COMMISSION STAFF WORKING PAPER SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Establishing a Registered Traveller Programme
Date: 2013-02-28
Institutions: European Commission
Subjects: Schengen Information System, biometrics, border control, data collection, exchange of information, external border of the EU, foreign national, traveller

EUROPEAN 
COMMISSION 

Brussels, 28.2.2013  
SWD(2013) 51 final 

COMMISSION STAFF WORKING PAPER 

SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL  

Establishing a Registered Traveller Programme  

{COM(2013) 97} 
{SWD(2013) 50 final} 
{SWD(2013) 52 final}

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COMMISSION STAFF WORKING PAPER 

SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL  

Establishing a Registered Traveller Programme  

1. 

PROBLEM DEFINITION 

According to the most recent comprehensive data provided by the Member States, there were 
669 million external border crossings in 2009, 675 million in 2010 and 700 million in 2011, 
including EU citizens and third-country nationals. Border crossings at the largest and busiest 
border crossing points have been increasing and will continue to do so in the future. Efficient 
and  fluent  management  of  increased  passenger  flows  at  the  external  border  crossing  points 
will be a challenge for majority of Member States. 

EU law requires that systematic checks are carried out at the Schengen external borders on all 
travellers (both on entry and exit). Thorough checks are normally carried out on third-country 
nationals,  and  minimum  checks  on  EU  citizens  and  persons  enjoying  the  right  of  free 
movement1.  However,  current  rules  for  third-country  nationals  could  be  described  as  "one-
size-fits-all" as the same checks apply regardless of any differences in risk between different 
travellers or their frequency of travel.  

Border checks of EU citizens can be automated, based on the current legislation, if they hold 
an e-passport. However, for third-country nationals this cannot be done without changing the 
legal  framework  and  establishing  a  specific  programme  to  facilitate  third-country  nationals' 
border  crossings.  26,5  %  of  travellers  crossing  the  EU  external  borders  are  third-country 
nationals – many of them crossing the border several times per year, even per week. Fluidity 
of border crossings and throughput capacity of border crossing points can be greatly improved 
even if only small percentage of frequent third-country travellers were to join the Registered 
Traveller Programme (RTP).  

The previous impact assessment accompanying the communication preparing the next steps 
in  border  management  in  the  European  Union2  in  2008  suggested  the  establishment  of  a 
Registered Traveller Programme for frequent and pre-vetted third-country national travellers. 
The  Commission's  Communication published  in  2011  discussed  the  various  options  and  the 

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OJ L 158, 30.4.2004. 
SEC(2008) 154, 13.2.2008. 

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way  ahead3.  The  present  impact  assessment  examines  different  implementation  options  in 
order to find the best possible way to implement the RTP. However, the impacts of the whole 
RTP are analysed based on the specific options.  

2. 

ANALYSIS OF SUBSIDIARITY 

Under  Articles  74,  77(2)(b)  and  77(2)(d)  of  the  Treaty  on  the  Functioning  of  the  European 
Union,  the  Union  has  the  power  to  adopt  measures  relating  to  checks  on  persons  and  the 
efficient monitoring of the crossing of external borders.  

The need for intervention at European level is clear. No Member State alone is able to build 
up  an  RTP  providing  facilitated  border  checks  across  the  Schengen  Member  States.  One 
individual Member State's decision to grant access to an EU-wide RTP would have an impact 
on all Schengen countries and must therefore be regulated at EU level. Any measures related 
to border control would have to apply to the Schengen area without internal border controls 
which  currently  includes  all  the  Member  States  except  Romania,  Bulgaria,  Cyprus,  UK  and 
Ireland and four other European countries (Norway, Iceland, Switzerland and Liechtenstein). 
Schengen  states  are  committed  to  maintaining  common  EU  borders  and  common  standards 
for  border  controls.  Checks  are  carried  out  only  at  the  external  border,  after  which  the 
traveller can travel freely within the Schengen area. It is vital for the internal security of the 
Schengen area that all the binding rules linked to border control are decided at EU level.  

Therefore, the objectives cannot be sufficiently achieved by the Member States acting alone 
but can be better achieved at EU level.  

EU added value 

The  RTP  needs  to  be  implemented  at  all  EU  external  border  crossing  points  and  will  have 
implications  on  the  border  guard  resources  of  all  Schengen  countries.  The  EU-RTP  ensures 
that  the  EU  has  a  common  approach  to  the  RTP  based  on  common  legislation  and  thus  it 
guarantees  that  rules  continue  to  be  the  same  at  all  Schengen  borders.  For  third-country 
national  travellers,  this  means  that  the  RTP  is  available  to  them  at  all  Schengen  border 
crossing  points  without  separate  vetting  by  another  Schengen  country.  In  other  words,  a 
person vetted by one Member State may benefit from facilitation when crossing the external 
borders of any other Member State. Without common rules this would not be possible.  

3. 

OBJECTIVES OF EU INITIATIVE 

The general objectives of the RTP are: 

•  To facilitate the crossing of EU external borders by third-country nationals; 

•  To maintain the current level of security. 

The specific objectives are: 

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COM(2011)680 final. 

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•  To promote access to the RTP for certain categories of frequent, pre-vetted third-country 

nationals; 

•  To ensure protection of RT's fundamental rights, in particular their personal data; 

•  To avoid discrimination between different groups of travellers. 

The operational objectives are: 

•  To decrease the time and costs of border crossings for frequent travellers and to increase 
the  throughput  capacity  of  border  crossing  points.  Border  checks  of  RTs  should  not  take 
more than 20-40 seconds on average.  

•  To  free  up  border  control  resources  by  25%  from  checking  cross  border  movements  of 
frequent  and  pre-vetted  travellers  and  to  enable  better  focus  on  checking  higher  risk 
travellers4 and/or serve other travellers. 

4. 

POLICY OPTIONS 

Five  policy  options  linked  to  the  implementation  of  the  RTP  were  identified  during  the 
consultation  with  stakeholders.  For  each  of  these  five  policy  options  real  practical 
implementation  options  have  been  defined.  As  regards  the  Policy  option  1  "lodging  an 
application for an RTP", the best sub-option is so clear and evident that lodging an application 
at  any  external  border  crossing  point  and  at  any  Member  States  consulate  was  selected 
without further analysis. The other four policy options and their sub-options are the following: 

4 

Travellers who have decided not to join the RTP are not and shall not be considered, due to their non-
participation in the RTP, as higher risk travellers.  

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4.1. 

Policy option 2: Data storage 

4.1.1.  An RTP based on data stored in a separate token5 (sub-option 2a) 

4.1.2.  An RTP based on data stored in a centralised database (sub-option 2b) 

4.1.3.  An RTP based on data stored in a separate token combined with a repository (sub-

option 2c) 

4.2. 

Policy option 3: Vetting criteria 

4.2.1 

Same as for multiple-entry visa holders (based on current EU law) (sub-option 3a) 

4.2.2  More thorough vetting with additional criteria (sub-option 3b) 

4.2.3  Discarded sub-option: Involvement of third countries in the vetting (sub-option 3c) 

4.3. 

Policy option 4: Automation of border control for Registered Travellers 

4.3.1.  Fully automated (sub-option 4a) 

4.3.2. 

Semi-automated (sub-option 4b) 

4.4. 

Policy option 5: Application fee 

4.4.1 

Fee of 20 EUR (sub-option 5a) 

4.4.2  No fee (sub-option 5b) 

5. 

ASSESSMENT OF IMPACTS 

Table 1 – Assessment of policy options*)  

Policy options and sub-options 

To  facilitate  the  crossing 
of EU external borders by 
third-country nationals 

To  maintain 
current 
security 

the 
level  of 

Costs  

Protection 
of 
fundamental rights 

Option 0 

Baseline 

Option 2 

Data stored in a token (2a) 

Data stored in a centralised database (2b) 

Data  (unique  identifier  number)  stored  in  a 
token  and  (unique  identifier,  biometrics  and 
data from application) in a central repository 
(2c) 

0 

0 

0 

0 

√√√ 

√√√√ 

√√√ 

√√ 

√√√ 

√√√ 

-√√ 

-√√ 

-√√√ 

-√ 

-√√√ 

-√ 

5 

In the context of a RTP, a token can be described as a physical device given to the authorised user to 
prove his/her identity electronically. The token acts like an electronic key to access something, in this 
case to the ABC system. 

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Options 3 and 4**) 

Same  vetting  as  for  multiple-entry  visa 
holders, fully automated border crossing 

√√√√ 

Same  vetting  as  for  multiple-entry  visa 
holders, semi-automated border crossing  

thorough  vetting,  fully  automated 

More 
border crossing  

thorough  vetting,  semi-automated 

More 
border crossing  

Option 5 

Application fee 20/10 euro (5a)  

No application fee (5b) 

√ 

√√√ 

√ 

√√ 

√√√ 

√ 

√√ 

√√ 

-√ 

-√ 

-√√ 

√√√ 

-√√√ 

- 

- 

0 

-√√√ 

0 

0 

-√√ 

-√√ 

- 

- 

*) The three sub-options of policy option 1 (lodging an application for an RTP) are not included in the table 1 as the best choice is already 
described at the beginning of chapter 4. 

**) the impacts of sub-options with regard to the policy options 3 and 4 (vetting criteria and automation of border control) are directly linked, 
in the sense that the impact of the sub-options with regard to vetting cannot be assessed without knowing which is the preferred option with 
regard to automation, and vice versa. Consequently the available four sub-options (3a, 3b, 4a, 4b) from the two policy options have been 
combined into the four variations possible, and the impact of all four variations is assessed in an integrated way. 

6. 

COMPARISON OF OPTIONS 

Data storage 

All three sub-options contribute significantly to the objectives as defined and are notably fully 
coherent  with  EU  border  policy:  security  and  prevention  of  irregular  immigration  is  not 
diminished during the border crossing, while the EU's openness to the world and its capacity 
to  facilitate  cross-border  people-to-people  contacts,  trade  and  cultural  exchange  is  boosted. 
The programme would be the first in the world which is open to all third countries, and which 
is operable across several states, in this case across the whole Schengen area. In this context, 
Europe can be seen as a pacesetter for the rest of the world.  

The token-based sub-option allows for visibility and limits data protection concerns. The sub-
option based on a centralised RTP is more secure and easier to implement in practice at the 
border crossing point. The latter is, however, counterbalanced by the need to develop a new 
centralised system in which all the data is available and subject to search.  

The sub-option based on a token/central repository can be seen as a hybrid between the above 
two sub-options, combining their respective advantages. It minimises the use of personal data 
in an EU system and it avoids the main of the security drawbacks of the token-based system. 
It provides, however, for the most complicated integration into the border control process as it 
introduces both a verification of the token as well as a verification against a central repository. 

Vetting criteria and automation of border control 

The assessment showed that stricter vetting procedure does not have any real impact on the 
security of the border check itself, and also that the facilitation of border crossings of semi-
automated  border  controls  is  too  limited  to  bring  added  value.  Furthermore,  stricter  vetting 

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procedure would increase significantly Member States' administrative costs and would have a 
significant effect on the protection of fundamental rights. 

Application fee 

By  introducing  a  fee  of  20  EUR,  Member  States  administrative  costs  for  examining 
applications  would  be  neutralised.  It  would  also  be  consistent  with  the  approach  chosen  for 
the treatment of visa  applications. However, no fee sub-option  would better guarantee  large 
number  of  participants  in  the  programme.  Downside  of  this  option  would  be  that  many 
ineligible applications would be submitted.  

7. 

PREFERRED OPTION  

Lodging an application for an RTP 

For policy option 1 it is clear that allowing the traveller to choose the best place for him/her 
to  lodge  an  application  would  guarantee  a  larger  number  of  participants  in  the  programme, 
thus helping Member States to manage their passenger flows at the external border crossing 
points. Therefore, the preferred sub-option is lodging an application for an RTP at any border 
crossing point and at any Member States consulate. The cost-effectiveness of this sub-option 
is clearly the best and it is fully coherent with existing border and visa policy. 

Data storage 

To  identify  the  preferred  option  with  regard  to  policy  option  2  is  more  complex  as 
demonstrated in chapter 6. The total scoring of each sub-option in relation to policy option 2 
is almost equal, but each sub-option displays distinctly different weaknesses: the token-based 
sub-option  displays  significant  security  issues,  the  central  database  sub-option  displays 
significant  fundamental  rights  issues,  and  the  token/central  repository  sub-option  significant 
cost issues. However, the cost benefit analysis shows that even the higher one-time costs and 
yearly operational costs of the token/central repository sub-option will be fully compensated 
in the long run by the economic benefits of the RTP as a whole for the Member States. This is 
therefore the preferred sub-option with regard to policy option 2. This sub-option provides for 
a proportionate balance between security, facilitation and data protection. The data stored in a 
central  repository  would  be  available  for  border  guards  only  when  assessing  application, 
renewing/revoking access to the RTP, in case the token is lost or stolen or any problems occur 
with facilitating RTs border crossings. While performing border checks a border guard would 
receive only hit/no hit information. With this option "privacy by design" is implemented. 

Vetting criteria and automation 

For  policy  options  3  and  4  it  is  clear  that  the  total  impact  of  combining  the  same  vetting 
criteria as for multiple-entry visas with fully automated border control has the highest impact 
on  facilitating  RTs'  border  crossings.  Furthermore,  it  offers  a  balanced  approach  to  security 
and  protection  of  fundamental  rights.  It  is  also  the  least  expensive  approach  taking  into 
account  the  costs  associated  with  stricter  vetting  procedure  and  semi-automated  border 
control.  

It should however be noted that the implementation of fully automated border control requires 
that an Entry/Exit System is developed and implemented in parallel, which would allow for 

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replacing the stamping obligation with an electronic registering of entry and exit dates of all 
travellers including those having an RT membership. 

Application fee 

For  policy  option  5  it  is  reasonable  to  accompany  the  RTP  with  a  fee  of  20/10  EUR  that 
would cover the administrative costs of examining applications, which would be set at a level 
that should not discourage potential applicants.  

In summary, the preferred option consists of 

•  The lodging of applications at consulates as well as border crossing points; 

•  The combination of a token and a centralised storage of anonymized biometric data of each 

applicant and the data from an application; 

•  Applying the same vetting criteria as currently defined in EU law for multiple-entry visas; 

•  Giving RT access to a fully automated border control process; 

•  Charging a fee of 20 euro per RT application. However, a reduced fee (10 euro) would be 
introduced in case a visa application and an RTP application are examined at the same time 
based on the same supporting documents. 

The  preferred  option  shall  fully  comply  with  the  relevant  legislation  on  the  protection  of 
personal  data,  in  particular  the  data  protection  principles  and  the  requirements  of  necessity, 
proportionality,  purpose  limitation  and  quality  of  data;  and  that  safeguards  and  mechanisms 
are in place for the effective protection of the fundamental rights of the individual travellers 
and  in  particular  the  protection  of  their  private  life  and  their  personal  data.  Staff  and  third-
country nationals must be made aware of these rights. 

Costs and financial support 

The  estimated  total  one-time  costs  of  the  preferred  option  of  the  RTP  for  the  Agency  to 
develop  a  centralised  part  would  be  43  million  EUR,  spread  out  over  2-3  years  and  annual 
average  costs  for  maintenance/operations  would  be  20  million  EUR/annum.  The  total  one-
time  costs  for  Member  States  to  develop  and  set-up  their  national  infrastructures  would  be 
164  million  EUR,  spread  out  over  2-3  years  and  annual  average  costs 
for 
maintenance/operations would be 81 million EUR/annum. The above-mentioned costs include 
also  administrative  costs  except  the  costs  for  examining  the  applications.  The  costs  of 
automation  would  greatly  vary  depending  on  the  number  of  automated  gates  that  would  be 
implemented.  

The  personnel  and  the  investment  costs  for  establishing  and  maintaining  the  RTP  would  be 
compensated within a reasonable timeframe in the form of released personnel resources and a 
lower unit price per border check.  

The Commission's proposal for the next multi-annual financial framework (MFF) includes a 
proposal of 4,6 billion EUR for the Internal security Fund (ISF) for the period 2014-2020. In 
the proposal, 1,1 billion EUR is set aside as an indicative amount for the development of an 
EES and an RTP assuming development costs would only start from 2015. Moreover, outside 
the sope of the ISF, a separate amount of EUR 822 million is set aside for the management of 

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existing  large  scale-IT  systems  (Schengen  Information  System  II,  Visa  Information  System 
and EURODAC).6 The Commission envisages entrusting the implementation tasks for these 
systems  to  the  Agency.  Providing  financial  support  for  national  development  costs  would 
ensure that difficult economic circumstances at national level do not jeopardise or delay the 
projects.  

For  third  countries,  no  costs  would  be  incurred  in  the  implementation  of  the  RTP.  After 
possible adoption of the RTP, third countries will be informed accordingly of the facilitation 
mechanism and that their citizens could apply for access to the RTP. 

8. 

MONITORING AND EVALUATION 

The Management Authority (the Agency) shall ensure that systems are in place to monitor the 
functioning of the RTP against the main policy objectives. Furthermore, the Commission shall 
produce  an  overall  evaluation  of  the  RTP.  The  impact  assessment  indicates  potential 
indicators  to  monitor  the  extent  to  which  the  policy  objectives  have  been  met.  The  main 
information sources are the RTP repository and ABC systems. 

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