUR 12.8 million for eu-LISA. Additionally, this would involve establishing a design/business team, service level agreements and extensive stakeholder management, as well as additional staff (7-10) and training costs (EUR 20 000 – 33 000) for eu-LISA. 6.1.2.Impact on Member States As regards the impact on Member States, O2, O3, O4 and O5 would allow savings on the costs attached to the current visa stickers, which would no longer be required (EUR 76.6 million over 2025-2029). The introduction of the digital visa would trigger only negligible costs for Member States that have not been taken into account in this impact assessment. Indeed, the tools to generate and verify a signed 2D barcode will already be in place to comply with the Commission’s Implementing Decision C(2020)2672 of 30.4.2020 introducing a digital seal on the uniform format for visas. In addition, the implementation of an EU visa application platform (O3, O4, O5) is expected to reduce the administrative burden on consulates both in terms of time spent processing paper-based applications and time spent printing and affixing the visa sticker with total savings under O3 amounting to EUR 364.3 million for all Member States on the 2025-2029 period, EUR 510.9 million under O4 (taking into account small additional costs to capture biometrics) and EUR 521.6 million under O5. Another benefit of the EU visa application platform is that all general information on Schengen visas will be kept up to date at central level, including a guidance tool that enables third country nationals to check if a visa is needed and under which conditions. All this will trigger savings for Member States up to 576 FTEs (2025 – 2029) to reply to queries from visa applicants. To implement the new EU visa application platform, each Member State using the EU platform (even the ones who already have some form of online portal) needs to adapt and connect its national systems with the centrally hosted and managed platform. According to the EU visa application platform prototype study, this investment would roughly amount to EUR 2.8 million to EUR 3.3 million (on average) per Member State . Once the national systems have been updated and connected to the managed service and sufficient storage space is provided for, these new enhanced national systems will need to be maintained, with an estimated cost between EUR 460 000 and EUR 570 000 per Member State, annually. These expected costs, however, vary with the number of applications a Member State receives. It should be noted that Member States choosing their own solution for digitalising visa applications (in policy options O1, O2, O3) must also have systems in place to store these digital files. O5 also includes additional time saving as biometric data would no longer be collected in person at the consulate or at VAC. The benefits relating to the reduction of administrative burden for Member States, even if they also rely on a number of forecast visa issued, are more reliable because they have been calculated on the basis of an existing workload/tasks and costs that currently exist, and have been estimated with Member States input. These costs will partially or completely disappear with digitalisation, which is why even assuming a stable number of travellers over the 2025-2029, the calculations would still show a significant reduction of the Member States administrative burden and associated costs. 6.1.3.Impact on third country nationals Third country nationals currently (O1) incur travel costs and sometimes accommodation costs to apply for a visa as they have to leave their travel document at the consulate, as well as costs to collect their travel documents after the application process is completed. Minimal improvements are expected under O2, where the costs for repeat applicants would reduce as they would no longer have to travel to the consulate or VAC to lodge their application. This would apply if Member State who run their own portals would allow applicants to submit supporting documents online. The same benefit for third country nationals would apply for options O3 and O4 as the third country nationals would not need to pick up their travel documents and could lodge their application online. This measure would entail a cumulated saving of up to EUR 2.7 billion under O2, 2.7 billion under O3 and 2.9 billion under O4 in terms of direct travel costs for third country nationals during the application process for over the 2025 - 2029 period , as well as the associated opportunity costs that comes with travelling to the consulate or VAC. Besides cost savings, 89% of the respondents in the public consultation indicated that not going to the consulate or VAC as a repeat applicant is important for them. However, costs and obstacles for first-time applicants would remain. Under O4, third country nationals will be able to use a single application platform whatever their Member State of destination, using one single procedure and being able to save and reuse their data for a subsequent application. In addition, a single online application platform would provide in one single place information on Member States application procedures. This information will be more easily updated and maintained, significantly increasing the quality and reliability of information provided to third country nationals. Although difficult to quantify, this option would spare time and produce greater benefits for third country nationals than in O3 where they would still have to cope with several application procedures. In O5, the benefits of the fully digitalised application would be even greater for third country nationals and would allow savings up to EUR 8.3 billion over the same 2025-2029 period. For visa applicants, digitalisation will decrease the travel costs associated to visa applications because they will not have to travel or pay a courier to pick up their passport with the visa sticker and repeat applicants will be able to apply fully online during five years after their first application. Even with a stable number of travellers, these benefits would remain substantial. It must be stressed that all options would have no impact on the visa fee itself. 6.2. Social impact 6.2.1.Security Under O2, Member States would continue to have different degrees of digitalisation of their visa procedures. Depending on which documents are requested on paper and which ones can be submitted online and/or digitally, consulates of different Member States may process documents of varying quality and reliability which would not allow improving the detection of forged documents. The major novelty of O5 is the possibility for first-time applicants or third country nationals to enrol biometrics independently by using a digital app on their smartphones to capture their facial image and fingerprints. O5 would decrease costs and increase time savings compared to O3 and O4; however, it also increases security risks. First, because the identification of the applicant is not done in a controlled environment (risk of identity fraud), and second because adequate quality of biometrics is not guaranteed, which could cause mismatches with data stored in EU information systems. As biometrics only have to be submitted every 59 months, identify fraud might go undetected for the same period of time. Even though there are secure technologies available to provide biometrics, a first identification is always done by checking it against an official identity document. Persons whose identity have been established, could then be allowed to identify themselves online with the biometric identifiers and secure technologies. By enrolling biometrics using a digital app, there is no check if an applicant commits identity fraud using a forged travel document in combination with their own biometrics. O5 is therefore likely to disrupt the reliability and security of Schengen visa applications. Under options implying the use of the EU Visa application platform, the choice of the hybrid or decentralised sub-option for the storage of data would avoid the risk of having a single point of failure and attacks. As regards the security implications of maintaining the visa sticker vs introducing a digital visa, evidence indicates that the paper visa sticker is not threat and risk-proof as it is prone to falsification and fraud. However, biometric checks against the VIS at the border should make entering and staying in the Schengen area with a forged sticker more difficult or rather impossible. The current Schengen Borders Code requires a biometric verification at the Schengen external border that the traveller corresponds with the person who applied for the visa (and whose biometrics are stored in VIS). With the entry into operation of the Entry-Exit System, biometric verifications will even become more routine as they will also apply to any third country national entering the Schengen area for a short stay and not falling in the exception cases. O4 will however achieve deeper harmonisation than the previous options because all applicants will upload their documents through the EU online application platform which will enforce certain formats and data quality. A digital visa embedding these security features will be significantly less prone to forgery. This will further reinforce the visa format security. Maintaining the visa sticker (O1) would not hamper the security benefits of EES and interoperability but may lead to inefficiencies: border guards would still be required to verify the sticker, and if check with VIS contradicts the data on the sticker, they would spend additional time investigating the mismatch and ascertaining that the sticker has been counterfeited.

The replacement of the visa sticker with the digital visa (O2, O3, O4, O5) would lower security risks related to counterfeited and stolen stickers, especially those not detected by border and/or police authorities. Furthermore, carriers will be better equipped to check if third country nationals hold a valid visa thereby mitigating the risk that they transport people with fraudulent visas to the Schengen area and alleviating the burden of checks at the Schengen borders. 1.2.1.Protection of personal data In general, as pointed out by the EDPS and national Data protection authorities, the higher degree of digitalisation of the options, the greater are the risks to data protection. That is why the principles of “purpose limitation” and “data minimisation” will have to be strictly respected in the context of the new developments triggered by digitalisation. As also pointed out by EDPS, data protection impacts of digitalisation would primarily stem from the introduction of a visa application portal (with impact on handling of personal data by external service providers, data security of the portal, collection of biometrics through digital means under O5 etc.). Under O2 mandatory standards may enhance monitoring of compliance and legal certainty, positively contributing to data subjects' trust in the data processing. The web service would entail data security implications that need to be mitigated via a “privacy enhancing” implementation. Under O3 the EU visa application platform would introduce uniform data processing practices, which would however apply only to a subset of Member States. Under O4 the EU platform would introduce uniform data processing practices, which would apply to all Member States. It would reduce exposure of personal data to ESPs as repeat travellers would be able to apply directly through the EU application portal. Under O5 the EU visa application platform would introduce uniform data processing practices, which would apply to all Member States and would even more reduce reliance to ESPs compared to O4 as first time and repeat applicants would be able to apply online. Nevertheless, under O5, the online biometric enrolment would open up new privacy challenges compared to the other options, such as collection of (new) or additional data on mobile application and exposure of data to other (third) parties. Under O3, O4 and O5, the use of ESPs does not pose a threat to data protection as long as processes and technologies used by ESPs comply with data protection and privacy enhancing principles and that proper monitoring of each ESP is carried out by Member States authorities. EU law already provides that ESPs need to respect GDPR and applicable data protection safeguards, which also applies to methods of identification of applicants by ESPs when collecting their biometrics. In addition, the use of a single application platform could lead to a reinforced compliance of data protection practices by ESPs (same standards/rules applying to all ESPs). A “privacy enhancing” implementation will safeguard security of data stored in the EU visa application platform. Nevertheless O5 presents serious risks regarding data protection due to the self-enrolment of biometrics through digital means. All other options (O2, O3 and O4) are relatively equivalent as far as data protection was concerned. In terms of the data protection implication of digital visas, currently the information about a visa is stored in a large-scale EU database – VIS, as well as evidenced by affixing a visa sticker in the passport. Hence, dematerialising the visa sticker into a purely digital visa does not change the fact that the visa information is (and will still be) stored in a large-scale EU database. Since storage in a centralised large-scale EU database has undeniable data protection impacts, the VIS regulation already contains high data protection safeguards (retention rules, access rules, access rights, rights to rectification, completion, erasure of personal data and restriction of processing etc.). Moreover, the recently revised VIS Regulation has further enhanced these data protection safeguards. These enhanced data protection safeguards will continue to apply, as the purely digital visas will continue to be stored in VIS. Additionally, the ETIAS Regulation, which introduces digital travel authorisations for visa-free travellers, is currently being implemented. This Regulation contains data protection standards for notifications to travellers regarding their travel authorisations. Notifications to travellers regarding digital visas will follow the same standards for communicating with travellers regarding their visas. 6.2.3.Protection of fundamental rights In terms of implications for the protection of fundamental rights, under O1 there would be no impact on the protection of fundamental rights compared to the present situation. Under O2 and even more so O3, O4 and O5, people with low IT literacy and people who cannot read or write applying from distance may need technical assistance to use online application tools, but the assistance provided by family members and friends, service providers and consulates would be sufficient to guarantee protection and inclusion, according to the results of the consultation with Member States. Service providers already provide assistance and services to support applicants today for paper-based and online applications. Repeat applicants with reduced mobility would be able to apply with no need to visit a consulate/VAC. Therefore, O1 O2, O3 and O4 would ensure compliance with the EU Charter of Fundamental Rights with O4 providing the same supporting features to people unable to see or hear in all Member States. O5 would comply with the protection of fundamental rights. Nevertheless, under O5 consulates and VAC staff would normally have little to no chance to perform on-site checks to detect child abduction or trafficking of human beings. In particular children above the age of 6 will not be required to come to the consulate/ VAC to enrol their biometrics. Even if the visa procedure plays a very limited role in detecting child abduction and trafficking of human being, O5 might offer less possibilities than other options to detect such cases. 6.3.Environmental impact Under the O1 scenario, the main environmental impacts concern the continued use of (non-) renewable resources due to paper-based administration (applications and visa stickers) and the travel of applicants to the consulates. The environmental impacts of these elements are expected to increase under the baseline scenario in line with the projected increase of visa applications and issuance. Additionally, the vast majority of the applicants will have to travel to the consulate or VAC on average 129.76 km in order to lodge their application and/or collect their travel document. This would produce up to 477 million kg of CO2 for both activities combined in 2029 (i.e. 2.9 billion kg over the 2025-2029 period). As O2 entails the introduction of common standards related to developing national visa application platforms, as well as the removal of certain boundaries such as the necessity to sign the application document in person, O2 would enable saving 38% of the CO2 emitted by third country nationals travelling to consulates/VACs, 50% of the paper needed for visa applications, and all paper used for visa stickers. Under O3, O4 and O5, thanks to the digital visa and the gradual reduction of travels by visa applicants to pick up their travel document or to apply (in particular for repeat applicants using the EU Visa application platform), the emissions of CO2 linked to the application process would decrease. O5 would almost save the remaining 75% of CO2 emissions and paper in the application process). Regardless of the number of travellers, paper consumption as well as travel of third country nationals for the purpose of applying for a visa will decrease, with positive impacts on the environment. Overall, the positive impact of all options on environment (reduction of travels for repeat applicants, paper consumption) are certain, regardless of the number of travellers whereas additional CO2 emissions triggered by additional travellers are difficult to forecast. According to the calculations carried out in the context of this impact assessment, the slight increase in tourism to the EU due to the implementation of the EU visa digital application platform for the period 2025-2029 would trigger additional emissions of up to 0.8 billion kg CO2 under O3, to 2.9 billion kg of CO2 under O4 and up to 6.2 billion under O5. Nevertheless the estimated increase of CO2 emissions might be overestimated, as it relies on an additional number of travellers triggered by the simplification and harmonisation of the application procedure that is difficult to predict. Furthermore the impact on the environment of these additional travels might be mitigated by carbon emission reduction measures for air transport. Recent initiatives aiming to reduce problematic fuel emissions in the air transport sector have not been taken into account in the calculation of the impact as it was not possible to produce reliable quantitative estimations. Because of this reason, the precise amount of extra CO2 indicated in the report is likely to overestimate the eventual impact. At this stage it is also not possible to assess whether travel habits and public-private initiatives will reduce the environmental footprint of the additional visa required third country nationals travelling in the coming years. 6.4.Impact on EU tourism and GDP Given the difficulty to forecast ex-ante a) the “natural” growth of visa-required travellers and b) the impact of the introduction of a single EU visa application platform (precise quantitative correlation) on the number of travellers, the impact on tourism and GDP should be considered carefully in the context of this impact assessment as it is based on assumptions.

As regards economic impacts on EU tourism and GDP, O1 and O2 are not expected to bring about significant benefits to international travel and consequently to EU GDP. Under the options including an EU visa application platform (O3, O4, O5), it has been assumed that the introduction of the EU visa application platform would have a slight positive impact on the contribution of visa-required third country nationals to the EU GDP due to the increase of visa required third country nationals travelling to the EU (2% under O3 and O4; 4% under O5), with the assumption that O5 would generate the highest increase in travel. These assumptions rely on the results of the public consultation and of the survey with Member States and the travel industry that corroborated this expectation: 86% of the respondents to the public consultation think that higher digitalisation would encourage more third country nationals to apply and travel; 11 Member States also mentioned that travel to the Schengen Area would benefit from a higher degree of digitalisation. Whereas O3 would already achieve significant progress towards the digitalisation of the visa procedure, O4 would really mark the transition from a largely paper-based application process to a truly digital and largely harmonised process, which might help attract more visa-required travellers to the EU and therefore generating a potential higher contribution to the EU GDP, with a potential higher impact on the EU GDP under O5. The Schengen Area would thus benefit from a more coherent image vis-à-vis third countries as the traveller vetting processes would conform to the worldwide state of the art: along with ETIAS, the Schengen visa process would be a) relying on advanced digital technologies allowing for fast, secure and seamless interactions; b) applied consistently by all Member States; and c) based on a virtual and secure proof of clearance (digital visa). 7.How do the options compare? To determine the preferred option, the policy options have been assessed and compared in the light of the following criteria: §Effectiveness, i.e. to what extent the option meets the policy objectives; §Efficiency, i.e. the relative weight of the costs and benefits of the option; §Other impacts: -Level of protection of personal data; -Coherence with the Charter of Fundamental Rights of the EU; The table below provides an overview of the result of the options comparison for all criteria. Detailed results on the comparison of policy options are provided in the ‘Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report’. Criteria Option 1 Option 2 Option 3 Option 4 Option 5 To streamline and make more efficient the visa application procedure for applicants and MS through digital means (SO1) 0 1.25 2 2.6 2.8 To increase the security of the Schengen area through the digitalisation of the visa sticker and digitalised application procedures (SO2) 0 1.75 2.0 2.5 -0.5 Impact on the environment 0 0.25 0.75 0.5 0.25 Overall effectiveness 0 1.1 1.6 1.9 0.8 EU-level & Member States 0 1.5 1.7 2.5 1.5 Third country nationals 0 1.5 1.5 2 2.5 Overall efficiency 0 1.5 1.6 2.25 2 Protection of personal data 0 0.5 0.75 1 -0.5 Coherence with Charter of Fundamental Rights 0 0 0 0 -0.5 7.1.Effectiveness Each specific objective under effectiveness was scored from -3 to +3 (-3 indicating the most negative impact, +3 indicating the most positive impact) based on the assessment of the options. The impact on environment was also taken into account in the assessment of the effectiveness. The overall mark for effectiveness was then calculated based on the average of the three sub-criteria. In the assessment of effectiveness, all options are assessed across the sub-criterions in comparison with the baseline scenario (policy option 1). In line with the Better Regulation Guidelines, O1 is considered as the benchmark against which all other options are assessed and scored. Therefore, the value of 0/nil is attributed to the baseline situation for all effectiveness criteria, whereby “0” means no impact compared to the baseline. A positive figure indicates an improvement of the situation in relation to the criterion assessed and a negative one a deterioration of the situation created by the implementation of the option. The marks reflect the assessment of the performance of each option in relation to each criterion. A high gap between two options (i.e. over 0.5 point) reflect substantial differences whereas lower gaps will reflect small discrepancies in the assessment of their performance relating to the criterion. Analysis of results §To streamline and make more efficient the visa application procedure for applicants and MS through digital means (SO1) O1 would contribute only to a very limited extent to these objectives, while O2 would strengthen their achievement by a) making the EU-standards mandatory and b) enabling efficiency gains thanks to the digital visa. O3 to O5 would increasingly simplify and harmonise the process: O3 would do so for repeat applicants in the 17 Member States expected to join the EU visa application platform. With a mandatory EU visa application platform for all Member States, O4 would simplify and harmonise the process in all Member States; and O5 would extend the benefits of O4 to all visa applicants (first time and repeat applicants). §To increase the security of the Schengen area through the digitalisation of the visa sticker and digitalised application procedures (SO2)

O1 would not contribute to these objectives. O2 to O5 would contribute to the same degree as far as the digital visa is concerned; in addition, O3 and O4 would allow Member States to strengthen examination by re-allocating FTEs saved in the administrative process if they choose to do so (with larger effects under O4); while O5 would undermine security by preventing proper correct on-site identification of first-time applicants and repeat applicants using a different travel document. O4 would fully harmonise format and data quality of supporting documents with the use of a single application tool, guaranteeing the same level of authenticity of documents submitted for all applications which would not be the case under O3 as Member States would not be obliged to digitalise their application process. The choice of a hybrid architecture for the EU visa application platform under O4 would also ensure that the storage of applications in national database would avoid the risk of a single point of failure and attack that could jeopardise all stored applications. §Environmental impact O2 would enable saving 38% of the CO2 emitted by third country nationals travelling to consulates/VACs, 50% of the paper needed for visa applications, and all paper used for visa stickers. These savings would also materialise under O3 to O5 (and O5 would save an additional 17% of CO2 emissions in the application process). Regarding the additional emission of CO2 triggered by the increase in travellers, the same considerations as for the impact on GDP apply, as they rely on an additional number of travellers which is difficult to estimate whereas the impact on travels of repeat applicants would materialise for all repeat applicants, whatever the number of visas issued. As the options would gradually result in a slightly increasing number of travellers, the effect in terms of CO2 emissions would also increase even if they might be mitigated by the reduction of fuel emissions in the air transport. With the implementation of the digital visa and of a mandatory single EU visa application platform, O4 would be the option that would endure the highest effectiveness in fulfilling the key objectives of the digitalisation of the visa procedures. 7.2.Efficiency The efficiency (effectiveness in relation to the cost) was scored from -3 to +3 (-3 indicating the most negative impact, +3 indicating the most positive impact) based on the assessment of the options. On the basis of the result of the calculation presented in the table below, a separate score has been assigned to: a) the economic impact at EU-level and Member States; b) the economic impact on third country nationals. The overall efficiency score corresponds to the average of both scores. The table below summarises the different costs and benefits compared with the baseline-option 1 with a quantification for each category of impact (additional cost or benefit compared with the baseline). The calculations have been made with a very slight increase of travellers (due to a “natural” increase of travels not linked to digitalisation). The baseline (16.9 million visas applied for in 2023, corresponding to 2019 pre-COVID level) would increase to 17.3 in 2024 and would stabilise to 17.8 million as from 2025). Beyond this “natural” growth of travellers, an additional increasing factor has been included to reflect a very slight increase of travellers linked to the use of the EU visa application platform (due to a simplified/easier application process) with + 5 % under O3 and O4 (with larger effects under O4 as all Member States would use the platform) and + 7% under O5. Given the difficulty to forecast ex-ante a) the “natural” growth of visa-required travellers and b) the impact of the introduction of a single EU visa application platform (precise quantitative correlation), an assessment of the costs and benefits has been carried out with a stable figure (16.9 million applied for in 2025-2029) in the sensitivity analysis (Annex X). Economic impact Comparison of each option against baseline (Option 1) Option 1 Option 2 Option 3 Option 4 Option 5 GDP contribution (over 2025-2029) EUR 392.3 billion Benefit: 0 Benefit: EUR 8.7 billion Benefit: EUR 19.1 billion Benefit: EUR 38.9 billion EU level No impact Costs EUR 3.5 – 6.4 million spent on technical costs (one-off) EUR 3.5 – 6.0 million spent on technical costs (2025- 2029) Costs EUR 25.7 – 31.3 million spent on technical costs (one-off) EUR 44.5 – 54,4 million spent on technical costs (2025 – 2029) EUR 2.5 million staff costs for eu-LISA to support development Costs EUR 33.8 – 41.2 million spent on technical costs (one-off) EUR 52.5 – 63.9 million spent on technical costs (2025 – 2029) EUR 2.5 million staff costs for eu-LISA to support development Costs EUR 34.0 – 41.5 million spent on technical costs (per year) EUR 52.5 – 64.4 million spent on technical costs (2025 – 2029) EUR 2.5 million staff costs for eu-LISA to support development Member States (aggregate numbers – all Member States) EUR 638.5 million spent on admin burden (2025-2029) 12 699 FTEs needed (2025-2029) Benefits EUR 257 million saved on admin burden & real estate (2025-2029) 4 014 FTEs saved (2025-2029) Costs EUR 30.9 – 37.7 million spent on technical costs (one-off) EUR 27.5 – 33.5 million spent on technical costs (2025 – 2029) Benefits EUR 364.3 million saved on admin burden & real estate (2025-2029) 6 417 FTEs saved (2025-2029) Costs EUR 68.3 – 83.5 million spent on technical costs (one-off) EUR 58.0 million – 70.5 million spent on technical costs (2025 - 2029) Benefits EUR 510.9 million saved on admin burden & real estate (2025-2029) 9 685 FTEs Saved (2025-2029) Costs EUR 68.3 – 83.5 million spent on technical costs (one-off) EUR 58.0 million – 70.5 million spent on technical costs (2025 - 2029) Benefits EUR 521.6 million saved on admin burden & real estate (2025-2029) 9 936 FTEs saved (2025-2029) Third country nationals (aggregate numbers – all third country nationals over 2025-2029) EUR 74 per applicant spent EUR 7.4 billion total spent for all applicants Benefits EUR 31 per applicant saved EUR 2.7 billion saved Benefits EUR 31 per applicant saved EUR 2.7 billion saved Benefits EUR 31 per applicant saved EUR 2.9 billion saved Benefits EUR 72 per applicant saved EUR 6.9 billion saved The impact on GDP, as mentioned above, would very much depend on the “natural” growth of travellers and the impact of the simplification of procedures on the choice of travel destinations for visa-required tourists. The additional contribution to GDP figures must be carefully interpreted in the light of these considerations as they rely on assumptions. On the basis of World Bank data relating to the impact of tourism on GDP, option 3 would lead to 1.1 million extra travellers over the 2025-2029 period and to EUR 8.7 billion extra benefits; option 4 would lead to 3.9 million extra travellers over the 2025-2029 period and to EUR 19.1 billion extra benefits; and option 5 would lead to 8.4 million extra-travellers over the 2025-2029 period and to EUR 38.9 billion extra benefits. For EU institutions and agencies, O2 would entail limited one-off costs at EU level to develop the web service to allow applicants having applied through national portals to check the validity of their visa. O3 to O5 would entail one-off and yearly costs related to developing and maintaining the EU digital application platform: such costs would be slightly higher under O4 compared with O3; and slightly higher under O5 compared to O4. Therefore, O2 would be the least