COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EC) No 810/2009 establishing a Community Code on Visas (Visa Code)
Date: 2018-03-14
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, Schengen Agreement, external border of the EU, foreign national, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.3.2018  SWD(2018) 77 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EC) No 810/2009 establishing a Community Code on Visas  (Visa Code) {COM(2018) 252 final} - {SWD(2018) 78 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

6 

1.1.  EU common visa policy .................................................................................. 6 
1.2.  Legislative package 2014 ................................................................................ 7 
1.3.  Broader policy context .................................................................................... 8 
1.4.  Consequences for the common visa policy ..................................................... 9 
1.5.  Scope of the initiative .................................................................................... 10 

2. 

PROBLEM DEFINITION ................................................................................................................ 12 

2.1.  What are the problems? ................................................................................. 12 
Insufficient financial resources to support visa processing .................................. 12 
2.1.1. 

2.1.2. 

Repeated visa procedures for regular travellers ................................................... 13 

2.1.3. 
origin 

Insufficient levels of return of irregular migrants to some countries of 
 .............................................................................................................................. 16 

2.2.  What are the problem drivers? ...................................................................... 17 
Insufficient financial resources ............................................................................ 17 
2.2.1. 

2.2.2. 

Repeated visa procedures ..................................................................................... 18 

2.2.3. 

Return of irregular migrants ................................................................................. 19 

2.3.  How will the problem evolve? ...................................................................... 20 
Insufficient financial resources ............................................................................ 20 
2.3.1. 

2.3.2. 

Repeated visa procedures ..................................................................................... 20 

2.3.3. 

Return of irregular migrants ................................................................................. 21 

3.  WHY SHOULD THE EU ACT? ...................................................................................................... 21 

3.1.  Legal basis ..................................................................................................... 21 
3.2.  Subsidiarity: Necessity of EU action ............................................................. 21 
3.3.  Subsidiarity: Added value of EU action ........................................................ 22 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................. 22 

4.1.  General objectives ......................................................................................... 22 
4.2.  Specific objectives ......................................................................................... 23 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................. 23 

5.1.  What is the baseline from which options are assessed? ................................ 23 
Insufficient financial resources ............................................................................ 23 
5.1.1. 

5.1.2. 

Repeated visa procedures ..................................................................................... 23 

5.1.3. 

Return of irregular migrants ................................................................................. 23 

5.2.  Description of the policy options .................................................................. 24 
Insufficient financial resources ............................................................................ 24 
5.2.1. 

5.2.2. 

Repeated visa procedures ..................................................................................... 25 

2 

 
 
5.2.3. 

Return of irregular migrants ................................................................................. 26 

5.3.  Options discarded at an early stage ............................................................... 27 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ......................................................... 28 

6.1.  Methodology .................................................................................................. 28 
Possible impacts ................................................................................................... 28 
6.1.1. 

6.1.2. 

Available data ....................................................................................................... 30 

6.1.3. 

Qualitative assessment method ............................................................................ 31 

6.2.  Assessment of policy options ........................................................................ 32 
Insufficient financial resources ............................................................................ 32 
6.2.1. 

6.2.2. 

Repeated visa procedures ..................................................................................... 35 

6.2.3. 

Return of irregular migrants ................................................................................. 37 

6.3.  Sensitivity analysis ........................................................................................ 40 

7.  HOW DO THE OPTIONS COMPARE? .......................................................................................... 40 

7.1. 
Insufficient financial resources ...................................................................... 40 
7.2.  Repeated visa procedures .............................................................................. 42 
7.3.  Return of irregular migrants .......................................................................... 43 

8. 

PREFERRED OPTIONS .................................................................................................................. 44 

Insufficient financial resources ...................................................................... 44 
8.1. 
8.2.  Repeated visa procedures .............................................................................. 44 
8.3.  Return of irregular migrants .......................................................................... 44 
8.4.  REFIT (simplification and improved efficiency) .......................................... 45 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ................................ 45 

ANNEX 1: PROCEDURAL INFORMATION .......................................................................................... 47 

ANNEX 2: STAKEHOLDER CONSULTATION ..................................................................................... 49 

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................ 62 

ANNEX 4: UPDATE ON THE IMPLEMENTATION OF THE VISA CODE ......................................... 65 

ANNEX 5: VISA FEE ................................................................................................................................ 76 

ANNEX 6: INBOUND TOURISM TO THE EU/SCHENGEN COUNTRIES ......................................... 85 

ANNEX 7: ELEMENTS CARRIED OVER FROM THE 2014 PROPOSAL ........................................... 87 

ANNEX 8: SENSITIVITY ANALYSIS OF MCA .................................................................................... 89 

3 

 
Glossary 

Term or acronym 

Meaning or definition 

EES 

ESP 

ETIAS 

eu-LISA 

LSC 

MEV  

MEV cascade 

Schengen evaluation 

Schengen States  

SEV 

service fee 

SIS 

TCN 

TFEU 

VAC 

VFA 

VIS 

Entry-Exit System  

external service provider (contracted by Member States to assist 
consulates with certain tasks in the visa application procedure, 
notably the collection of applications, of the visa fee and of 
biometric identifiers as well as the return of travel documents to visa 
applicants) 

European Travel Information and Authorisation System  

European Agency for the operational management of large-scale IT 
systems in the area of freedom, security and justice 

Local Schengen Cooperation (regular meetings of Member States' 
consuls in a certain location, chaired by EU Delegation) 

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) 

agreed approach of how many previous visas/trips the applicant has 
to prove to qualify for a long-validity MEV and how the length of 
validity for each subsequent visa would increase 

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 

EU Member States applying the common visa policy in full (all EU 
Member States with the exception of Bulgaria, Croatia, Cyprus, 
Ireland, Romania and the United Kingdom) as well as the Schengen 
associated countries: Iceland, Liechtenstein, Norway and 
Switzerland 

single-entry visa 

fee paid to the ESP for collecting the application and biometric 
identifiers 

Schengen Information System 

third-country national  

Treaty on the Functioning of the European Union 

visa application centre (operated by an ESP) 

Visa Facilitation Agreement 

Visa Information System (database of all visa applications and 
decisions on those applications, including photograph and 
fingerprints of applicants) 

4 

 
 
 
visa 

visa fee 

VIS Regulation 

Visa Code 

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) 

fee paid to the consulate for processing the visa application 

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) 

Regulation (EC) No 810/2009 of the European Parliament and the 
Council of 13 July 2009 establishing a Community Code on Visas 
(Visa Code) 

Visa Code recast proposal 

2014 proposal to recast the Visa Code (COM(2014) 164 final) 

Visa Regulation 

Council Regulation (EC) No 539/2001 of 15 March 2001 listing the 
third countries whose nationals must be in possession of visas when 
crossing the external borders and those whose nationals are exempt 
from that requirement 

VWA 

Visa Waiver Agreement 

2014 Impact Assessment 

Impact Assessment accompanying the Visa Code recast proposal 
(SWD(2014) 68 final) 

5 

 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

EU common visa policy 

The  abolition  of  checks  at  internal  borders  of  the  states  forming  part  of  the  Schengen 
area is one of the most valued achievements of EU integration. The common visa policy 
for  short-stay  visas  is  one  of  the  Schengen  area's  "flanking  measures"  (together  with 
the  harmonisation  of  the  external  border  controls,  enhanced  cross-border  police 
cooperation, and the creation of the Schengen Information System (SIS)) accompanying 
the establishment of a common area without checks at internal borders. 

The  visa  policy  serves  various  objectives, 
irregular 
immigration  as  well  as  safeguarding  public  order  and  security.  In  general  a  visa 
requirement is accepted worldwide as a tool for countries (or groups of countries such 
as  the  EU)  to  tackle  different  kinds  of  migration  and  security  risks.  That  is  the  reason 
why the EU will maintain visa requirements for citizens of a number of third countries.  

in  particular  preventing 

At the same time the visa policy also aims at facilitating travel to the EU for legitimate  
and  bona  fide  travellers,  notably  by  exempting  nationals  of  countries  with  lower 
migratory  or  security  risks  from  the  visa  requirement  and  by  easing  visa  procedures 
wherever possible. In that respect the visa policy also plays a role in supporting tourism 
and trade, and thus boosting growth in the EU. 

The common visa policy is a set of harmonised rules governing different aspects1: 

 

 

the  Visa  Regulation  (539/2001)  laying  down  the  common  "visa  lists"  of 
countries  whose  nationals  require  a  visa  to  travel  to  the  EU  and  those  who  are 
exempt from that requirement; 
the  Visa  Code  (Regulation  810/2009)  establishing 
conditions for issuing short-stay visas; 

the  procedures  and 

  Regulation 1683/95 laying down a uniform format for the visa sticker; and  
 

the VIS Regulation (767/2008) setting up the Visa Information System (VIS), in 
which all visa applications and Member States' decisions are recorded, including 
applicants personal data, photographs and fingerprints. 

Moreover  the  EU  has  concluded  a  number  of  Visa  Facilitation  Agreements  (VFA)  and 
Visa Waiver Agreements (VWA) with third countries which implement or derogate from 
those common rules.   

This set of rules allows the Schengen States to mutually recognise visas issued by each 
of  them.  The  decision  to  issue  a  visa  is  a  decision  taken  by  national  authorities,  which 
should  take  into  account  not  only  their  own  interest  but  that  of  all  Schengen  States. 

1  

Not all of these regulations are applied equally by all EU Member States. The visa policy is part of 
the Schengen acquis and therefore does not apply to the United Kingdom and Ireland; it does apply 
to Schengen associated countries (Iceland, Liechtenstein, Norway and Switzerland). While the Visa 
Regulation applies to all Member States, the Visa Code and the VIS Regulation only apply to the 
Member States fully applying the Schengen acquis 

6 

 
                                                            
Therefore,  the  holder  of  a  visa  issued  by  Schengen  States'  individual  consulates,  as  a 
general rule, is entitled to circulate in the entire Schengen area.  

Visas are in principle not issued at the external borders or within the Schengen area but 
visa  applications  have  to  be  lodged  before  travelling  to  the  EU  at  one  of  the  Member 
States' consulates in third countries. Rules of competence define which Member State 
is entitled to examine and decide those applications, namely the Member State which is 
the applicant's only or main destination.  

1.2. 

Legislative package 2014  

The Visa  Code is  a  core element of the common visa policy:  it establishes  harmonised 
procedures and conditions for processing visa applications and issuing visas. It entered 
into  force  on  5  April  2010,  with  the  overarching  objectives  of  facilitating  legitimate 
travel  and  tackling  irregular  immigration,  enhancing  transparency  and  legal  certainty, 
strengthening procedural guarantees and reinforcing equal treatment of visa applicants.  

The  Visa  Code  required  the  Commission  to  submit  the  European  Parliament  and  the 
Council  an  evaluation  of  its  application  two  years  after  all  the  provisions  of  the 
Regulation have become applicable2. On the basis of that evaluation, an in-depth impact 
assessment was carried out, focussing on three broad problem areas:  

1.  the lengthy, costly and cumbersome nature of visa procedures for applicants; 
2.  the insufficient geographical coverage in visa processing; 
3.  the lack of a visa allowing travellers to stay more than 90 days in the Schengen 

area. 

On  1  April  2014  the  Commission  adopted  two  legislative  proposals:  the  Visa  Code 
recast  proposal3  addressing  the  first  two  problem  areas  and  the  touring  visa  proposal4 
addressing the third one. The overall aims of this package were to foster travel to the EU 
through  facilitations  in  the  visa  policy  –  and  thereby  to  contribute  to  tourism,  trade, 
growth  and  employment in  the EU  – and  to  harmonise  implementation  of the common 
rules.  

As  regards  the  visa  procedures,  the  Visa  Code  recast  proposal  included  a  number  of 
substantial facilitations for applicants: longer timeframe to lodge an application, abolition 
of  the  requirement  to  present  a  travel  medical  insurance,  shorter  decision  deadlines  as 
well as less documentation and easier access to multiple-entry visas (MEV) for frequent 
travellers.  Some  of  those  facilitations  were  largely  accepted  by  the  co-legislators  while 
others were watered down or rejected in the course of negotiations by the co-legislators.  

As  regards  the  geographical  coverage  the  Commission  proposed  that  the  Member 
State(s)  present  in  one  location  would  mandatorily  represent  all  Member  States  not 
present,  if  no  representation  agreements  were  entered  into.  This  proposal,  while 

2  

3  
4  

The provisions on notification of a visa refusal and its grounds and on providing an appeal 
procedure against a visa refusal became applicable on 5 April 2011. 
COM(2014) 164 final. 
COM(2014) 163 final. 

7 

 
                                                            
supported by the European Parliament, was widely rejected by Member States, arguing 
that  it  would  put  disproportionate  burden  on  Member  States  with  a  large  consular 
network while other Member States would be tempted to close smaller consular sections 
relying on others. In the meantime the number of representation agreements (voluntarily) 
concluded between Member States has further increased and Member States have opened 
visa application centres (VAC) in locations where they were not present.5 Therefore this 
problem  is  less  pressing  today  than  it  was  in  2014,  and  will  not  be  dealt  with  in  this 
impact assessment. 

Negotiations between the European Parliament and the Council on the Visa Code recast 
proposal  ended  in  a  deadlock  by  end  2016.  On  the  one  hand,  the  Council  generally 
maintained a very restrictive approach during the negotiations by rejecting essential parts 
intended to modernise and facilitate the visa application procedure whereas the European 
Parliament was overall quite supportive of the Commission's proposal with regard to the 
procedural  facilitations.  On  the  other  hand  and  more  importantly,  both  institutions 
presented  amendments  that  went  far  beyond  the  Commission's  proposal:  the  Council 
introduced  a  link  between  third  countries'  cooperation  on  readmission  and  visa 
facilitation, while the EP proposed to create a "humanitarian visa" in the Visa Code. This 
latter suggestion was opposed by both the Council and the Commission as the Visa Code 
covers visas for short stays only, a position which was confirmed by the ECJ ruling of 7 
March  2017.6  This  stalemate  blocked  all  further  attempts  to  make  progress,  prompting 
the  Commission  to  announce  withdrawal  of  the  proposal  in  the  Commission  Work 
programme for 20187.  

As regards the lack of a visa for longer stays, the Commission's touring visa proposal 
was  meant  to  fill  the  legal  gap  between  short-stay  visas  and  long-stay  residence  and 
encountered  support  in  the  European  Parliament  and  some  Member  States,  but  did  not 
gather  a  qualified  majority  in  Council.  Some  Member  States  rejected  the  proposal, 
expressing  doubts  about  its  necessity  and  legal  basis  and  fearing  possible  abuse.  The 
Commission  has  therefore  also  announced  the  withdrawal  of  the  proposal  in  the 
Commission Work Programme for 2018, as there currently does not seem to be sufficient 
political willingness to address the problem.  

1.3. 

Broader policy context 

In the past four years (since the Commission proposed the Visa Code recast), the EU has 
experienced unprecedented levels of refugees and irregular migration into the EU and 
increased threats to its internal security, including a number of terror attacks. This led 
the EU to launch a fundamental overhaul of its migration and security policies. Many of 

5  

6  
7 

the number of "blank spots" (the number of instances where a Member State is neither present nor 
represented in a visa-required country and where an applicant therefore has to travel abroad to 
lodge a visa application) has decreased from approximately 900 in 2014 to around 750 in early 
2018, so that about 150 "blank spots" were "filled" in the meantime. (Those numbers include the 12 
visa-required countries worldwide where no Member State is present or represented, amounting to 
312 blank spots alone.).  
Case C-638/16 PPU. 
 COM(2017) 650 final, 24.10.2017, annex IV. 

8 

 
                                                            
these  new  initiatives  have  been  successfully  adopted  or  implemented  and  others  are 
currently in the legislative procedure.  

As a result the EU information systems for border management and security have been 
considerably  strengthened  and  new  ones  are  being  developed.  In  particular  the  co-
legislators have decided to introduce an Entry-Exit System (EES)8 to better manage and 
facilitate  third-country  nationals'  crossing  the  Schengen  area's  external  borders.  Among 
other  objectives,  it  will  allow  Member  States  to  monitor  irregular  stays  in  the  EU  and 
identify overstayers. This will contribute to strengthening the common visa policy, as it 
will enable consulates to better assess applicants' lawful use of previous visas.  

The  Commission  also  proposed  a  European  Travel  Information  and  Authorisation 
System (ETIAS)9 which will screen visa-exempt third-country nationals against security 
and migration risks before they start their travel to the EU. This initiative is expected to 
be adopted in the coming months. Contrary to the current visa application procedure, this 
check will entirely rely on digital solutions, notably allowing applicants to apply online 
at an EU portal.  
Finally the Commission has recently adopted the so-called interoperability proposal10 to 
better  link  the  various  EU  information  systems  for  security,  border  and  migration 
management and improve their use by border guards, migration and asylum officials and 
police officers to ensure they have the right information at the right time.  

In  the  past  years  the  EU  also  stepped  up  its  activities  to  support  Member  States  in 
returning irregular migrants to their countries of origin, including by overcoming third 
countries' reluctance to cooperate with Member States in readmitting their own citizens. 
The 2015 Action Plan on Return11 called for all relevant policies to be used as incentives 
for  the  partner  country's  willingness  to  cooperate  on  readmission,  and  for  further 
exploration  of  visa  policy  as  an  important  leverage  in  that  context.  In  June  2016  the 
Commission adopted the Partnership Framework Communication12 in which it stated that 
the  visa  policy  can  be  a  very  powerful  element  in  the  discussions  with  third  countries 
about  cooperation  on  migration.  The  European  Council  conclusions  of  22  and  23  June 
2017 called for further efforts to achieve real progress in return and readmission policy, 
using all possible levers, including by reassessing visa policy towards third countries. 

1.4. 

Consequences for the common visa policy 

In the last years, apart from the strengthening of the visa waiver suspension mechanism 
(allowing the EU to react quickly to substantial increases of migratory or security risks 
resulting from visa-free travel by temporarily suspending the visa exemption for one or 
several  nationalities)  and  the  exemption  from  the  visa  requirement  to  the  citizens  of 
certain third countries, the common visa policy has not been subject to a fundamental 
review or overhaul.  

8  

9  
10  
11 
12 

Regulation (EU) 2017/2226 of the European Parliament and of the Council of 30 November 2017, 
OJ L 327, 9.12.2017, p. 20. 
COM(2016) 731 final, 16.11.2016. 
COM(2017) 793 final, 12.12.2017. 
COM(2015) 453 final, 9.9.2015. 
COM(2016) 385 final, 7.6.2016. 

9 

 
                                                            
The  overall  integrity  of  the  visa  processing  by  Member  States  has  not  been 
fundamentally  called  in  question  in  the  past  few  years.  Yet  there  is  a  growing  need  to 
ensure that visa policy matches the present and future challenges and can make a more 
important contribution to the objectives of the EU's migration and security policies. The 
Commission,  in  its  Communication  on  the  Delivery  of  the  European  Agenda  on 
Migration13, announced that it would come forward with its ideas on how to modernise 
the EU's common visa policy for both the short and longer term. The main objectives of 
this review are to bring the visa policy up to speed with the development of new border 
management systems, to better use visa policy in its cooperation with third countries, and 
to  ensure  a  better  balance  between  migration  and  security  concerns,  economic 
considerations and general external relations.   

The  Commission  Work  Programme  201814  confirmed  the  Commission's  intention  to 
withdraw  the  current  Visa  Code  recast  and  touring  visa  proposals  and  to  propose  a 
targeted  revision  of  the  Visa  Code.  The  further  development  of  the  Visa  Information 
System (VIS) and the alignment of the visa policy's legal framework with developments 
on border management instruments and interoperability objectives will be the subject of a 
separate proposal and impact assessment.15  

1.5. 

Scope of the initiative 

While migration and security related objectives have become more important than in the 
past, one should not lose sight of the fact that the vast majority of visa applicants are not 
posing any security and/or migratory threat to the EU. Some of the elements of the first 
problem area (linked to the visa procedure) tackled by the recast proposal and the 2014 
Impact  Assessment  remain  valid  in  the  current  migratory  and  security  context.  The 
stakeholder  and  open  public  consultations  carried  out  for  this  Impact  Assessment  have 
confirmed the importance of those issues for stakeholders and visa applicants.16  

The targeted revision of the Visa Code will have a twofold purpose: 

1.  Firstly  it  should  preserve  some  of  the  elements  of  the  2014  recast  proposal 
which  remain  relevant  in  the  current  context  and  on  which  compromise  seems 
possible. 17 These elements are either linked to the facilitation of visa procedures 
or  to  clarification  and  streamlining  of  existing  provisions.  Most  of  them 
concern rather procedural matters which do not leave much room for considering 
different policy options and do therefore not need to be examined in detail in this 
impact  assessment.  The  items  that  will  be  carried  over  are  listed  in  annex  7, 
together  with  a  short  description  of  their  expected  impacts  as  well  as  their 
potential  for  simplification  and  cost  reduction.  The  most  important  element  of 
facilitation in the 2014 proposal was the proposed rules on the increased issuing 

13  
14  
15  

16  
17 

COM(2017) 558 final, 27.9.2017. 
COM(2017) 650 final, 24.10.2017. 
This initiative will require a revision of the VIS Regulation and some aspects of the Visa Code 
which relate to the use of the VIS by consulates. 
See summary of the consultations in annex 2.  
Some of the provisions from the original proposal will be amended to take account of positions 
expressed in the negotiations between the co-legislators. 

10 

 
                                                            
of  multiple-entry  visas  with  long  validity  to  regular  travellers.  As  different 
approaches are possible and were discussed during the legislative procedure and 
the  stakeholder  consultations,  it  is  useful  to  examine  the  problem  and  different 
policy options in a more detailed analysis in this report.  

2.  Secondly it should address new elements that have come up in the negotiations 
between  the  co-legislators  on  the  Visa  Code  recast  proposal  and  have  been 
highlighted in the Commission's Communication on the Delivery of the European 
Agenda  on  Migration  as  well  as  in  the  consultations  carried  out  by  the 
Commission.  This  concerns  the  amount  of  the  visa  fee  and  the  financing  of 
Member  States'  visa  processing  activities,  as  well  as  the  question  of 
establishing a legal link between visa policy and third countries' cooperation 
on readmission of irregular migrants.  

This Impact Assessment report will therefore focus on the following problem areas: 

 

 

 

the  need  for  sufficient  financial  resources  to  support  Member  States'  visa 
processing;  
the divergent practices among Member States in issuing multiple-entry visas and 
the resulting repeated visa procedures for regular travellers; 
the role that visa policy can play as leverage in the EU's readmission policy. 

The third area differs from the two others in that the source of the problem originates in 
the area of return, and not in visa policy, and the affected groups and stakeholders as well 
as the consequences of the problem are very different. Nevertheless the two policy areas 
both have a strong external relations dimension and can be considered as foreign policy 
tools.  A  link  can  be  established  to  obtain  better  leverage  vis-à-vis  third  countries,  as 
shown  below  in  the  baseline  scenario  (section  5.1.3)  and  the  policy  options  (section 
5.2.3). 

A number of issues raised in the stakeholder consultation (or the 2014 evaluation) are not 
addressed  in  this  report,  such  as  the  use  and  monitoring  of  external  service  providers 
(ESP), new IT solutions for a full digitalisation of the visa application process, and the 
current  differentiation  between  visa-free  and  visa-required  countries.  The  scope  of 
stakeholder consultation was deliberately broader, as it was also supposed to feed into the 
policy communication that will accompany this initiative. Some issues, such as lodging 
and decision-making deadlines as well as monitoring of ESP, are covered by the carry-
overs from the 2014 proposal (see annex 7). Issues regarding visa requirements concern 
the  Visa  Regulation  (539/2001)  and  will  be  addressed  in  the  communication.  On  full 
digitalisation  of  visa  procedures  the  communication  will  announce  the  launch  of 
feasibility studies that could feed in future legislative initiatives. 

11 

 
2. 

PROBLEM DEFINITION 

2.1.  What are the problems? 

2.1.1.  Insufficient financial resources to support visa processing 

The number of visa applications processed by Member States has increased considerably 
over  the  last  eight  years  since  the  Visa  Code  entered  into  force.  While  Member  States 
processed  10.2  million  visa  applications  worldwide  in  2009,  this  figure  rose  by  almost 
70% to a peak of 17.3 million in 2013,  and then dropped to 15.2 in 201618, which still 
represents an increase by more than 50% over 2009. According to preliminary figures it 
is  estimated  that  in  2017  the  number  of  visa  applications  will  have  increased  again  to 
around 16 million. 

At the same time the financial resources available to Member States' visa authorities and 
consulates for visa processing (per application) have remained static or even diminished 
due to budget cuts following the economic crisis. The visa fee of EUR 60 defined by the 
Visa  Code  should  be  the  main  financial  source  to  cover  the  costs  of  visa  processing. 
However, in a 2016 questionnaire survey as well as in the stakeholder consultation many 
Member  States  have  affirmed  (and  some  have  presented  calculations  showing)  that  the 
current  fee  does  not  cover  their  administrative  expenses,  notably  in  terms  of  staffing 
(both  expatriate  and  locally  hired  staff),  premises,  equipment,  development  and 
maintenance of IT systems, printing and secure management of visa stickers. This means 
that  Member  States  have  to  cover  the  funding  gap  from  their  general  administrative 
budget.  

Scarce resources for visa processing have prompted Member States to use outsourcing of 
certain  tasks  to  ESPs  to  alleviate  the  workload  for  their  consulates.  However,  due  to 
increasing  volumes  of  applications  outsourcing  did  not  lead  to  sufficient  cost  savings. 
Member  States  were  forced  to  take  more  drastic  measures,  such  as  cutting  staff  in 
consulates, reducing training and shifting more tasks from expatriate to local staff.  

As shown by several recent Schengen evaluation reports and LSC reports, understaffing 
(especially as regards expatriate staff which is by far more costly) and lack of appropriate 
training are recurrent problems. Consulates often lack well-trained experts with specific 
knowledge  (e.g. document  security experts). Staff shortages in consulates' visa sections 
directly affect the quality and integrity of the examination of visa applications and thus 
put at risk the screening function of visa procedures, with possible negative consequences 
for migratory and security threats.  

Some  Member  States  have,  as  a  result  of  short  financial  resources,  started  closing 
consular/visa  sections  or  refusing  representation  of  other  Member  States  in  certain 

18  

The drop in numbers was mostly due to a very strong decrease of applications in Russia (from 7 
million in 2013 to 3.2 million in 2016) and was not fully compensated by increases in other 
countries such as China and India.  

12 

 
                                                            
locations.19  Those  measures  create  problems  for  visa  applicants,  as  it  means  that  they 
have to travel to other countries (than those they live in) to apply for a visa.  

Insufficient financial and human resources also lead to long waiting times and deadlines 
in  processing  the  visa  applications,  especially in  peak  seasons  when  Member  States  do 
not always have the necessary resources to dispatch temporary staff reinforcements. This 
is  confirmed  by  many  complaints  received  by  the  Commission  as  well  as  the  open 
stakeholder consultation. The fact the length of the procedure was rated by respondents 
in the open consultation as the most difficult aspect of the visa procedure (32.6% selected 
it as the most difficult, 27.5% as the second most difficult element). The 2013 European 
Commission's study on the economic impact of short stay visa facilitation highlights that 
the most important source markets are late-booking markets. The lengthy visa procedures 
therefore deter tourist from travelling to Europe in the first place, leading to considerable 
revenue  losses  for  the  European  tourism  industry.20  According  to  a  European  Tour 
Operators Association (ETOA) report, it is estimated that 21% of potential tourists from 
emerging  markets  abandon  their  plans  to  travel  to  Europe  due  to  slow  processing  of 
visas.21  

The lack of sufficient revenues supporting visa processing thus undermines the integrity 
of  the  visa  processing  as  well  as  the  objective  of  providing  fast  and  client-friendly 
procedures to visa applicants.  

2.1.2.  Repeated visa procedures for regular travellers 

One  of  the  main  problems  already  identified  in  great  detail  in  the  2014  Impact 
Assessment is the lengthy and cumbersome visa procedure. This is particularly true for 
regular  travellers  who  visit  the  EU  at  least  once  a  year  for  business  trips,  to  attend 
conferences,  to  meet  family  or  friends,  or  as  tourists.  In  the  stakeholder  consultation, 
associations  representing  business  travellers,  maritime  transport,  performing  arts  and 
tourism  were  particularly  in  favour  of  reducing  administrative  burdens  for  frequent 
visitors. In the open public consultation 84% of individual respondents who travel to the 
Schengen area at least twice per year stated that they had not received any facilitations 
during the visa application process despite repeated visa applications. 

The Visa Code allows the issuing of multiple-entry visas (MEV) with a validity of up to 
five years. However, experience gathered in Schengen evaluations and in LSC since the 
start of application of the Visa Code shows that this possibility is rarely used. Member 
States (at central or consulate level) have a restrictive policy for issuing visas with a long 

19  

20 

21  

For instance since 2014 France, citing budgetary reasons, closed its visa sections in Nepal, Papua 
New Guinea, Fiji, Botswana, South Sudan, Brunei, Paraguay, Moldova and Montenegro. Similarly 
Denmark closed visa sections in Bolivia, Ecuador and Nepal. Several Member States started 
refusing representation of other Member States quoting lack of resources.  
Study on the economic impact of short stay visa facilitation on the tourism industry, 
https://ec.europa.eu/growth/content/study-economic-impact-short-stay-visa-facilitation-tourism-
industry-0_en  
ETOA, Europe: Open for Business?, http://www.etoa.org/docs/default-source/Reports/ETOA-
reports/2010-etoa-origin-markets-report.pdf?sfvrsn=2. 

13 

 
                                                            
validity; as a maximum many consulates are willing to issue a visa with a validity of one 
year, with a few rare exceptions. There are several reasons for the reluctance to Member 
States to issue MEV with a long validity: long-established practices to issue visas mainly 
for  the  planned  trip;  consulates'  apprehension  that  visas  with  long  validity  increase 
migratory risk; national requirements for consulates to consult central authorities before 
issuing  visas  with  long  validity;  and  the  unclear  legal  basis  (see  below,  section  2.2.2). 
Moreover,  there  are  also  wide  variations  between  Member  States'  practices  when  it 
comes to the length of validity of these MEV.  

The table below shows the MEV-issuing practice of three Schengen consulates in China 
visited as part of Schengen evaluations in 2016 and 2017. It shows, in two of the three 
cases, the very low share of MEV with a validity of one year or more among the total of 
visas  issued  (between  1  and  1.5%).  At  the  same  time  it  shows  the  wide  variety  of 
practices among Member States. These figures should be read against the background of 
the rapidly improving socio-economic situation of Chinese applicants and the rather low 
migratory risk from China, compared with other third countries.  

Share of total visas issued 
MEV 1 year 
MEV 2 years 
MEV 3 years 
MEV 4 years 
MEV 5 years 
Total MEV 1 year or more 

Member State 1  Member State 2  Member State 3 
0.99% 
0.24% 
0.19% 
- 
0.04% 
1.45% 

0.87% 
0.09% 
0.00% 
- 
- 
0.97% 

15.4% 
0.57% 
0.64% 
0.68% 
2.13% 
19.4% 

By way of comparison, the standard validity of visitor visas issued by the United States 
and  Canada  in  China  is  10  years  (unless  the  passport  validity  is  shorter  than  that,  in 
which case the visa validity is adapted to that of the passport). These countries argue that 
the risk of irregular migration and overstay does not increase by issuing visas with longer 
validity,  while  security  checks  in  databases  can  continuously  be  performed  by  the 
systems during the validity of the visa (leading to its revocation where appropriate).  

The  low  share  of  long-validity  MEV  –  combined  with  cumbersome  and  costly  visa 
procedures  –  affect  the  EU's  economy  negatively.  It  prevents  spontaneous  business  or 
leisure  travel  by  affluent  travellers  notably  from  countries  such  as  China,  India,  or  the 
Gulf region, who tend to increasingly take last-minute decisions on travel. Such persons 
who have not yet been granted a MEV with long validity after one or two trips to the EU 
with single-entry visas might turn their attention towards countries which are more ready 
to grant them visitor visas with long validity (e.g. United States, Canada, New Zealand). 
Business  people,  tourists  as  well  as  people  travelling  for  medical  treatment  will  thus 
direct  their  investment  and  spending  to  countries  outside  of  the  EU.  That  will  carry 
negative  consequences  for  the  EU's  tourism  industry,  retail  trade,  the  health  sector  and 
the economy as a whole.  

While it is very difficult to estimate the overall scale of the economic loss to the EU as a 
result  from  heavy  and  repetitive  visa  procedures,  the  fact  as  such  was  confirmed  by 

14 

 
 
stakeholders  during  the  targeted  and  the  open  public  consultations.22  The  tourism 
industry  associations  highlighted  the  role  of  outbound  travel  agencies,  who  have 
considerable  influence  in  steering  business  towards  markets  where  visa  procedures  are 
perceived to be less cumbersome. In the open consultation 22% of individual respondents 
who  offered  an  answer  stated  they  would  be  deterred  from  visiting  the  Schengen  area 
again due to their experience with the visa procedure.  

The  EU  Member  States  are  among  the  world's  leading  tourist  destinations  and  the 
tourism  and  travel  industry  plays  a  key  role  in  the  European  economy.23  Currently  it 
contributes approximately 10% to the EU's GDP and it contributed to the labour market 
by  11.6%  in  2016.24  Visa-required  countries  include  those  with  the  highest  increase  in 
international tourism expenditure in the first half of 2017 (China: +19%, Russia: + 27% 
after some years of declines, Thailand: +8%).25 However, the low share of MEV among 
the total number of visas issued unnecessarily restrains further growth of the industry and 
limits its global competitiveness26.  

Another  consequence  of  the  low  volume  of  MEV  with  long  validity  is  that  frequent 
travellers have  to  apply over and over again which represents  an administrative burden 
not only for the applicants, but also for the consulates in particular in locations with very 
high  volumes  of  applications.  This  constitutes  a  strain  for  the  consulates'  human 
resources  which  are  already  stretched  as  a  result  of  the  limited  financial  resources  (see 
above, section 2.1.1).  

Finally,  the  varying  practices  of  Member  States  with  regard  to  issuing  MEV  with  long 
validity  encourage  applicants  to  disregard  the  rules  of  Member  States'  competence  for 
issuing visas and apply with those Member States where they expect the most favourable 
outcome  (so  called  "visa  shopping").  This  means  that  applicants  are  more  likely  to 
provide  fraudulent  information  or  documents  with  regard  to  their  travel  destination 
and/or  purpose.  Visa  shopping  is  a  form  of  fraud,  and  even  though  it  is  difficult  to 
determine the extent of the phenomenon, Member States confirm that visa shopping is a 
serious issue and occurs frequently. Online fora in third countries show a vivid exchange 
among  applicants  on  which  consulates  issue  visas  with  a  long  validity.  Divergence  in 
issuing long-validity MEV is one of the strongest factor for visa shopping and also leads 
to accusations against some Member States of "unfair competition" to attract tourists and 
businesspeople and of not respecting the common rules.  

22  

According to the tourist industry, regular travellers to Europe tend to avoid the main tourist 
'hotspots' and visit less known towns and regions instead, boosting the economy in less developed 
areas. 
See also annex 6.  

23  
24   World Travel & Tourism Council, Travel & Tourism Economic Impact 2017, 
https://www.wttc.org/research/economic-research/economic-impact-analysis/. 
UNWTO, European Union Short-Term Tourism Trends, Volume 1, 2017-5. 
For instance, the number of Chinese outbound travellers rose by 6% to 135 million in 2016 and 
their expenditure to US$ 261 billion (UNWTO press release, 12 April 2017). However, Europe 
only received about 10.2 Chinese visitors, a growth of just 2% (according to the European Travel 
Commission).   

25  
26  

15 

 
                                                            
2.1.3.  Insufficient levels of return of irregular migrants to some countries of origin  

In the wake of the migration crisis of 2015 the numbers of irregular migrants in the EU 
expected  to  return  to  their  home  country  has  grown  considerably27.  These  numbers 
comprise  people  found  to  be  staying  illegally  in  the  EU,  persons  having  received 
negative asylum decisions as well as those for whom return decisions were issued.     

According  to  Eurostat  data28,  between  2011  and  2016  over  5  million  third  country 
nationals were found to be illegally present in the territory of the EU Member States, out 
of which just over 3 million in 2015 and 2016 alone. As regards asylum seekers, in 2015 
and  2016  a  total  of  718  665  third  country  nationals  received  first-instance  negative 
asylum decisions, with an additional 412 330 having received negative decisions in the 
first three quarters of 2017. In the six-year period of 2011-2016, 2 891 260 persons were 
ordered  to  leave,  out  of  which  1  118  385  were  returned  to  third  countries.  This  means 
that 1 772 875 persons were not returned, out of which 600 925 in 2015-2016 alone. It 
can be assumed that the majority of these persons continue to remain in the territory of 
the EU Member States.  

Irregular migrants staying in the territory of the Member States and waiting for return to 
their home country – whether refused asylum seekers, overstayers or other third-country 
nationals  who  do  not  (or  no  longer)  fulfil  the  conditions  of  entry  and  stay  –  remain  in 
legal  limbo:  not  having  an  authorisation  to  stay,  they  do  not  have  the  right  to  work 
legally,  and  thus  do  not  benefit  from  the  rights  and  legal  protection  available  to  legal 
migrants  having  access  to  employment.  They  cause  high  costs  for  Member  States  in 
terms of housing, food, medical expenses and related expenses, as well as administrative 
costs.  When  return  is  not  immediately  possible,  certain  basic  rights  are  provided  under 
the Return Directive, such as emergency healthcare and access to education for children. 
Many Member States go beyond the basic requirements and continue to provide housing, 
healthcare,  as  well  as  adult  education  even  after  a  return  decision  has  been  taken,  to 
reduce the likelihood of absconding. Irregular migrants can easily become prey of human 
traffickers, as well as be subject to exploitation.  

Irregular  migrants  who  pose  a  risk  of  absconding  can  be  detained  by  the  EU  Member 
States pending preparation of return for up to 18 months. Detention of irregular migrants 

27 

28  

While there is no data set collected in the EU to show in a consolidated manner the total (stock) 
number of irregular migrants in the European Union, this number can be extrapolated based on the 
available official Eurostat statistics, i.e. data on persons ordered to leave and effectively returned to 
third countries, persons found to be illegally present and the numbers of negative asylum decisions, 
as well as based on the numbers of arrivals of irregular migrants to the EU. There are however 
precision limitations to the use of individual datasets, as they are not always complementary or 
directly comparable. To give an example, France estimates the number of irregular migrants staying 
in the country based on the number of beneficiaries of state-funded health care (aide médicale 
d’État) at well above 311 310 (Avis n° 114 (2017-2018) de M. François-Noël BUFFET, fait au nom 
de la commission des lois, déposé le 23 novembre 2017). 
Eurostat database, Third-country nationals found to be illegally present – annual data (rounded); 
Asylum and first-time asylum applicants by citizenship, age and sex – annual aggregated data 
(rounded), Third-country nationals ordered to leave – annual data (rounded); Third-country 
nationals returned following an order to leave – annual data (rounded). 

16 

 
                                                            
is  not  only  a  serious  restriction  of  freedom  for  the  migrants  themselves,  but  also  very 
costly for the Member States. Due to high judicial requirements and the limited detention 
capacity  in  the  Member  States,  the  threshold  for  detention  of  irregular  migrants  is  set 
very  high.  Alternatives  to  detention,  such  as  reporting  obligations,  seizing  travel 
documents and/or valuables, requirement to  reside at a specified location, are known to 
be inefficient in preventing absconding.  

This  increases  the  risk  of  secondary  movements  of  irregular  migrants  and  abuse  of 
Member States' immigration systems.  Secondary movements increase the administrative 
burden  of  Member  States  in  terms  of  identification  of  apprehended  irregular  migrants, 
administrative  and/or  judicial  proceedings  necessary  to  reach  a  decision  on  the  right  to 
stay  in  a  given  Member  State,  appeal  procedures,  possible  detention,  preparation  of 
return etc.  

Finally the failure to efficiently return migrants to their home country is also an incentive 
for  further  irregular  migration.  The  dangers  along  the  road  to  Europe  are  often 
disregarded by irregular migrants because they know that the risk of being returned once 
in  Europe  is  rather  low.  Migrants  would  reconsider  whether  it  is  worthwhile  to  invest 
their own and/or family savings to enter Europe if the likelihood of being returned was 
significant. 

2.2.  What are the problem drivers? 

2.2.1.  Insufficient financial resources 

One  of  the  main  drivers  for  the  insufficient  financial  resources  for  the  purpose  of  visa 
processing is that the standard visa fee29 of EUR 60 has not changed since 2006, i.e. 
even before the entry into force of the Visa Code in 2009. While the Visa Code provides 
that it "shall be revised regularly in order to reflect the administrative costs", it does not 
define a specific procedure for revising the fee. Currently the only possibility to change it 
is to amend the Visa Code.  

During the negotiations on the Visa Code recast proposal several Member States were in 
favour  of  reviewing  urgently  the  visa  fee.  This  issue  was  brought  up  to  Coreper  in 
September  2015,  which  invited  the  Commission  to  carry  out  an  assessment  of 
administrative costs of the processing of visa applications.  Following up this request, the 
Commission carried out a survey among Member States to assess the cost of processing a 
visa application and what methodology should be followed to make such a calculation.30 

In the stakeholder consultation, almost all Member States were of the view that the cost 
of  processing  a  visa  application  exceeds  the  amount  of  the  fee  and  that  the  visa  fee 

29  

30  

A number of fee reductions and waivers apply. For instance, the visa fee is EUR 35 for children 
between age 6 and 12, and waived for children under 6. Moreover, most Visa Facilitation 
Agreements (VFA) concluded by the EU with third countries in force – including the one for 
Russia (3.2 million applications in 2016) – provide for a standard visa fee of EUR 35. VFAs cover 
about 30% of all visa applications. 
See annex 5, parts 1-2.  

17 

 
                                                            
should be increased. However, they differed on the precise amount and whether it should 
be differentiated by location or validity of the issued visa. Some argued that rather than 
linking the visa fee to the administrative costs, a political decision should be taken to set 
it  at  a  certain  level.  A  few  Member  States,  however,  recalled  that  travellers'  spending 
during their stay compensates for low revenues from the visa fee. This point of view is 
shared  by  stakeholders  in  the  tourism  and  travel  business,  who  argue  that  the  visa  fee 
should  be  seen  as  a  marketing  cost  that  is  overcompensated  not  only  indirectly  by  the 
economic  benefit  of  travel  and  tourism  to  the  Schengen  area,  but  directly  by  the 
additional tax revenue that Member States derive from visitors' spending in the Schengen 
area. 

In comparison with many other countries' fees for comparable visitor visas, the EU visa 
fee is rather low.31 

2.2.2.  Repeated visa procedures 

The main driver for and underlying cause of the repetitive visa procedures for frequent 
travellers and the low share of long-validity MEV is the unclear legal basis for issuing 
such  MEVs  and  Member  States'  diverging  interpretation  of  it.  Some  Member  States 
require their consulates to consult central authorities before granting long-validity MEVs, 
which represents an additional burden and thus a disincentive for consulates to do so.  

While the Visa Code provides for the  – in principle mandatory  – issuing of MEV  with 
long validity between six months and five years to bona fide regular travellers who have 
proven their integrity and reliability by lawfully using previous visas, this formulation of 
the  provision  allows  for  different  interpretations.  The  legal  basis  is  not  very  clear  with 
regard  to  the  conditions  for  issuing  of  long-validity  MEV,  the  personal  scope  of  the 
provision and the precise length of validity MEVs to be issued.32 For instance there are 
diverging views on how applicants are to prove the need to travel frequently or regularly 
(which in theory implies concrete planning and evidence of future trips), to what extent 
previous  trips  to  other  comparable  countries  (e.g.  UK,  US,  Canada,  Australia,  New 

31  

United States: USD 160 (EUR 133); UK: up to six months validity: GBP 89 (EUR 100), up to two 
years: GBP 337 (EUR 383), up to five years: GBP 612(EUR 696); Australia: AUD 140 (EUR 90); 
New Zealand: NZD 170 (EUR 100). Among those countries, only Canada has a comparable visa 
fee: CAD 100 (EUR 67). See more details in annex 5, part 3. 
Article 24(2) Visa Code:  

32  
2.   Without prejudice to Article 12(a), multiple-entry visas shall be issued with a period of validity 

(a)  

(b)  

between six months and five years, where the following conditions are met: 
The applicant proves the need or justifies the intention to travel frequently and/or regularly, in 
particular due to his occupational or family status, such as business persons, civil servants engaged 
in regular official contacts with Member States and EU institutions, representatives of civil society 
organisations travelling for the purpose of educational training, seminars and conferences, family 
members of citizens of the Union, family members of third-country nationals legally residing in 
Member States and seafarers; and 
The applicant proves his integrity and reliability, in particular the lawful use of previous uniform 
visas or visas with limited territorial validity, his economic situation in the country of origin and his 
genuine intention to leave the territory of the Member States before the expiry of the visa applied 
for. 

18 

 
                                                            
Zealand,  Japan)  can  be  taken  into  account  and  whether  certain  categories  of  travellers 
such as tourists can benefit from the provision, as they are not explicitly mentioned.  

Moreover there are no rules on the number of previous visas/trips that would entitle the 
applicant to a long-validity MEV and how fast the length of validity for each subsequent 
visa would increase (so called "MEV cascade"). Some Member States at central level or 
in  individual  consulates  have  developed  such  cascades  (e.g.  the  so-called  "decision 
protocols"  of  one  Member  State's  Ministry  of  Foreign  Affairs)  leading  to  individual 
practices  which  only  aggravate  the  lack  of  harmonisation.  Additionally,  it  has  been 
observed  in  Schengen  evaluations  that  Member  States  do  not  always  take  account  of 
visas issued by other Member States for the purpose of considering applicants as frequent 
travellers.  The  guidance  provided  by  legislation  to  consulates  on  the  issuing  of  MEV 
with long validity is therefore insufficient in several aspects. 

2.2.3.  Return of irregular migrants  

Readmission of own nationals is an obligation under international customary law, hence 
cooperation on return is not something that is at the will of a government. Nevertheless 
many third country governments are reluctant to readmit their own nationals. In the 
case of 80 third countries the return rates (i.e. the share of persons return to their country 
out of those ordered to leave EU territory) fall below the EU average return rate (46.4% 
in 2016). Around 700 000 persons of those found to be illegally present in the territory of 
EU  Member  States  in  2016  and  nearly  300  000  persons  of  those  ordered  to  leave 
originated from countries that lie below that average return rate. The return rate as such 
does  not  fully  reflect  the  level  of  cooperation  with  third  countries,  as  the  discrepancy 
between the number of persons ordered to leave and those effectively returned can also 
be  attributed  to  Member  States'  own  legal  or  administrative  obstacles  to  return. 
Nevertheless, a comparison between the return rates to various third countries is a solid 
indicator of the differences in the level of cooperation on return and readmission. 

Return of an irregular migrant can only be enforced on condition of possession of a valid 
travel  document.  If  such  a  document  is  available,  no  formalities  or  procedures  with 
authorities of the third country of origin are necessary. A third country's cooperation is 
necessary,  however,  when  no  valid  travel  document  is  available  to  Member  State's 
authorities and consequently the nationality of the irregular migrant has to be confirmed 
and a travel document issued by third country authorities. This is a widespread situation 
as many irregular migrants conceal or destroy their passport to prevent their return. 

In general, based on Member States' reports, cooperation in the return process is difficult 
with most third countries of origin. The authorities in the third countries concerned are 
not  willing  to  cooperate  efficiently  in  this  process,  hence  procedures  are  delayed, 
obstacles  are  created,  and  eventually  removal  is  postponed  or  avoided.  The  most 
recurrent obstacles reported were: 

 

requiring  additional  information,  such  as  criminal  records  or  identification 
documents; 

19 

 
 
 

 
 

 
 

requests to identify the person, as opposed to establishing his/her nationality; 
failure  to  accept  the  return  decision  as  the  outcome  of  national  procedures,  and 
the  request  to  reconsider  the  grounds  for  stay  of  the  third-country  nationals 
concerned; 
lack of competence of the embassies to establish nationality and identity; 
lack  of  capacity/willingness  at  the  consular  sections  of  embassies  to  conduct 
interviews with alleged nationals; 
refusal to issue travel documents; 
refusal to accept return flights, in particular charter flights. 

As regards the reasons  for the lack of third countries' cooperation on return, most third 
countries  do  not  provide  formal/public  justification,  given  the  sensitivity  of  the  topic. 
However the experience in negotiations with third countries on readmission, at EU and 
Member States level identified these main reasons: 

  public  opinion  in  third  countries  remaining  very  hostile  to  cooperation  on 

readmission with the EU; 

  protecting  the  interests  of  own  nationals  who  have  migrated  to  Member  States, 

whether they had done so regularly or irregularly; 

  pressure  from  the  diaspora  –  in  some  cases  embassies/consulates  have  been 
reported  to  become  subject  to  pressures,  bribes  or  even  threats  by  the  migrants' 
families urging them to prevent return; 
fear  of  the  loss  of  remittances  from  migrants,  which  in  many  third  countries 
constitute  a  substantial  share  of  the  GDP  (even  though  irregular  migrants 
represent  only  a  fraction  of  the  diaspora  and  are  unlikely  to  be  able  to  send 
significant amounts given their precarious status).  

 

2.3.  How will the problem evolve? 

2.3.1.  Insufficient financial resources 

Without  any  change  to  the  current  visa  fee,  it  is  very  likely  that  the  lack  of  financial 
resources  will  lead  to  further  cuts  to  Member  States'  budgets  for  visa  processing, 
resulting  in  staff  shortages  and  the  closing  of  visa  sections.  The  consequences  of  these 
tendencies have been described in section 2.1.1. 

2.3.2.  Repeated visa procedures 

While some Member States have recognised the problem and have started taking action 
(mostly  at  central  level)  to  encourage  consulates  to  issue  more  long-validity  visas,  the 
awareness and the perceived need for action is not shared equally among Member States. 
In  the  absence  of  clear  harmonised  rules  on  the  issuing  of  visas  to  regular  travellers, 
Member  States  and  their  consulates  are  likely  to  continue  to  determining  their  own 
approach.  

Many are likely to continue to be reluctant to issue MEV with long validity, while others 
might continue to adopt a more open approach, depending either on economic interests 

20 

 
and  general  relations  with  the  host  country  or  on  consuls'  individual  assessments.  
Especially  consulates  of  smaller  Member  States  with  no  capacity  problems  because  of 
limited numbers of applications or those who do not attract tourists do not feel the same 
level of pressure from central authorities, host countries, applicants, the tourism industry 
and  business  in  general  to  issue  more  long-validity  MEV,  first  because  the  volume  of 
visa applications in their consulates is lower and secondly because they are less likely to 
be the main destination of repeated trips of the same applicant. It is therefore likely that 
the gap between the practices of more forthcoming and more restrictive Member States 
will further increase.   

2.3.3.  Return of irregular migrants  

Given  the  peak  in  asylum  applications  in  2015 and  2016  and  the length  of  asylum  and 
appeal procedures, it can be assumed with certainty that the number of migrants expected 
to return to their countries (and thus the scope of the problem) will grow in the coming 
years.  On  the  basis  of  Eurostat  figures  it  can  be  extrapolated  that  about  1.2  million 
refused  asylum  seekers  will  be  progressively  receiving  enforceable  return  decisions  in 
2018-201933.  Out  of  the  2  583  735  asylum  applications  made  in  2015-2016,  884  655 
were  still  pending  in  2017  and  could  result  in  a  high  number  of  return  decisions.  The 
political pressure to enforce return decisions in practice will grow accordingly.  

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The  legal  basis  for  the  common  visa  policy  is  Article  77(2)(a)  TFEU.  This  Article 
empowers  the  Union  to  adopt  measures  concerning  "the  common  policy  on  visas  and 
other short stay residence permits". The existing Visa Code and other legislation in the 
field of the common visa policy have been adopted on that legal basis.  

3.2. 

Subsidiarity: Necessity of EU action 

The  abolition  of  checks  at  internal  borders  in  the  Schengen  area  requires,  among  other 
measures,  a  common  policy  on  visas.  The  common  visa  lists  (of  countries  whose 
nationals  require  visas  and  of  those  whose  nationals  are  exempted  from  the  visa 
requirement),  and  uniform  conditions  and  harmonised  procedures  for  issuing  visas  are 
pre-conditions  for  enabling  mutual  recognition  of  visas  which  allows  third-country 
nationals  legally  present  in  one  Schengen  State  to  travel  to  the  other  Schengen  State 
without  requiring  checks  at  internal  borders.  No  stakeholders  have  so  far  called  in 
question this principle. 

The conditions and procedures for issuing short-stay visas are established by a regulation 
that  is  directly  applicable  in  all  Member  States,  namely  the  Visa  Code.  The  problems 

33  

Not all Member States issue return decisions together with negative asylum decisions, and out of 
those which do, some report only enforceable return decisions to Eurostat, i.e. decisions which have 
entered into force once all appeal deadlines had expired or appeal procedures had been completed. 

21 

 
                                                            
elaborated in the previous sections are unlikely to disappear in the near future and they 
are directly related to the current provisions of the Visa Code. Amendments of the Visa 
Code are only possible at EU level.  

The initiative will further develop and improve the rules in the Visa Code. The short-stay 
visa in principle allows its holder to circulate freely in the Schengen area, which implies 
the  highest  degree  of  harmonised  rules  that  cannot  be  solved  by  Member  States  acting 
alone and can only be addressed at EU level. 

3.3. 

Subsidiarity: Added value of EU action 

As  described  in  the  baseline  scenario  below,  the  continued  application  of  the  current 
legal framework is not going to lead to resolving these problems. 

As regards the financing of visa processing, it is possible for Member States to increase 
their national budget for consulates and central visa authorities; however that possibility 
is  considerably  limited  by  national  budget  constraints  which  exist  in  most  Member 
States.  Moreover,  the  Visa  Code  stipulates  that  the  visa  fee  should  reflect  the 
administrative  costs  of  visa  issuing.  Furthermore,  it  is  legally  not  possible  for  Member 
States to charge additional or higher fees from visa applicants for visa processing; such 
action can only be taken at EU level.  

As  regards  the  issuing  of  long-validity  MEVs  for  regular  travellers,  the  Visa  Code 
currently  leaves  rather  broad  discretion  to  Member  States.  However,  as  argued  above, 
national  action  in  this  field  is  likely  to  be  very  uneven  and  therefore  to  aggravate  the 
problem, as it can lead to visa shopping as well as complaints by  some Member States 
and mutual accusations. EU action is therefore warranted to achieve a more harmonised 
development and implementation of current rules.  

National  action  is  possible  and  desirable  to  try  to  obtain  better  cooperation  of  third 
countries  on  matters  of  return  of  irregular  migrants.  Many  Member  States  have 
developed activities in that field, with varying success. However, it is unlikely that any of 
such  activities  will  achieve  the  same  leverage  towards  reluctant  third  countries  to 
cooperate  as  concerted  action  by  all  Member  States,  e.g.  in  the  framework  of  the 
common visa policy.  

4. 

OBJECTIVES: WHAT IS TO BE ACHIEVED? 

This section lists the general and specific objectives any initiative should have to address 
the above-mentioned problems faced by Member States and visa applicants.  

4.1.  General objectives 

The  general  objective  of  the  initiative  is  to  strengthen  the  common  visa  policy  while 
addressing  migration  and  security  concerns  on  one  hand  and  taking  into  account 
economic considerations and general external relations on the other hand.  

22 

 
4.2. 

Specific objectives 

In  order  to  achieve  the  general  objective,  the  following  specific  objectives  should  be 
addressed:  

1.  ensure  sufficient  financial  resources  to  Member  States  in  order  to  safeguard  the 

quality and integrity of visa processing;  

2.  ensure more systematic and harmonised issuing of multiple-entry visas with long 

validity to bona fide regular travellers; 

3.  advance  the  EU's  interests  in  the  area  of  return  and  readmission  by  increasing 

leverage vis-à-vis non-cooperative third countries in the area of visa policy. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

5.1.1.  Insufficient financial resources 

The  standard  visa  fee  will  remain  unchanged  at  EUR  60  (and  EUR  35  for  children 
between  6  and  12  years  of  age)  despite  the  Visa  Code  provision  requiring  its  regular 
revision. Member States' visa authorities will continue to experience the same difficulties 
in obtaining sufficient financial resources to fund visa processing in consulates, leading 
possibly to further closings of visa sections and staff shortages, which affect the level of 
service  provided  to  visa  applicants  and  may  put  at  risk  the  integrity  of  the  visa 
examination procedure.  

5.1.2.  Repeated visa procedures 

The existing provision on issuing MEV with long validity (Article 24(2) Visa Code) will 
continue  to  apply  and  will  be  interpreted  and  implemented  very  differently.  Many 
consulates will continue to  be rather restrictive in issuing such MEV, thereby requiring 
frequent travellers to go through repeated visa procedures resulting in increased costs and 
administrative burden for applicants and a high workload for applicants. The potential for 
additional  unplanned  trips  to  the  Member  States  by  holders  of  MEV  will  not  be 
exploited. 

5.1.3.  Return of irregular migrants  

Currently  there  is  no  legal  basis  for  making  visa  procedures  conditional  on  a  third 
country's  willingness  to  cooperate  with  Member  States  on  return  and  readmission  of 
irregular migrants. However, in  parallel to Council's proposed amendments to the Visa 
Code recast proposal to provide for a legal framework for using visa policy as leverage 
for  enhancing  cooperation  on  readmission,  Council  decided  in  June  2017  to  develop  a 
Coreper-led  coordination  mechanism  ("visa  policy  toolbox").34  This  mechanism  would 
be  applied  on  an  ad-hoc  basis  within  the  existing  legal  framework,  using  the  limited 

34  

Council document 9880/17 EU RESTRICTED. As this document is restricted, the approach 
followed can only be sketched vaguely. 

23 

 
                                                            
margin of manoeuvre given to Member States in the Visa Code. On the basis of a set of 
agreed  indicators  measuring  the  level  of  cooperation  of  a  given  third  country,  Coreper 
would  give  guidance,  on  a  case-by-case  basis  and  using  an  incremental  approach,  and 
recommend the coordinated application by Member States of a series of measures related 
to  the  visa  procedure.  The  measures  are  to  be  coordinated  by  Local  Schengen 
Coordination and regularly monitored by Coreper. 

The  Commission  supported  this  "toolbox"  approach  as  "pragmatic  and  efficiency-
oriented" and not affecting the Commission's institutional role and responsibilities, as the 
measures  covered  fell  within  Member  States'  margins  of  manoeuvre  with  regard  to  the 
implementation of the Visa Code.  

To  date  a  decision  leading  to  a  set  of  measures  being  agreed  on  has  been  made  with 
regard  to  only  one  third  country  in  September  2017.  The  mere  launch  of  the  process 
proved  successful  in  negotiations  on  a  return  arrangement  and  it  was  decided  not  to 
implement  the  agreed  measures  pending  signals  of  improvement  of  cooperation  on 
readmission.  

Therefore the baseline therefore has to be considered as a dynamic one, as no experiences 
in  the  effective  implementation  of  the  "toolbox  approach"  and  its  impact  have  been 
gathered yet. 

5.2. 

 Description of the policy options 

5.2.1.  Insufficient financial resources 

There  is  wide  consensus  that  the  visa  fee  paid  by  applicants  should  cover  the  costs  of 
Member States in processing visa applications, as far as possible. The principle that the 
visa  fee  should  reflect  the  administrative  costs  is  set  in  the  Visa  Code  itself  (Article 
16(3)).  It  is  fully  in  line  with  Member  States'  administrative  rules  providing  that  their 
own  citizens  have  to  cover  the  costs  of  certain  administrative  activities,  such  as  the 
issuing of passports, ID cards and driving licences. 

In  2016  the  Commission  conducted  a  questionnaire  survey  among  Member  States  on 
administrative costs and the calculation of the visa fee.35 It emerged in the survey and the 
subsequent discussions in the Visa Committee that it is virtually impossible to calculate 
the level of a common visa fee on the basis of national administrative costs. On the one 
hand, costs levels (in particular for staff) are very different among Member States. On the 
other hand, there were different views on factors that should be taken into account. There 
was  also  no  agreement  on  whether the  fee  should  remain  a  "flat  rate"  or  whether there 
should  be  differentiated  fees,  depending  on  the  length  of  validity  of  the  visa  or  on  the 
place of application.  

In the survey some Member States presented their own calculations of costs and/or came 
up with suggestions what the visa fee should be, as shown in this table: 

35  

See summary of Member States' replies in annex 5, parts 1 and 2.  

24 

 
                                                            
Member State 

Austria 
Belgium 
Denmark 
Latvia  
Luxembourg 
Malta 
The Netherlands  
Slovenia 
Sweden 

Calculation  of  administrative  costs  per 
visa application (in €) 

Suggested visa fee (in €) 

80-90  
143 (at consulates) 
69.92 (at consulates) 
99.06 

120 (not counting VFAs) 

90-100  

120 

65 

100 

In  the  stakeholder  consultation,  the  tourism  industry  associations  favoured  decoupling 
the visa fee from administrative costs and proposed setting it with regard to the practice 
of  'competing'  countries.  While  stakeholders  cautioned  against  raising  the  visa  fee, 
several  conceded  that  the  indirect  costs  of  a  visa  application  (travelling  to  the 
consulate/ESP,  obtaining  the  travel  medical  insurance  and  all  supporting  documents, 
legalisations, etc.) can be equally or more important than the visa fee.   

On this basis the following options will be examined: 

Policy option 1A: Status quo 

Unchanged common visa fee (EUR 60, children aged 6-11: EUR 35). 

Policy option 1B: National visa fees based on administrative costs 

Abolish the EU visa fee and allow Member States to set their visa fee nationally, based 
on real administrative costs (and a common calculation model defining the administrative 
costs that should be taken into account and the calculation method). 

Policy option 1C: Increase of common visa fee 

Increase  the  common  visa  fee  and  establish  a  mechanism  to  adjust  it  periodically  (e.g. 
every two years, most probably through delegated acts, on the basis of criteria defined in 
the regulation). 

  Sub-option 1C1: EUR 80 (children aged 6-11: EUR 40). 
  Sub-option 1C2: EUR 100 (children aged 6-11: EUR 50). 
  Sub-option 1C3: EUR 120 (children aged 6-11: EUR 60). 
  Sub-option 1C4: SEV/MEV up to 6 months: EUR 80, MEV 1-5 years: EUR 120.  

5.2.2.  Repeated visa procedures 

Policy  options  to  address  this  problem  area  should  ensure  more  systematic  and 
harmonised  issuing  of  MEV  with  long  validity  to  bona  fide  regular  travellers,  to  avoid 
repeated  and  unnecessary  visa  procedures  both  for  applicants  and  consulates.  The 
following options will be examined: 

25 

 
 
 
 
 
 
 
 
 
 
 
Policy option 2A: Status quo 

Leave  Member  States  /  individual  consulates  to  determine  their  general  approach  to 
issuing MEV with long validity (based on the current provision in the Visa Code).  

Policy option 2B: Recommended best practice 

Suggest  a  non-binding  approach  to  issuing  MEV  with  long  validity  in  the  Visa  Code 
Handbook, including a general MEV cascade.  

Policy option 2C: Common MEV cascades 

Define  (legally  binding)  MEV  cascade(s)  in  the  Visa  Code  and/or  Commission 
implementing decisions.  

  Sub-option 2C1  (general  MEV  cascade):  Visa  Code  defines  a  "one-size-fits-all" 
MEV cascade: after 2 visas in last 12 months, applicant obtains 3-year MEV, then 
5-year MEV (based on Visa Code recast proposal). 

  Sub-option 2C2  (general  and  country  MEV  cascades):  Visa  Code  defines  a  less 
generous "one-size-fits-all" MEV cascade: after 3 visas in last 2 years, applicant 
obtains  1-year MEV, then 2-year  MEV, then 5-year MEV; and provides  for the 
possibility  of  more  favourable  cascades  for  specific  countries  (based  on 
assessment in LSC and limited to countries cooperating on readmission). 

  Sub-option  2C3  (country  MEV  cascades):  Visa  Code  provides  for  possibility  to 

adopt MEV cascades for specific countries, based on assessment in LSC. 

Policy option 2D: Standard MEV with 2- or 5-year validity 

Define MEV with long validity (e.g. 2 or 5 years) as the new standard visa in the Visa 
Code,  while  allowing    Member  States  to  derogate  from  the  rule  and  issue  visas  with 
shorter validity in individual cases. 

5.2.3.  Return of irregular migrants  

Visa policy can play an important role to obtain better leverage vis-à-vis third countries 
on readmission of irregular migrants. However, it is also clear that better cooperation on 
readmission  with  reluctant  third  countries  cannot  be  obtained  through  visa  policy 
measures alone. Instead a policy mix of positive and negative incentives in various areas 
(in  particular  development  cooperation,  trade,  investments,  education)  would  be 
necessary to sway a country's attitude. Measures in the visa policy area would therefore 
be one tool among others in the EU's hands to achieve better cooperation. All other tools 
(as  coordinated  notably  in  the  Partnership  Framework)  will  remain  equally  important. 
For the purpose of this report, however, only policy options in the area of visa policy 
will be considered: 

26 

 
Policy option 3A: Status quo 

Continue the Coreper-led "toolbox approach" (using the existing flexibility of Visa Code) 
to put pressure on third countries not cooperating on readmission of irregular migrants36. 
No legislative amendments. 

Policy option 3B: Positive incentives 

Amend  the  Visa  Code  to  create  a  legal  basis  for  positive  incentives  for  cooperation  on 
readmission,  such  as  lower  visa  fees  and  a  favourable  MEV  cascade,  to  be  applied  in 
countries that cooperate or improve their cooperation with Member States.  

Policy option 3C: Negative incentives 

Amend the Visa Code to create a legal basis for negative incentives for cooperation on 
readmission. 

  Sub-option 3C1 (maximum approach): negative incentives on various aspects of 
the  visa  procedure,  to  be  defined  in  the  regulation  (e.g.  higher  visa  fee,  more 
supporting  documents,  maximum  processing  time,  limited  length  of  MEVs), 
applicable to all holders of passports. 

  Sub-option 3C2 (targeted approach):  negative incentives  as above,  applicable in 
two separate phases: 1) holders of diplomatic and service passports, 2) holders of 
ordinary passports. 

It  would  also  be  possible  to  conceive  of  a  combination  of  both  positive  and  negative 
incentives.  While  this  possibility  should  not  be  discarded  outright  and  should  be 
considered seriously on the basis of the options proposed, its impacts will not need to be 
assessed separately. 

5.3.  Options discarded at an early stage 

For  the  first  problem  area  (financial  resources),  the  lowering  or  even  abolition  of 
common  visa  fee  could  be  a  possible  option,  but  will  be  discarded  at  this  stage  as  it 
would not contribute to reaching the objective. Some stakeholders in the tourism industry 
argue that a reduction in the visa fee should be seen as a marketing  cost  and would be 
recovered indirectly through additional income in the national economy and the resulting 
tax revenue. However, it is not clear where the necessary financial resources would come 
from: Member States are not ready to subsidise visa issuing even further, and a tax on the 
tourism  industry  to  fund  visa  issuing  would  encounter  strong  opposition  and  seem 
disproportionate. Moreover, reducing or abolishing the visa fee would also carry certain 
risks, as it could encourage potential irregular migrants to just "try their luck" lodging a 
visa application without any or at low cost. 

36  

For all policy options 'cooperation on readmission' only refers to readmission of third countries' 
own nationals, except where third countries have committed to, e.g. in a readmission agreement 
with the EU, readmitting nationals of other third countries that have transited through their territory. 

27 

 
                                                            
6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

6.1.  Methodology 

6.1.1.  Possible impacts 

The EU's visa procedures concern most directly two types of actors: visa applicants and 
Member States' authorities. Any options modifying the common visa policy will have the 
most immediate impact on those two groups. Other groups of (mostly economic) actors 
will be affected indirectly by changes of behaviour of the directly affected groups. These 
impacts  in  turn  can  have  broader  consequences  for  the  societies  of  EU  Member  States 
and the EU's external relations.  

The first group which is directly affected are visa applicants, i.e. third-country nationals 
who  are  under  the  visa  requirement  and  who  apply  for  a  short-stay  visa  at  one  of  the 
Schengen consulates. Applicants will directly experience any change in the visa fees, as 
it  will  affect  the  costs  involved  in  the  visa  procedure  and  might  influence  their  travel 
plans,  particularly  for  tourism  purposes.  Any  change  in  the  issuing  of  MEV  with  long 
validity will also affect visa applicants, as it might reduce the number of times they have 
to apply for a visa and thus their financial and "hassle" costs, and increase their flexibility 
to  travel  spontaneously.  Finally,  if  any  (positive  and  negative)  change  of  the  visa 
procedure is applied in order to obtain a third country's cooperation on readmission, this 
change will also positively or negatively affect visa applicants and their travel behaviour.  

The second group directly affected are  Member States' authorities, first and foremost 
consulates  in  third  countries  as  the  visa-issuing  authorities.  They  will  be  directly 
concerned  by  any  change  in  the  visa  fee  which  will  influence  the  financial  resources 
available  for  visa  processing.  Changes  in  the  approach  to  issuing  MEV  will  affect  the 
number of visa applications to be processed. Any increased leverage on third countries' 
cooperation  on  readmission  will  impact  on  the  public  authorities  dealing  with  refused 
asylum  applicants  and  irregular  migrants,  namely  migration,  asylum  and  police 
authorities.  

Groups indirectly affected by the visa policy are economic actors in the EU having visa 
holders  as  clients  or  employees,  such  as  the  tourism  industry  (travel  agencies,  hotels, 
restaurants  etc.),  airlines  and  other  transport  companies,  the  retail  sector,  enterprises 
engaged  in  international  trade  (export/import,  trade  fairs),  the  health  industry  (clinics) 
and the shipping industry (employing seafarers). Any changes in travel behaviour by visa 
applicants/holders  (caused  by  modifications  to  visa  fees  or  MEV  issuing  rules)  will 
indirectly affect these actors' revenues and competitiveness.  

The EU Member States' economies and societies will feel the impact of changes in visa 
policy.  Economic  activity  in  the  above-mentioned  sectors  influences  growth  and 
employment rates. Visa policy is one of the tools for controlling irregular migration and 
preserving  the  Schengen  area's  integrity  and  security.  Financial  resources  available  to 
visa-issuing  authorities  will  impact  the  quality  of  their  work,  the  integrity  of  the  visa 
processing  and  consequently  the  security  of  the  Schengen  area.  Similarly,  increased 

28 

 
leverage  for  the  EU  readmission  policy  and  better  return  rates  will  improve  migration 
management, as well as people's acceptance of the EU's migration policy. Increased or 
reduced travel as a result of the changes in the EU's visa policy will influence people-to-
people  contacts  and  cultural  exchange  between  populations  in  Europe  and  other 
continents and it will have an effect on emission of greenhouse gases and thus  climate 
change. As many people travel to the EU to visit their family members, the  protection 
of family life37 will also be indirectly affected by increased or reduced possibilities for 
travel.  

Finally  changes  in  the  visa  policy,  through  their  effect  on  third  country  nationals' 
opportunities,  will  have  direct  positive  or  negative  impact  on  the  EU's  relations  with 
third countries and the EU's image in the world. This is particularly relevant regarding 
the link between visa policy and readmission policy. 

The following table summarises the possible impacts of the policy options:  

Economic impacts 

  costs for public authorities (visa authorities/consulates):  

  direct (staff, premises, equipment etc.) 
  indirect (enforcement costs) 

  benefits for public authorities (visa/asylum/police 

authorities):  
  income 
  cost savings 

  costs for third country citizens (applicants):  

  direct (fees) 
  indirect (non-monetisable, such as "hassle costs") 

  benefits for third country citizens (applicants):  

  direct (cost savings) 
  indirect (non-monetisable, such as more flexible travel) 

  competitiveness of EU tourism industry and trade sector 
  employment in EU (tourism/trade sectors) 
 
integrity and security of Schengen area 
  people-to-people contacts 
  external relations/image of EU 
  emission of greenhouse gases (as result of increased/reduced 

travel) 

  protection of the family 

Social impacts 

Environmental 
impacts 
Fundamental 
rights impacts 

The different possible interventions in the three problem areas are not likely to all have 
noteworthy  impacts  in  all  of  the  above-mentioned  areas.  Therefore  the  assessment  for 
each problem area is focused on the fields where the different policy options are likely to 
have significant impacts. A selection of the most relevant impacts will be established for 
each problem area. 

37  

Articles 7, 9 and 33 of the Charter of Fundamental Rights of the European Union.  

29 

 
 
 
                                                            
6.1.2.  Available data 

The  Commission  collects  yearly  visa  statistics  from  Member  States  which  include  the 
number of visa applications by Member State and by location (i.e. consulate), the number 
of  visas  issued  and  the  number  of  visas  refused  (with  which  the  refusal  rate  can  be 
calculated). These statistics also include the share of MEV issued, but not their length of 
validity.  The  Visa  Code  recast  proposal  included  a  more  detailed  collection  of  visa 
statistics, including  the length  of validity of visas issued, nationality of applicant,  visas 
issued  in  representation  and  number  of  appeals.  The  current  EU  legislation  does  not 
provide  the  possibility  for  the  statistics  on  visas  to  be  produced  centrally  from 
information available in the VIS; however the upcoming revision of the VIS legal base 
will entrust eu-LISA with the task of producing such statistics. In the current absence of 
an entry/exit system, no data on the use of visas are available38, such as the number of 
trips to the EU by holders of MEV. In general there are only limited data on travellers to 
the EU (compared with other destinations), especially on details such as their nationality, 
the frequency of travel, costs and expenditure. 

There  are  no  statistics  on  the  costs  of  visa  processing  or  on  budgetary  resources 
available  to  Member  States'  foreign  ministries  /  visa  authorities  for  that  purpose.  The 
Commission services conducted a questionnaire survey among Member States in 2016 to 
collect  information  on  the  costs  of  visa  processing  and  the  methodology  to  calculate 
them.  These  costs  cover  a  variety  of  items  (human  resources,  premises,  equipment,  IT 
development  and  maintenance,  printing  and  secure  dispatch  of  visa  stickers)  of  which 
many  are  not  exclusively  used  for  visas,  but  also  other  consular  tasks  (e.g.  issuing  of 
national passports). On the basis of the replies to  the survey, it became clear that these 
costs are difficult to estimate. A few Member States shared their estimates of the costs of 
visa processing, but they were calculated differently and resulted in wide variations. This 
fragmentary evidence will be used where possible.  

Little  evidence  is  available  as  regards  the  costs  and  benefits  of  policy  options  for  visa 
applicants/holders. There is no stakeholder organisation, such as an NGO or association 
directly  representing  visa  applicants  that  could  provide  reliable  data.  In  the  public 
consultation  evidence  was  gathered  on  third-country  nationals'  experience  with  the 
Schengen visa procedure, allowing for certain conclusions to be drawn on the costs and 
benefits  in  these  individual  cases.  As  respondents  to  the  consultation  are  self-selected, 
however, these responses are not necessarily representative of all visa applicants.  

In  the  absence  of  a  survey  of  a  statistically  relevant  number  of  visa  applicants  in  a 
representative  number  of  third  countries,  it  is  very  difficult  to  assess  the  impact  which 
changes in the visa fee or the issuing of MEV will have on third-country nationals' travel 
behaviour.  This  can  only  be  estimated  on  the  basis  of  anecdotal  evidence  or  general 
assumptions. Consequently the same is true for the knock-on effects of changes in travel 

38  

Such data will be available with the entry of operations of the EES.  

30 

 
                                                            
behaviour  on  economic  or  social  outcomes.  Therefore  the  existing  data  on  inbound 
tourism in the EU is of limited value for assessing impact of specific policy options.  

Available  data  regarding  readmission  of  irregular  migrants  are  limited  to  available 
Eurostat statistics (including by nationality) on the number of return decisions taken by 
Member States and the number of effective returns. With those two indicators, the return 
rate can be calculated. However, even those figures have to be taken with some caution 
as  they  do  not  reflect  exclusively  the  willingness  of  third  countries  to  cooperate  on 
returns.  Those  statistical  data  need  therefore  to  be  complemented  by  more  qualitative 
information,  resulting  from  Member  States'  experience  in  cooperation  with  those  third 
countries.  Furthermore,  implementation  of  the  Return  Directive39  varies  between  the 
Member  States,  which  results  in  different  interpretation  of  statistical  indicators.40 
Member States either do not have or  are reluctant to share data on the costs of lodging 
and  detention  of  irregular  migrants  before  they  can  be  returned,  nor  on  the  costs  of 
returns.  Finally  –  apart  from  anecdotal  experience  in  the  EU  with  regard  to  one  third 
country  –  there  is  no  hard  evidence  on  how  visa  leverage  can  translate  into  better 
cooperation of third countries on readmission.  

The  ample  experience  gathered  by  the  Commission  services  in  monitoring  Member 
States' implementation  of the visa policy,  notably  through the  Schengen evaluations41, 
was exploited wherever possible.42 In this context the Commission services have visited, 
since the beginning of 2015, 32 consulates of 16 Schengen States all over the world, thus 
generating hands-on and in-depth knowledge of Member States' visa-issuing practices.  

6.1.3.  Qualitative assessment method 

The scarcity of data does not allow for a quantitative assessment of the different policy 
options, such as could be done in a cost-benefit analysis. Instead a qualitative method 
will have to be used. Given the widely spread impacts that the policy options are likely to 
have,  it  seems  most  judicious  to  conduct  a  multi-criteria  analysis  (MCA)43.  It  is  a 
technique  to  reach  a  judgment  based  on  an  explicit  set  of  objectives  and  associated 
criteria and is particularly useful in case of complex interventions with diverse quantified 
and/or qualitative impacts (in particular factors which cannot be expressed in monetary 
terms). An MCA is used to assess and rank alternative options in an impact assessment.   

39  

40  

41  

42  

43  

Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on 
common standards and procedures in Member States for returning illegally staying third-country 
nationals. 
For example, it cannot be excluded that in some Member States the real number of persons ordered 
to leave is undervalued, as it is lower than the number of rejected asylum decisions, while failed 
asylum seekers constitute only a subset of all persons issued return decisions. 
In accordance with Council Regulation (EU) No 1053/2013 establishing an evaluation and 
monitoring mechanism to verify the application of the Schengen acquis.  
This information is rather of qualitative than quantitative nature and has been used cautiously, given 
the confidential character of the evaluation reports ("EU restricted" documents, established by 
means of Commission implementing decisions). For instance, Member States have not been named. 
See tool #63 of the Better Regulation toolbox. However, a slightly simplified model will be applied.  

31 

 
 
                                                            
This method will be applied as follows: 

1.  For each problem area a number of impact criteria are established, based on the 

selection of most relevant impacts (see above).  

2.  The weight of each criterion (e.g. 20%) will have to be defined as a measure of 

its overall importance compared with other impacts.  

3.  The  performance  of  each  policy  option  for  each  criterion  will  be  ranked  on  a 
scale  from  0  to  3,  based  on  a  qualitative  assessment  of  the  impacts  (compared 
with the status quo option which by definition will be 0).44  

4.  This  ranking  will  include  the  direction,  i.e.  whether it is  positive  or  better  than 

the status quo (+) or negative or worse than the status quo (-).  

5.  The performance score, including the direction (+ or -), will be multiplied by the 
weight factor and added to the performance scores of all other criteria, resulting 
in  an  aggregate impact score for each policy option. These scores will already 
make it possible to compare and rank the policy options. 

6.  However,  as  in  the  absence  of  hard  data  those  scores  will  largely  be  based  on 
estimations and assumptions, it is useful to assess and compare them on a number 
of general principles (ranging from - - - for the most negative to + + + for the 
most positive): 
  effectiveness (with regard to policy objectives), 
  proportionality, 
 

feasibility (legal and practical) and coherence with other policies. 

7.  The  preferred  option  will  be  determined  through  a  comparison  on  the  basis  of 

the aggregate impact score and the other criteria. 

6.2.  Assessment of policy options 

6.2.1.  Insufficient financial resources 

Relevant impacts, criteria and relative weight 

For Member States a change of the visa fee has direct impact on the financial resources 
available for visa processing. Even in Member States where the visa fee income ends up 
in the general state budget, higher revenues give the visa authorities a stronger stand in 
their  budget  negotiations  with  the  finance  ministry.  Sufficient  financial  resources  are 
essential for the staffing of consulates, training and the quality of visa processing.  

As  argued  above,  these  factors  have  a  bearing  on  the  integrity  and  security  of  the 
Schengen  area,  which  is  influenced  not  only  by  the  amount  of  the  financial  resources 
available,  but  also  possibly  by  the  fee  model  (common  EU  or  national).  Therefore  this 
will have to be assessed separately. 

44  

0 = no change, 1 = weak change, 2 = moderate change, 3 = strong change.  

32 

 
 
                                                            
The reverse side of additional income for Member States through increased visa fees are 
additional direct costs for visa applicants. It will have to be assessed whether the different 
policy  options  are  likely  to  influence  their  decisions  to  travel  to  the  EU  and  how. 
Changes  in  travel  behaviour  will  –  as  argued  above  –  have  influence  on  certain 
economic sectors and therefore on employment and growth in the EU. It will also impact 
people-to-people  contacts,  the  protection  of  the  family  and  the  EU's  image  worldwide, 
and  it  will  have  an  effect  on  carbon  emissions.  As  all  these  indirect  impacts  are  a 
consequence  of  the  travel  behaviour,  they  will  not  be  assessed  separately.  Overall 
reduced  travel  will  be  assessed  as  negative  (despite  the  positive  effects  on  climate  gas 
emissions, which will however be outweighed by the other negative effects).  

The following weighting will be attached to the three impact criteria. Changes in travel 
behaviour  can  affect  the  EU's  economy  and  will  therefore  be  weighted  equally  to 
increases  in  financial  resources.  As  the  integrity  and  security  of  the  Schengen  area  is 
already  influenced  by  the  amount  of  financial  resources  available,  the  second  criterion 
just rates the additional impact of the fee model chosen (national / common visa fee) and 
will therefore be weighted less.  

Financial resources 
Integrity / security of Schengen area 
Changes in travel behaviour 

40% 
20% 
40% 

Qualitative assessment of impacts  

Policy  option  1A  (status  quo)  would  not  produce  any  change.  The  performance  is 
therefore ranked +/-0 on all three criteria.  

Impacts  of  policy  option  1B  (national  visa  fees  based  on  administrative  costs)  will 
depend on how Member States would adapt their visa fees. While evidence gathered in 
the survey suggests that most Member States have higher costs than the current EUR 60 
per visa application, it is far from certain that all of them would raise the fees. Some with 
a strong interest to attract tourists might even be tempted to lower their fees in order to be 
more  'competitive'  (similarly  as  has  been  witnessed  with  reduced  processing  time  and 
other unilateral 'facilitations' in some locations). Others might be reluctant to raise the fee 
before  other  Member  States  do  it.  It  can  therefore  be  assumed  that  the  increase  in 
financial resources will be weak, if at all (+1). What can be expected is that the resulting 
divergence  in  visa  fees  would  strongly  encourage  visa  shopping  and  presentation  of 
fraudulent  documents  to  obtain  a  visa  at  low  cost;  combined  with  the  risk  of  one  or 
several Member States engaging in 'disloyal competition'. This would raise threats to the 
integrity and security of the Schengen area (-1). Overall travel behaviour is uncertain to 
predict, but would probably remain neutral (+/-0).  

33 

 
 
Policy options 1C1, 1C2, 1C3 and 1C4 (increase of the common visa fee) will have a 
direct  positive  impact  on  financial  resources,  depending  on  the  scale  of  the  increase 
under the various sub-options45: 

Current visa fee revenue all Member States worldwide 
Additional revenue for option 1C1 (EUR 80) 
Additional revenue for option 1C2 (EUR 100) 
Additional revenue for option 1C3 (EUR 120) 
Additional revenue for option 1C4 (EUR 80/120)46 

Visa fee revenue in € 
792 million 
205 million 
412 million 
619 million 
267 million 

Increase by  Rating 

26% 
52% 
78% 
34% 

+1 
+2 
+3 
+1 

Parallel positive effects can be expected as a result for the security of the Schengen area, 
provided  the  additional  revenues  are  fully  invested  into  additional  staff  for  visa 
processing  as  well  as  IT  tools  and  training  and  would  therefore  contribute  to  a  more 
thorough  examination  of  applications  (same  rating  for  options).  As  regards  impact  on 
travel behaviour, it can be assumed that an increase of the visa fee by EUR 20 will not 
yet cause noticeable changes, given the overall costs involved in visa procedures47 and in 
travelling to Europe from visa-required countries in Africa, Asia or Latin America48 (+/-
0);  the  same  is  true  if  MEV  of  one  year  or  more  would  be  charged  EUR  120,  as  this 
would  be  regarded  as  'fair'  by  most  visa  applicants.  Similarly  an  increase  by  EUR  40 
would  only  cause  a  weak  change  in  travel  behaviour  (-1).  Given  comparable  countries' 
visa  fees49  and  the  lack  of  alternatives,  even  a  visa  fee  of  EUR  120  would  very  likely 
only lead to a moderate reduction of travel to the EU (-2). 

45  
46  

47  

48  

49  

See detailed calculations in annex 5, part 4. 
Even though the additional revenue would be higher for option 1C4 than for option 1C1, it is rated 
the same (+1), as a considerable part of additional income would be lost in a more inefficient 
procedure. Differentiated fees for SEV/MEV for up to 6 months and MEV valid for one year or 
more would mean that the final fee level cannot be determined at the time of lodging the 
application, but only when the decision on the application (and thus on the length of validity) has 
been taken by the consulate. An additional procedural step for reimbursing part of the fee or 
payment of the additional fee after the decision would have to be introduced, leading to additional 
administrative burden and costs.  
This includes costs for travelling to the consulate/ESP (to give fingerprints), the service fee for the 
ESP, the travel medical insurance, costs for obtaining supporting documents, such as notarisation or 
legalisation of official documents, and courier fees for the return of the travel document. In the 
public consultation, applicants report spending on average EUR 45 for the travel medical insurance 
and around EUR 60 for travelling to the consulate or visa application centre. In some cases these 
costs are several hundred EUR and have a far greater impact on the applicant's budget than the visa 
fee. 
Intercontinental flight tickets cost several hundred euros. Accommodation and other costs 
associated with travelling have to be added. A survey of Chinese tourists found that the average 
amount spent on an overseas trip in 2016 was about RMB 20 000, around EUR 2500 (Oliver 
Wyman consultancy, 2017). The only countries for which even a moderate increase could have 
slightly more negative impacts are Belarus, Kosovo and Turkey, notably for cross-border day trips 
for shopping or other purposes. All other countries with direct land borders are either visa-free or 
covered by VFA with a reduced visa fee which will not be affected by an increase of the general 
visa fee.  
See details in annex 5, part 3.  

34 

 
 
 
 
 
 
                                                            
Overview  

Impact criteria 

Weight 

Options 

Financial resources 
Integrity / security of 
Schengen area 
Changes in travel 
behaviour 
Aggregate impact score 

40% 
20% 

40% 

100% 

1A 
0 
0 

0 

0 

1B 
+1 
-1 

1C1 
+1 
+1 

1C2 
+2 
+2 

1C3 
+3 
+3 

1C4 
+1 
+1 

0 

0 

-1 

-2 

0 

+0.2 

+0.6 

+0.8 

+1.0 

+0.6 

6.2.2.  Repeated visa procedures 

Relevant impacts, criteria and relative weight 

Changing the approach to issuing MEV with long validity will have impacts on Member 
States'  costs  for  issuing  visas.  A  more  generous  issuing  of  visas  with  a  validity  of  one 
year and above  will  mean  that frequent travellers will have to apply less frequently for 
visas. This in turn means less work for consulates, but also less revenue from visa fees. 
As the administrative costs for  most  Member States  lie above the current  visa fee (and 
are  likely  to  continue  to  do  so),  issuing  more  long-validity  MEV  will  lead  to  net  cost 
savings for Member States, though of limited scale. 50  

A higher share of MEV also means cost savings for frequent travellers, both on direct 
costs (for visa fees, ESP service fees, costs for obtaining supporting documents, travel to 
the  ESP/consulate,  courier  fees  etc.)  as  well  as  indirect  "hassle  costs"  (mainly  the  time 
loss involved in visa procedures).  

More  long-validity  MEV  also  have  a  direct  positive  impact  on  travel  behaviour. 
Holders of MEV of one year or more are more flexible in planning their trips to the EU 
and  will  be  able  to  travel  more  spontaneously.  In  the  public  consultation,  respondents 
who had received MEV reported taking on average 4.25 additional trips to the EU during 
the  validity  period  of  their  visa,  which  had  not  been  initially  planned  at  the  time  of 
application. It is therefore likely that a higher share of MEV will also increase travel to 
the  EU  with  the  positive  knock-on  effects  (described  above)  on  EU  economic  actors, 
employment  and  growth,  people-to-people  contacts  and  cultural  exchange,  family  life 
and the EU's external image (as well as negative effects for climate gas emissions). As 
explained above, increased travel will be assessed positively. 

50  

Cost savings for Member States will only be achieved if the visa fee does not fully meet or even 
exceed the administrative costs of Member States for processing one visa application. The extent of 
costs savings for Member States therefore depends on the policy option that will be chosen for the 
first problem area. It is assumed here for the purpose of simplicity that the preferred policy option 
will not fully cover the administrative costs for the majority of Member States.  

35 

 
 
                                                            
It is assumed that more MEV with long validity will have no impact on the integrity and 
security of the Schengen area.51 The migratory risk of visa applicants is checked before 
the visa is issued, and generally frequent travel is an indicator of low migratory risks. As 
regards  security  risks,  the  regular  SIS  check  will  be  performed  at  each  entry  in  the 
Schengen area.  

The following  weighting will be attached to the three impact criteria. The cost savings 
for Member States and applicants respectively are rated lower than the change in travel 
behaviour as the related monetary and non-monetisable benefits of increased issuing of 
MEV are likely to be greater for the wider economy and society than for the applicants 
and consulates themselves. 

Cost savings for Member States  
Cost savings for frequent travellers 
Changes in travel behaviour 

20% 
20% 
60% 

Qualitative assessment of impacts52  

Policy  option  2A  (status  quo)  would  not  produce  any  change.  The  performance  is 
therefore ranked +/-0 on all three criteria.  

Policy  option  2B  (recommended  best  practice  in  the  Visa  Code  Handbook)  might 
prompt  a  few  Member  States  to  improve  their  practice  on  issuing  MEV  with  long 
validity.  However,  falling  short  of  a  concerted  action,  it  is  unlikely  to  have  tangible 
effects as regards cost savings for Member States (+/-0) and only limited positive impact 
for frequent travellers' cost savings and increased travel (both +1).  

Policy  options  2C1,  2C2  and  2C3  (MEV  cascades  at  central  and/or  country  level), 
are likely to have greater impact due to their legally binding nature, but it will vary for 
individual  travellers.  The  'once-size-fits-all'  MEV  cascade  in  option  2C1  is  more 
generous than the 'fall-back' MEV cascade in option 2C2. A business person who travels 
to the EU three times a year would have to apply – over a period of five years – for four 
visas  in  option  2C1,  but  six  times  in  option  2C2.  The  cost  savings  both  for  Member 
States and for applicants could therefore be greater in option 2C1 than in option 2C2. In 
the latter option however,  there is a good chance that a more favourable MEV cascade 
would  be  established  for  countries  with  low  migratory  risk  which  are  important  for 
Member  States  economically,  be  it  as  business  partners  or  countries  of  importance  for 
inbound  tourism,  such  as  China,  India  or  the  Gulf  countries.  This  possibility  would 
compensate for the less favourable 'fall-back cascade'. Cost savings for both options are 
therefore  assumed  to  be  largely  equally  positive  (+2  for  Member  States  and  +3  for 

51  

52  

This is also confirmed by the practice of US and Canadian consulates to issue MEV with a validity 
of 10 years as a standard visitor visa.  
As only positive impacts will be recorded for this problem area and in order to allow for a more 
differentiated assessment of policy options, impacts will be rated as follows: 0 = no change, 1= very 
weak change, 2 = weak change, 3 = moderate change, 4 = strong change, 5 = very strong change. 

36 

 
 
                                                            
frequent travellers). In both options, the traveller would hold a MEV with a long validity 
(one  year  or  more)  from  the  second  or  third  year  onwards,  so  the  potential  for 
spontaneous additional trips would be similarly positive (+3). In option 2C3 the country 
MEV  cascades  would  take  some  time  to  be  agreed  locally  and  established  by 
Commission  implementing  decision  and  the  approach  would  be  more  patchy  while  no 
'fall-back'  cascade  would  apply,  leading  to  a  slower  and  weaker  positive  impact  on  all 
three criteria (+1, +2 and +2 respectively).  

For  parents  who  visit  their  son  or  daughter  in  the  EU  only  once  a  year,  none  of  those 
options would bring any advantages. This would change in policy option 2D (standard 
MEV  with  2-  or  5-year  validity).  As  all  travellers,  including  first-time  applicants, 
would be issued an MEV with a long-validity, the number of visa applications worldwide 
would drop considerably and lead to the greatest cost savings for Member States (+4) and 
applicants  (+5).  Equally  the  potentially  for  additional  travel  and  business  opportunities 
for the EU would increase most (+4).  

This  option  would  correspond  to  the  current  US  and  Canadian  standard  practice  of 
issuing visas with a validity of ten years, even to first time applicants. According to those 
countries'  reasoning  the  length  of  validity  of  a  visa  does  not  affect  the  migratory  risk 
presented  by  the  applicant,  while  the  security  risk  can  be  controlled  by  regularly 
checking visa holders against security databases. 

Overview  

Impact criteria 

Weight 

Cost savings for Member 
States  
Cost savings for frequent 
travellers 
Changes in travel 
behaviour 
Aggregate impact score 

20% 

20% 

60% 

100% 

2A 
0 

0 

0 

0 

Options 

2C1 
+2 

2C2 
+2 

+3 

+3 

+3 

+3 

2B 
0 

+1 

+1 

2C3 
+1 

+2 

+2 

2D 
+4 

+5 

+4 

+0.8 

+2.8 

+2.8 

+1.8 

+4.2 

6.2.3.  Return of irregular migrants  

Relevant impacts, criteria and relative weight 

The  policy  options  in  this  problem  area  could  have  impacts  on  two  different  levels, 
namely both in the readmission area and in the visa area.  

Firstly, if the (positive or negative) incentive measures work, third countries' cooperation 
on readmission will improve and greater number of irregular migrants or refused asylum 
applicants  can  be  returned  to  their  countries  of  origin.  These  improved  return  rates 
would  have  positive  impacts  in  terms  of  cost  savings  for  Member  States'  public 
authorities  (for  housing,  food,  administration  and  related  expenses),  higher  security, 
better  acceptance  of  the  EU  migration  policy  and  a  deterrent  effect  on  potential  future 

37 

 
 
irregular migrants. These impacts (which are all a consequence of change in return rates) 
will be assessed jointly. 

Secondly, the positive or negative incentives – if ever applied – might have effects in the 
visa area. Changes in visa fees, visa procedures or issuing of MEV with long validity will 
have  an  influence  on  costs  for  visa  applicants  and  ultimately  their  travel  behaviour 
(with  related  consequences  for  employment  and  growth  in  the  EU,  as  argued  in  more 
detail above).  

Finally, a relaxing or tightening of visa policy as a result of linking it with third countries' 
cooperation  on  readmission  will  have  positive  or  negative  impacts  on  the  EU's  and 
Member States' relations with third countries and the EU's image in the world.  

The following weighting will be attached to the three impact criteria. The greatest weight 
is given to improved return rates, as these are most directly linked to the policy objective. 
Changes in travel behaviour will not be given a strong weight, as only few third countries 
are likely to be affected. Any possible impact on external relations will also be duly taken 
into consideration, but will be given less weight than the main objective. 

Improved return rates 
Changes in travel behaviour 
External relations / image of EU 

60% 
10% 
30% 

Qualitative assessment of impacts  

The  "toolbox"  approach  (policy  option  3A:  status  quo)  is  an  internal  Council 
instrument  developed  for  the  purpose  of  reinforcing  the  link  between  readmission  and 
visa,  in  particular  in  the  context  of  ongoing  negotiations  with  third  countries.  The 
measures  in  the  toolbox  were  developed  within  the  limits  of  the  current  rules  (Visa 
Code).  A  specific  set  of  visa  measures  that  would  be  applied,  on  a  case-by-case  basis, 
with regard to a given third country after a political commitment to implement them has 
been taken. As the status quo option the performance is ranked +/-0 on all three criteria. 

The effect of policy option 3B (positive incentives) on return rates is likely to be weak 
and  could  be  counterproductive.  The  scope  of  visa  facilitations  that  can  be  offered  to 
countries with high migratory risk without putting at risk the integrity of visa procedures 
and  the  security  of  the  Schengen  area  is  by  definition  limited  and  therefore  rather 
unlikely  to  overcome  governments'  reluctance  in  cooperating  with  Member  States  with 
readmission  procedures  in  many  cases.  This  is  corroborated  by  the  EU's  recent 
experience  in  combining  the  negotiations  on  readmission  agreements  with  visa 
facilitation  agreements53.  Moreover,  offering  such  facilitations  to  previously  non-
cooperative  third  countries  might  even  have  a  counterproductive  effect  on  already 

53  

Progress in most ongoing parallel negotiations with countries in the southern neighbourhood (e.g. 
Morocco, Tunisia, Jordan) is limited, as third countries consider that the visa facilitations offered by 
the EU are not substantial enough to justify concessions in the readmission area.  

38 

 
 
                                                            
cooperative  countries  which  could  consider  unfair  that  they  are  not  being  offered  any 
facilitations  and  might  be  encouraged  to  cease  their  cooperation  with  a  view  to  being 
offered similar advantages. Therefore the limited positive impact such positive incentives 
will  have  on  return  rates  is  likely  to  be  neutralised  (+/-0).  As  visa  facilitations  are  not 
likely  to  materialise  for  many  third  countries,  any  positive  impact  on  travel  behaviour 
will  be  negligible  (+/-0).  This  option  is  therefore  not  likely  to  have  any  positive  (or 
negative) effects for external relations and the EU's image in the world either (+/-0). 

Policy  options  3C1  ('maximum'  negative  incentives)  and  3C2  ('targeted'  negative 
incentives) are likely to have a stronger impact on return rates. The negative incentives, 
in  particular  the  increase  of  the  visa  fee  and  the  decision  not  to  issue  MEV  anymore, 
would  have  a  deterrent  effect  on  third  countries'  governments,  even  before  those 
'sanctions' would be applied. The possibility of imposing negative incentives in the visa 
area as a credible measure would already provide substantial leverage in discussions with 
a third country government on readmission. While it is unlikely that measures in the visa 
area  alone  will  have  sufficient  influence,  it  can  be  assumed  that  –  in  conjunction  with 
other incentives in the area of development cooperation and/or external trade – they can 
contribute to encouraging governments to better cooperate with Member States and lead 
to higher rates of return of irregular migrants (+2).  

As  it  can  be  expected  that  the  negative  incentives  will  have  a  deterrent  effect  and  will 
thus  be  applied  in  a  limited  number  of  cases,  it  is  not  likely  that  there  will  be  strong 
consequences  for  the  amount  of  overall  travel  to  the  EU  from  visa-required  countries. 
Therefore it can be considered that the overall impact on travel behaviour and the knock-
on effects on employment and growth will be weak (-1).  

The linking of readmission policy with negative incentives as regards the issuing of visas 
could  have  negative  consequences  for  the  EU's  and/or  Member  States'  relations  with 
those countries and the EU's image in the world. In that context it can be assumed that 
option  3C1  which  would  target  the  entire  population  from  the  beginning  with  a  wide 
range  of  measures  would  be  seen  more  negatively  (-2)  than  the  targeted  and  gradual 
approach in option 3C2 which would have a limited scope of measures and would first 
target the government employees (-1).  

Overview  

Impact criteria 

Weight 

Options 

Improved return rates 
Changes in travel behaviour 
External relations / image of EU 
Aggregate impact score 

60% 
10% 
30% 
100% 

3A 
0 
0 
0 
0 

3B 
0 
0 
0 
0 

3C1 
+2 
-1 
-2 
+0.5 

3C2 
+2 
-1 
-1 
+0.8 

39 

 
 
6.3. 

Sensitivity analysis 

Given the scarcity of quantitative data to assess the economic, social and other impacts of 
the  various  policy  options,  both  the  weighting  of  impact  criteria  and  the  performance 
score of policy options are in most cases the result of a qualitative assessment based on 
the  best  assumptions  and  estimations  available.  Even  though  the  multi-criteria  analysis 
(MCA) has been substantiated by facts and arguments, it cannot be guaranteed that the 
results  are  devoid  of  possible  errors  of  judgment,  and  they  should  be  taken  with  the 
necessary caution.  

A  sensitivity  analysis  has  been  conducted  to  verify  to  what  extent  a  change  of  the 
weighting would influence the results of the MCA.54 Instead of giving different weights 
to the most important impact criteria identified, the same weight would be attached to all 
criteria. For the first and second problem areas (insufficient financial resources, repeated 
visa  procedures),  the  comparative  ranking  of  policy  options  would  not  change.  For  the 
third  problem  area  (return  of  irregular  migrants),  the  ranking  would  be  affected  by  a 
different  weighting  of  the  impact  criteria.  The  best-ranking  option  (3C2,  targeted 
negative incentives) in the assessment above would get the same score as the status quo 
option  (3A)  and  the  positive  incentives  (3B);  only  the  maximum  negative  incentives 
(option 3C1) would score worse. This change of ranking is due to higher weight given to 
negative  effects  on  travel  behaviour  –  which  is,  however,  unjustified,  given  the  small 
number of countries and persons that are likely to be affected.  

7. 

HOW DO THE OPTIONS COMPARE? 

7.1. 

Insufficient financial resources 

The best-rated policy option in the aggregate impact score is option 1C3 (common visa 
fee of EUR 120), followed by options 1C2 (EUR 100) and then 1C1 (EUR 80) and 1C4 
(EUR 80 for SEV and MEV up to 6 months, EUR 120 for MEV of 1-5 years). 

Effectiveness  

As  argued  above,  an  increase  of  the  EU's  common  visa  fee  would  clearly  be  more 
effective in reaching the policy objective of ensuring that the level of the visa provides 
sufficient  financial  resources  to  Member  States  in  order  to  safeguard  the  quality  and 
integrity of visa processing, than a re-nationalisation of the visa fee (option 1B), which 
might  even  be  counter-productive  (-).  Options  1C1  to  1C4  are  all  effective  in  making 
positive contributions to the objective of ensuring sufficient financial resources for visa 
processing.  The  effectiveness  increases  proportionally  to  the  rise  in  the  visa  fee:  nine 
Member States have provided calculations of administrative costs or otherwise suggested 
a visa fee (see section 5.2.1). The level calculated or suggested by three Member States 
would be met by a visa fee of EUR 80 (option 1C1 and 1C4) (+), for six of them a visa 

54  

See full results in Annex 8. 

40 

 
                                                            
fee of EUR 100 (option 1C2) would sufficient (++), and a visa fee of EUR 120 (option 
1C3) would meet (or exceed) the costs of eight of those Member States (+++).  

Proportionality 

Even though the visa fee has not been raised since 2006, the most proportionate option 
seems to be an increase by 33% to EUR 80 (++).  Had the visa fee been increased each 
year since 2006 on the basis of the general EU-wide inflation rate55, it would stand today 
at around EUR 73.85. Also the lowest estimate of actual visa-processing costs provided 
by  a  Member  State  is  EUR  69.  Higher  increases  (by  67%  or  100%)  seem  increasingly 
difficult  to  justify  towards  third  countries  and  applicants  are  therefore  deemed 
disproportionate (- and - - respectively). Intermediary solutions would be a general visa 
fee  of  EUR  80  with  higher  fees  for  long-validity  MEV  (++)  or  national  fees  based  on 
actual administrative costs (++). 

Feasibility and coherence 

Re-nationalising  the  visa  fee  has  neither  been  supported  by  any  stakeholder  nor  is  it 
coherent  with  the  goal  of  a  harmonised  visa  policy  flanking  the  common  area  without 
internal  borders.  In  practice  it  would  be  difficult  to  get  all  Member  States  to  apply  the 
same calculation of real administrative costs, and there is a serious risk of visa shopping 
with all negative consequences involved (- - -). 

A  moderate  increase  of  the  visa  fee  would  seem  the  most  coherent  and  feasible  option 
(+++), with feasibility declining with higher increases (++ and + respectively).  

The  option  of  a  moderate  increase  of  the  general  visa  fee,  combined  with  a  higher 
increase for long-validity MEV seems to be 'fair' at first sight and has been supported by 
three Member States in the targeted consultation. However, it would create problems in 
practice,  as  neither  the  applicant  nor  the  ESP  /  consulate  collecting  the  visa  fee  would 
know at the outset the final amount of the visa fee – which would depend on the outcome 
of the examination and decision by the visa officer. In some cases part of the fee would 
have to be reimbursed (or paid in addition) after the decision has been taken, creating an 
additional  procedural  step  and  considerable  administrative  burden,  taking  into  account 
more  than  15  million  visa  applications  yearly.  Therefore  most  Member  States  have 
rejected this option, and the practical feasibility is assessed negatively (-).  

55  

Eurostat, HICP – inflation rate, 
http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tec00118&plugi
n=1.  

41 

 
 
 
 
 
                                                            
Overview  

Impact criteria 

Options 

Aggregate impact score 
Effectiveness 
Proportionality 
Feasibility / coherence 

0 
0 
0 
0 

1A 

1B 
+0.2 
- 
++ 
- - - 

1C1 

1C2 

1C3 

1C4 

+0.6 
+ 
++ 
+++ 

+0.8 
++ 
- 
++ 

+1.0 
+++ 
- - 
+ 

+0.6 
+ 
++ 
- 

7.2.  Repeated visa procedures 

The best-rated policy option in the aggregate impact score is option 2D (standard MEV 
with  2  or  5-year  validity),  followed  by  options  2C1  (general  MEV  cascade)  and  2C2 
(general and country MEV cascades). 

Effectiveness  

Option  2D  (standard  MEV  with  long  validity)  clearly  would  be  the  most  effective  in 
meeting  the  policy  objective  of  ensuring  more  systematic  and  harmonised  issuing  of 
multiple-entry visas with long validity to bona fide regular travellers (+++). It would be 
followed  by  the  two  options  (2C1  and  2C2)  providing  for  a  "one-size-fits-all"  MEV 
cascade at EU level or a "fall-back" MEV cascade combined with country cascades (both 
++) and then option 2C3 providing for MEV cascades country-by country only (+). The 
non-regulatory option (2B) would not be very effective in meeting the objective (0). 

Proportionality 

None  of  the  options  seem  disproportionate.  Option  2D  (standard  MEV  with  long 
validity),  though  presenting a  simple  and  straightforward  solution,  would  constitute  the 
most radical departure from Member States' current practices and could therefore be seen 
as  going  to  some  extent  beyond  what  is  necessary  to  achieve  the  objective  (-).  The 
options  with  MEV  cascades  (2C1,  2C2  and  2C3)  correspond  to  what  some  Member 
States  already  practice  and  therefore  seem  to  be  more  proportionate.  The  possibility  to 
adapt the MEV cascade to a third country's local circumstances (options 2C2 and 2C3) 
increases flexibility and therefore ensures a higher degree of proportionality (+++) than a 
MEV  cascade  that  would  apply  in  the  same  manner  worldwide  (option  2C1)  (+).  The 
non-regulatory  option  (2B)  will  have  produce  little  change  and  are  therefore  are 
considered neutral as regards proportionality (0).  

Feasibility and coherence 

Option  2D  (standard  MEV  with  long  validity),  though  being  the  most  effective,  is  not 
coherent  with  either  the  current  rationale  of  the  Visa  Code,  the  Visa  Facilitation 
Agreements  signed  with  third  countries  or  Member  States'  practices  that  all  point  to  a 
"progressive" increase in the length of validity of visas. While some travel and tourism 
stakeholders would certainly favour a complete change of practice, mirroring the 10-year 
visas routinely issued by the United States or Canada, no Member State has advocated it. 

42 

 
 
Its  coherence  and  practical  feasibility  is  therefore  judged  rather  weak  (-).  Similarly 
options 2C1, 2C2 and 2C3, which are all variations of the MEV cascade are in line with 
the approach already used in some VFA and can therefore be assessed as both coherent 
and feasible in practice (++). The non-regulatory option is of course even more feasible 
(+++).  

Overview  

Impact criteria 

Aggregate impact score 
Effectiveness 
Proportionality 
Feasibility / coherence 

2A 

0 
0 
0 
0 

2B 
+0.8 
0 
0 
+++ 

Options 

2C1 

2C2 

2C3 

+2.8 
++ 
+ 
++ 

+2.8 
++ 
+++ 
++ 

+1.8 
+ 
+++ 
++ 

2D 
+4.2 
+++ 
- 
-   

7.3.  Return of irregular migrants  

The  best-rated  policy  option  in  the  aggregate  impact  score  is  option  3C2  (negative 
incentives,  targeted  approach),  followed  by  options  3C1  (negative  incentives, 
maximum approach). 

Effectiveness  

While the current 'toolbox approach' (status quo) has had some merit in bringing the first 
targeted  third  country  to  cooperate  better  with  Member  States  on  readmission,  it  might 
quickly show its limitations when Member States will be required to apply the measures. 
The  Visa  Code  currently  imposes  strict  limits  regarding  the  margin  of  manoeuvre  of 
Member States, thus limiting the effectiveness of the mechanism (0). As argued above, 
the  positive  incentives  might  not  only  have  little  effect,  but  might  even  be 
counterproductive in reaching the policy objective (-). The negative incentives are likely 
to  be  the  most  effective  approach,  albeit  only  in  combination  with  other  measures  in 
development cooperation or trade (++).  

Proportionality 

While  the  positive  incentives  would  not  go  beyond  what  is  necessary  to  achieve  the 
objective and therefore respect the principle of proportionality (+), the policy option 3C2 
with  its  gradual  and  targeted  approach  (targeting  government  officials  first,  as  they  are 
responsible for the country's policy on readmission, while keeping negative sanctions for 
the country's general population as the ultima ratio) is best adapted to the objective and 
therefore ranks best in terms of proportionality (++). The maximum negative incentives 
that would immediately hit the entire population of the third country would seem to go 
beyond what is necessary (--). 

43 

 
 
 
 
Feasibility and coherence 

While  both  the  positive  and  negative  incentives  appear  feasible  and  coherent  (+),  the 
'targeted'  negative  incentives  –  due  to  the  gradual  approach  –  are  most  likely  to  be 
implemented and thus work in practice (++). 

Overview  

Impact criteria 

Options 

Aggregate impact score 
Effectiveness 
Proportionality 
Feasibility / coherence 

3A 
0 
0 
0 
0 

3B 
0 
- 
+ 
+ 

3C1 
+0.5 
++ 
- - 
+ 

3C2 
+0.8 
++ 
++ 
++ 

8. 

PREFERRED OPTIONS 

8.1. 

Insufficient financial resources 

The  preferred  option  is  option  1C1  (common  visa  fee  at  EUR  80).  It  is  not  the  most 
effective  option,  as  higher  fee  increases  would  obviously  generate  higher  financial 
resources. However, it will lead to a sound increase of revenues (+26%), while not being 
a deterrent for the overwhelming majority of visa applicants, for whom an increase of the 
fee by EUR 20 will not be a decisive factor, compared with the price of airline tickets to 
Europe  and  other  costs  involved  in  travel.  In  international  comparison  the  fee  would 
remain relatively low and therefore competitive. Moreover, combined with a mechanism 
to increase the fee on a two-yearly basis (for instance by the inflation rate), this option 
presents a solution that will not need to be revisited in the near to medium future.  

8.2.  Repeated visa procedures 

The preferred option is option 2C2 (less generous "one-size-fits-all" MEV cascade at EU 
level  and  the  possibility  of  more  favourable  cascades  for  specific  countries,  limited  to 
countries  cooperating  on  readmission).  Though  not  the  most  effective  option  (as  any 
option that would prescribe long-validity MEV as the standard visa to be issued), it will 
achieve  to  a  great  extent  the  objective  of  increasing  the  number  of  long-validity  MEV 
issued. It further combines a minimum standard applicable to all third countries with the 
possibility  of  more  favourable  solutions  for  specific  third  countries,  adapted  to  local 
circumstances  and  migratory  risk.  The  more  favourable  MEV  cascades  for  specific 
countries would take time to be defined and agreed. This option therefore combines the 
advantages of options 2C1 and 2C3.  

8.3.  Return of irregular migrants  

The preferred option is option 3C2 (targeted negative incentives). Negative measures in 
the  visa  area  are  likely  to  be  the  most  effective  in  bringing  change  in  third  country 
governments  towards  cooperation  with  Member  States  on  readmission  of  irregular 

44 

 
 
migrants,  even  though  they  might  need  to  be  combined  with  measures  in  other  policy 
areas (e.g. development cooperation, trade) to be fully successful. At the same time the 
gradual  approach  –  targeting  at  first  the  government  officials  of  the  country  concerned 
before aiming, as the ultima ratio, at the general population – is the most appropriate and 
proportionate  approach  and  will  entail  the  least  negative  consequences  for  travelling, 
economic sectors and the EU's standing and reputation.  

As outlined in the description of policy options (section 5.2.3), it is possible to combine 
the negative incentives with some elements of positive incentives. However, they should 
be  designed  in  a  way  that  would  not  lead  counterproductive  effects  by  discouraging 
cooperative  third  countries  from  pursing  their  cooperation  on  readmission.  A  possible 
method would be – in preferred option 2C2 – to reserve more favourable MEV cascades 
for specific countries to those which cooperate well with Member States on readmission. 

8.4.  REFIT (simplification and improved efficiency) 

Initiatives  to  amend  existing  legislation  are  by  definition  subject  to  Regulatory  Fitness 
and  Performance  (REFIT)56  requirements.  The  scope  for  simplification  and  improving 
the  efficiency  of  the  Visa  Code  by  reducing  regulatory  costs  should  be  explored. 
Simplification and cost reduction are achieved in two ways by the envisaged initiative. 

First, the main simplification measure both for applicants and consulates is the increased 
issuing  of  MEV  with  long  validity,  as  envisaged  in  the  preferred  option  2C2.  It  will 
considerably reduce the number of visa procedures that frequent travellers to the EU have 
to  go  through.  The  cost  reduction  potential  both  for  applicants  and  consulates  is 
thoroughly assessed in this report (in particular in section 6.2.2).  

Secondly, a significant number of measures likely to be carried over from the 2014 Visa 
Code  recast  proposal  aim  at  simplifying  visa  procedures,  clarifying  provisions  and  in 
many  cases  also  reducing  costs  for  visa  applicants  and  Member  States.  Their  expected 
impact will be briefly assessed in annex 7.     

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

Three years after start of application of the revised Visa Code (i.e. three and a half years 
after  its  entry  into  force),  the  Commission  will  present  an  evaluation  report.  It  should 
assess  the  progress  with  respect  to  the  three  main  problem  areas  and  policy  objectives 
addressed in this report.  

The monitoring will be facilitated by three developments: Firstly, the Entry-Exit System 
(EES)  is  scheduled  to  be  operational  by  2020,  making  it  possible  to  obtain  precise 
statistics  on  travel  to  the  EU  by  visa-required  third-country  nationals.  Secondly  it  is 
planned  in  the  framework  of  the  revision  of  the  VIS  legal  framework  to  authorise  eu-
LISA to provide the Commission with more comprehensive statistics extracted from the 

56  

For more information on the REFIT programme, see: https://ec.europa.eu/info/law/law-making-
process/evaluating-and-improving-existing-laws/refit-making-eu-law-simpler-and-less-costly_en  

45 

 
                                                            
VIS, including on the length of validity of visas issued. This would provide precise data 
on  the  share  of  MEV  with  long  validity  issued  by  Member  States.  Finally,  once  the 
Regulation  on  the  use  of  the  Schengen  Information  System  for  the  return  of  illegally 
staying  third-country  nationals57  is  adopted  and  implemented,  return  decisions  and 
effective returns will be recorded in the Schengen Information System, thus substantially 
improving the availability of precise data.  

The table below provides more detailed suggestions for potential indicators and methods 
for data collection.  

Problem area 

Potential indicators 

Insufficient financial resources 

Repeated visa procedures 

Return of irregular migrants  

- income from visa fee 
- real administrative costs of issuing 
visas 
-  changes  in  travel  behaviour  as  a 
result of the increased visa fee 

-  length  of  validity  of  visas  issued 
(less  than  1  year,  1-year,  2-year,  3-
year, 4-year, 5-year) 
-  changes  in  travel  behaviour  as  a 
result of increased issuing of MEVs 
with long validity (per nationality) 
- number of cases where visa policy 
is  raised  in  negotiations  with  non-
cooperative third countries 
-  number  of  cases  where  negative 
incentives are being applied to non-
cooperative third countries 
- change in return rate for those 
non-cooperative third countries 
- change in the number of 
return/readmission agreements and 
or informal arrangements 
-  Member States' feedback on level 
of cooperation with third countries 

Method of data collection / 
source 
Survey among Member States  

EES statistics on entry and exit of 
visa-required third-country 
nationals (eu-LISA) 
VIS statistics (eu-LISA) 

EES statistics on entry and exit of 
visa-required third-country 
nationals (eu-LISA) 
DG HOME's own information 

Eurostat statistics, SIS statistics 
on return (eu-LISA) 
DG HOME's own information 

These  indicators  will  be  used  to  monitor  developments  in  the  three  problem  areas 
addressed by this report and to evaluate the revised regulation, three years after the start 
of application. In the best-case scenario, the revised Visa Code will be adopted in 2019 
and  become  applicable  by  the  end  of  that  year.  The  evaluation  would  be  due  by  end 
2022. As the EES is scheduled to be operational by 2020, the first annual figures should 
be available at the end of 2021. Annual data for the purpose of the evaluation would be 
available for 2021 and 2022. As regards the VIS legislative initiative, entry into force is 
not likely before 2020, leading to a similar time period of relevant data. 

57  

COM(2016) 881 final. 

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
Annex 1: Procedural information 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

The  lead DG is the Directorate-General for Migration and Home Affairs (DG HOME). 
The  Decide  Planning  reference  is  PLAN/2017/2083.  The  initiative  is  mentioned  in  the 
Commission Work Programme for 2018 (COM(2017) 650 final), annex I, item n° 20. 

10.  ORGANISATION AND TIMING 

Work to prepare the draft proposal and the impact assessment began in early November 
2017.  The  inter-service  steering  group  for  the  impact  assessment  was  composed  of  the 
Secretariat General (SG), the Legal Service (SJ), the European External Action Service 
(EEAS), DG JUST, DG GROW, DG TRADE, DG DEVCO, DG NEAR, DG MARE and 
DG EAC. Two meetings were held, on 17 November 2017 and 25 January 2018. 

11.  CONSULTATION OF THE RSB 

The  draft  impact  assessment  was  submitted  to  the  Regulatory  Scrutiny  Board  on  31 
January  2018;  an  updated  version  including  the  full  results  of  the  open  stakeholder 
consultation, which ended on 2 February 2018, was submitted on 7 February 2018. The 
Board  examined  the  draft  Impact  Assessment  on  21  February  2018  and  delivered  a 
positive opinion on 23 February 2018. The RSB's comments and suggestions were taken 
into account in the final version.  

12.  EVIDENCE, SOURCES AND QUALITY 

Serious efforts have been made to collect data, facts and figures to support the problem 
definition,  the  baseline  scenario,  and  the  assessment  of  impacts  of  the  various  policy 
options.  The  2014  evaluation  of  the  Visa  Code  was  updated  with  available  data  (see 
annex  4).  Data  from  a  2016  questionnaire  survey  on  visa  fees  were  used.  Targeted 
stakeholder  consultations  and  an  open  public  consultation  were  organised  to  collect 
evidence (see annex  2).  The ample experience gathered by the Commission services in 
monitoring  Member  States'  implementation  of  the  visa  policy,  notably  through  the  in-
depth Schengen evaluations has been exploited wherever possible. 

It must be acknowledged, however, that much of this information is rather of qualitative 
than  quantitative  nature  and  that  even  basic  data  are  missing  in  relation  to  the  three 
problem  areas  covered  in  the  impact  assessment,  e.g.  on  the  length  of  validity  of  visas 
issued by Member States. In the short time available to carry out this impact assessment, 
it was not possible to conduct an external study to gather more data than those already 
available.  

There are several reasons behind the lack of reliable data. The focus of the visa policy is 
the fight against irregular immigration and security risks by harmonising the conditions 
and procedures of processing visas. Economic issues of costs, benefits and administrative 

47 

 
burden  were  traditionally  considered  secondary  by  the  co-legislators  in  this  area.  The 
legislation  in  force  does  not  foresee  appropriate  indicators  to  be  collected  from  the 
Schengen  States  or  from  other  sources.  It  is  generally  acknowledged  that  it  is  very 
difficult to determine quantifiable indicators in this area.  

As regards the administrative costs of Member States, it must be noted that there are 26 
Schengen States having more than 2000 Schengen visa issuing consulates in approx. 170 
countries. Operating costs differ from Schengen State to Schengen State, third country to 
third country and consulate to consulate. The most important cost components relate to 
the premises, personnel, operating and security-related equipment. It is very difficult to 
separate  the  visa  processing  from  other  tasks  carried  out  by  embassies/consulates.  The 
visa  section  is  usually  located  in  the  building  of  the  embassy/consulate;  even  if  it  is 
physically  separate,  the personnel  carries  out  many  other  tasks  not  related  to  Schengen 
visa  processing,  such  as  consular  assistance,  classical  administrative  services  for  own 
nationals, passports and residence permits. At smaller missions, consular staff also carry 
out diplomatic duties. Similarly, the equipment is not only used for issuing visas but also 
for  managing  other  tasks,  reception  of  own  nationals,  issuing  of  passports.  The  data 
gathered  are  not  representative  and  vary  considerably  between  Schengen  States  which 
means that the method of cost calculation (if any) also varies between Schengen States. 
Most Schengen States do not even have specific statistics, only estimations regarding the 
revenues  from  the  visa  fee.  That  is  why  it  was  impossible  to  set  "Schengen  averages" 
regarding the cost of processing a visa for the Schengen States. 

A similar explanation applies to the costs and benefits on the applicants' side, which also 
depends  on  many  factors  such  as  the  place  of  residence  (i.e.  distance  to  the  competent 
consulate),  the  purpose  and  length  of  the  intended  trip  and  the  visa  history  of  the 
applicant. Although it is recognised that the visa requirement and procedures can indeed 
influence  travel  flows,  providing  quantifiable  evidence  to  what  extent  there  is  such  an 
impact  is  even  more  challenging.  There  are  many  other  factors  influencing  the 
destination choice, such as travelling costs, security and safety issues, available services 
in the country to be visited, exchange rates. Without conducting a worldwide study with 
a representative number of visa applicants in a representative number of third countries, 
it is not possible to determine to what extent changes in the visa procedure (such as on 
the visa fee and the issuing of MEV) will lead to changes in applicants' and visa holders' 
travel hehaviour. Recent studies and research only revealed little empirical evidence on 
this issue. Therefore it has been impossible to reliably estimate and quantify the scale of 
effects of policy options (particularly the economic and financial impacts). 

Therefore this impact assessment is to a great extent based on a qualitative assessment of 
impacts, based on Member States' experience and the Commission's Schengen evaluation 
reports, as explained in detail in secion 6.1 of this report.  

48 

 
 
 
 
Annex 2: Stakeholder consultation  

In  preparation  of  the  targeted  revision  of  the  Visa  Code,  the  accompanying  Impact 
Assessment and the Commission Communication, the Commission services conducted a 
stakeholder  consultation  between  November  2017  and  February  2018.  The  main 
objective was to gather the views and experiences of the 'main users' of the Visa Code in 
order  to  improve  procedures  for  obtaining  visas  while  keeping  in  mind  the  current 
migratory and security challenges. As a similar consultation was last conducted in 2014 
in  connection  with  the  evaluation  of  the  Visa  Code  and  the  accompanying  legislative 
proposals, the present stakeholder consultation was intended to update and complement 
the views collected at the time.58 

The  consultation  was  organised  in  two  separate  phases  targeting  selected  stakeholders 
and  the  public.  First,  Member  States,  Members  of  the  European  Parliament  and  the 
representatives of the main interest groups and professional organisations participated in 
three separate meetings, where they were given the opportunity to present their views to 
the Commission services on the basis of a discussion paper raising the following issues: 

  Minimising administrative burdens for consulates and applicants alike 
  Harmonising rules on issuing multiple-entry visas 
  Linking visa issuing rules to the cooperation of third countries on readmission 
  Revising the level of the visa fee 
  Assessing the use of outsourcing 
  Digitalising the visa issuing procedure 
  Reconsidering the nationality-based visa requirements in the long term 

Participants also had the opportunity to submit written position papers after the meetings. 
Second,  an  open  public  consultation  was  conducted  through  an  internet-based  survey 
between 24 November 2017 and 2 February 2018, targeting visa applicants and citizens 
who  wished  to  give  their  input  on  the  modernisation  of  the  EU's  visa  policy. 
Organisations also had the opportunity to submit position papers through the open public 
consultation. 

I. Consultation meetings 

1. Member States 

The  first  meeting  took  place  on  13  November  2017,  with  representatives  of  all  the 
Member  States  present.  20  Member  States  also  submitted  written  comments  after  the 
meeting. 

Regarding  minimising  administrative  burdens,  six  Member  States  noted  that  it  is 
important  not  to  mix  up  procedural  burdens  with  requirements  necessary  for  assessing 
migratory and security risk. Procedural facilitations should not put security and migratory 
concerns at stake. All relevant supporting documents should be submitted and deadlines 
for decision making should not be shortened. Many Member States made suggestions on 
current  practices  that  could  be  eliminated  in  a  revision  of  the  Visa  Code,  such  as  the 

58  

See Annexes 4 and 5 of the 2014 Impact Assessment for a summary of the stakeholder consultation 
activities at the time: SWD(2014) 68 final 

49 

 
 
                                                            
mandatory  lodging  in  person  of  the  visa  application  or  the  right  of  applicants  to  lodge 
directly at consulates rather than external service providers. 

A clear majority of Member States that took the floor on the harmonisation of practices 
regarding  the  issuing  of  multiple-entry  visas  (MEVs)  were  in  favour  of  creating 
clearer rules, possibly using a 'cascade' approach whereby applicants who have lawfully 
used their previous visas in a certain time span receive MEVs with a progressively longer 
validity  period.  Three  Member  States  suggested  that  the  Local  Schengen  Cooperation 
among Member States in third countries could play a role in adapting the MEV issuing 
practices  to  local  circumstances,  which  would  be  formally  adopted  as  a  Commission 
implementing act following consultation of the Visa Committee. 

Concerning a link between visa issuing rules and the cooperation of third countries 
on readmission, the vast majority of Member States are in favour of using visa policy as 
a  leverage  to  improve  cooperation  on  readmission.  While  one  Member  State  was  in 
favour  of  the  legal  provisions  agreed  by  Council  during  the  negotiations  on  the  Visa 
Code  recast,  many  others  were  more  reserved  about  incorporating  very  detailed  legal 
provisions  into  the  Visa  Code,  emphasising  that  the  mechanism  for  triggering 
derogations  should  be  as  simple  as  possible  and  the  derogations  should  be  easily 
applicable  so  as  not  to  create  additional  burden  for  consulates.  Five  Member  States 
favoured  a  case-by-case  political  decision  within  the  existing  legal  framework,  arguing 
that such an approach would be more efficient and flexible.  

Regarding the level of the visa fee, almost all Member States favoured an increase, but 
they  recognised  that  it  is  impossible  to  calculate  the  unique  'cost'  of  processing  a  visa 
application. Several Member States therefore suggested no longer linking the visa fee to 
the administrative costs, but rather taking a political decision to set it at a certain level. 
Some Member States argued that any increase should be modest so not to prevent travel 
for tourism purpose. A handful of Member States suggested that the level of the visa fee 
could  be  country  specific,  with  a  role  for  Local  Schengen  Cooperation  in  helping 
determine the appropriate fee, whereas others recalled the need for a straightforward and 
simple system. One Member State suggested that higher fees  (+50%) be charged when 
visas  are  issued  at  the  external  borders.  A  number  of  Member  States  noted  that  the 
reduced visa fee applied under the Visa Facilitation Agreements certainly does not cover 
the  administrative  costs.  Two  Member  States  were  explicitly  in  favour  of  applying  a 
progressive fee linked to the length of validity of the visa applied for; however, another 
Member State recalled that such a system could create additional administrative burden 
in terms of appeals and reimbursements in case the visa issued does not correspond to the 
fee paid. 

All  Member  States  declared  their  satisfaction  with  the  cooperation  with  external 
service providers, which they consider indispensable for visa processing. Most Member 
States  would  be  in  favour  of  strengthening  the  legal  framework  so  that  it  reflects  this 
reality, including more stringent rules on monitoring. Some Member States argued for an 
increase  in  the  service  fee  (now  fixed  at  maximum  50%  of  the  visa  fee,  i.e.  30  EUR) 
charged by external service providers in specific third countries. 

Regarding  the  digitalisation  of  visa  processing,  all  Member  States  that  took  the  floor 
argued that priority should be given to the development of a digital visa, whereas fully 
on-line  applications  are  a  rather  long  term  perspective.  Studies  should  be  launched  on 
both issues, although some Member States preferred to wait until EES and ETIAS are in 
place before proceeding further on digital visas.  

50 

 
Regarding  the  differentiation  of  visa  requirements  based  on  nationality  or  on 
individual travellers' profile,  a handful  of Member States would  be in  favour  of further 
discussions  on  differentiating  between  travellers,  while  some  others  noted  that  such  an 
individual  approach  could  raise  problems  regarding  visa  reciprocity.  A  number  of 
Member  States  suggested  a  critical  revision  of  Annex  II  (visa-free  countries)  to 
Regulation 539/2001. The clear majority of Member States, though, preferred to maintain 
to  the  current  nationality-based  system;  only  once  ETIAS  and  EES  are  firmly  in  place 
could  another  approach  be  considered.  A  majority  of  Member  States  considered  that 
there is no need to revise Regulation 539/2001 at this point in time. 

2. Members of the European Parliament 

The Commission services participated in a meeting on 12 December 2017 in Strasbourg, 
where the coordinators of the political groups in the LIBE committee and the rapporteurs 
and shadow rapporteurs on the legislative proposals of the 2014 visa package gave their 
views on the modernisation of the EU's visa policy.  

The  MEPs  from  the  EPP  group  considered  that  time  had  been  lost  since  the  2014 
proposals, in part because of Parliament's position on humanitarian visas. They asked not 
to  lose  sight  of  the  economic  dimension  of  visa  policy  (tourism,  business  travel)  and 
considered external service providers to be essential for facilitating visa applications. In 
general  the  MEPs  expressed  general  support  for  the  Commission's  approach  on  the 
targeted  revision  of  the  Visa  Code.  There  was  general  scepticism  about  disconnecting 
visa  policy  from  nationality.  There  was  also  concern  about  how  the  discussion  on  visa 
policy would influence other files on the table in the legal migration and security fields. 

The  S&D  group  expressed  scepticism,  but  was  looking  forward  to  see  Commission 
proposals. Instead of working towards partnerships with third countries, the Commission 
seemed to focus on the EU's narrow self-interest by promoting only the tourism of rich 
people.  "Facilitations"  would  in  reality  just  mean  that  more  personal  data  was  entered 
into  more  and  more  databases.  A  link  between  visa  policy  and  readmission  was  not 
enough and real partnerships with the countries concerned were needed instead.  

The ECR group recalled that the original aim of visa policy was always the prevention 
of migratory and security risks. However, they agreed that now the situation had changed 
dramatically  with  the  terror  attacks  in  the  past  few  months  and  years.  There  was  full 
support for the intention to lower administrative burdens; IT solutions could be of great 
help  in  this  respect.  It  was  necessary  to  link  visa  policy  to  readmission  and  applicants 
should  pay  the  full  cost  of  the  visa  procedure.  The  group  was  opposed  to  full 
harmonisation  of  visa  issuing  practices;  while  there  could  be  coordination,  it  should 
remain  up  to  MS  to  take  the  final  decision.  Nationality  should  remain  the  primary 
criterion for visa policy. 

The  ALDE  group  supported  the  enlargement  of  discussions  to  security  and  migration 
concerns, in addition to the economic dimension. They could back a revision of the visa 
fee and suggested varying fees depending on third countries' cooperation on readmission. 
This,  however,  would  exclude  any  move  away  from  nationality  as  the  criterion  for 
defining  visa  requirements,  an  idea  which  was  met  with  scepticism.  The  group  was 
radically  in  favour  of  harmonising  practices  between  Member  States,  especially  as 
regards the issuing of multiple-entry visas. 

The  GUE-NGL  group  wondered  if  there  were  no  security  and  migration  concerns  in 
2014. Simplification and modernisation were already the objectives of the 2014 proposal, 

51 

 
 
so  they  were  not  convinced  by  a  change  of  strategy.  While  it  might  be  necessary  to 
harmonise  practices  on  multiple-entry  visas,  the  group  considered  that  Commission 
lacked  coherence  by  not  proposing  to  harmonise  asylum  policies  upwards,  too.  The 
group was against raising the visa fee, since this would further limit the right to mobility. 
Suggestions to move away from nationality as the defining criterion would contradict any 
link of visa policy with readmission. 

The Greens-EFA group was not satisfied with the link with readmission and warned of 
unintended  consequences  in  the  cooperation  with  partner  countries.  They  favoured 
harmonisation as long as it was upwards and recalled their support for the touring visa. 
IT  solutions  needed  to  be  carefully  assessed  for  their  data  protection  impact;  the  same 
must  be  done  if  there  is  a  move  away  from  nationality  towards  more  individualised 
approaches, which they look upon favourably. 

3. Stakeholders 

The Commission services organised a targeted consultation meeting with stakeholders on 
20  November  2017.  16  persons  representing  12  organisations  from  the  fields  of  travel, 
tourism,  shipping  and  air  transport  were  present.59  Many  also  provided  written 
contributions after the meeting. 

Concerning  the  reduction  of  administrative  burdens,  the  association  representing 
business travellers noted that facilitations should be available for business travellers that 
often need to depart on short notice and that cannot be without their passport for several 
weeks. 

The  tourism  industry  associations  noted  that  native  language  support,  a  single  point  of 
complete information to the public and a user-friendly and culturally-sensitive approach 
to  applicants  was  essential.  The  application  form  should  be  simplified  and  the  advance 
deadline for lodging applications extended. Applications from persons who had already 
been  granted  visas  should  be  handled  more  flexibly  and  visas  on  arrival  should  be 
considered. The question of which Member State is competent for an application causes 
problems, especially if this country is not represented locally. Applicants should be able 
to lodge their application at any consulate that is located close to their residence. Travel 
medical insurance  should  not  be required at  the time of lodging application.  Generally, 
requirements for supporting documents should be harmonised and their number reduced;  
the  requirement  for  confirmed  hotel  reservations  should  be  replaced  by  an  agency 
guarantee that accommodation will be booked after the final group size is known, or by 
sufficient own means.  

The  association  representing  performing  arts  highlighted  that  other  administrative 
burdens,  such  as  work  permits,  also  play  a  large  role.  The  credibility  of  the  inviting 
agency/sponsor  in  the  EU  should  be  part  of  the  assessment  for  providing  facilitations. 
The association also regretted that following the withdrawal of the touring visa proposal, 
the  legal  gap  regarding  stays  over  90  days  without  staying  for  90  days  in  any  single 
Member State will remain. 

59  

Association of Corporate Travel Executives, Cruise Lines International Association, ECTAA 
(National travel agents’ and tour operators’ associations), European Community Shipowners’ 
Associations, European Tourism Association, European Travel Commission, HOTREC (Hotels, 
Restaurants, Pubs and Cafes in Europe), International Air Transport Association, International 
Association of Amusement Parks and Attractions, International Chamber of Shipping, Pearle* - 
Live Performance Europe, World Travel & Tourism Council,  

52 

 
 
                                                            
The  maritime  transport  associations,  speaking  also  on  behalf  of  the  European  Sectoral 
Social  Dialogue  Committee,  noted  that  the  new  proposal  should  take  into  account 
seafarers'  working  conditions.  Processing  time  should  be  reduced  (10  days)  and 
applications  should  be  allowed  longer  in  advance  (9  months).  In  exceptional 
circumstances, applications at the border should be facilitated. The previous visa history, 
also regarding other countries (US, Australia), should be considered. 

The airlines noted that the visa process should not be a barrier to travel and information 
to the public should be as clear as possible. 

Regarding  the  issuing  of  multiple-entry  visas,  all  associations  were  in  favour  of 
expanding the issuing of MEVs with a longer validity to bona fide applicants, including 
tourists.  From  a  business  traveller  perspective,  MEVs  facilitate  travel  at  short  notice. 
From a tourism perspective, MEVs should be considered as a marketing tool: On the first 
visit,  tourists  go  to  the  most-visited  sites;  by  incentivising  repeat  visits,  lesser-known 
regions in the EU would benefit from more sustainable tourism. For maritime transport, 
MEVs would reduce the complexity of crew changes and decrease the need for visas at 
the  border.  The  airlines  suggested  using  PNR  data  on  applicants'  travel  history  for 
identifying frequent travellers and issuing MEVs. 

All  associations  noted  that  visa  fees  around  the  world  are  not  cost-based  and  the  EU 
should set it with regard to the practice of "competitors". Most considered the fee of 60 
EUR reasonable and did not support an increase. The cost of the visa process should be 
seen as a marketing cost and shouldn't be covered entirely by the fee: the money spent 
(and taxes paid) by travellers in the EU needs to be taken into account. Measures should 
also be taken to reduce the indirect costs of the application process, such as travel to the 
consulate. 

All  associations  appreciated  the  services  provided  by  external  service  providers,  but 
considered that more competition between them was necessary to keep standards up. The 
performing arts association insisted on maintaining the possibility of lodging applications 
directly at consulates. 

All associations urged speedy progress in moving towards an electronic visa and online 
applications.  Any  studies  that  might  still  be  necessary  should  be  targeted  on  technical 
questions. 

Regarding  the  differentiation  of  visa  requirement  based  on  nationality  or  on 
individual travellers' profile, most associations warned of the complexity of introducing 
further criteria besides nationality. The airlines highlighted that requirements need to be 
understood by carriers. The hotels associations suggested waiting for the implementation 
of EES and ETIAS before further options are considered. Some other associations were 
open  to  introducing  additional  criteria  besides  nationality,  such  as  the  country  of 
(permanent)  residence.  In  particular,  the  performing  arts  association  noted  that  the 
purpose  of  travel  could  be  considered.  In  the  same  line,  the  maritime  transport 
travellers.  The  association 
associations  underscored 
representing business travellers was most supportive of moving away from nationality as 
the  sole  criterion,  as  companies  now  have  staff  of  all  nationalities  based  all  over  the 
world. 

that  seafarers  are 

low-risk 

The  associations  representing  maritime  transport  expressed  strong  concern  about  the 
possible  link  between  visa  policy  and  cooperation  on  readmission.  The  associations 
warned  that  only  15%  of  their  crews  come  from  countries  that  have  concluded 
readmission  agreements  with  the  EU;  excluding  Russia,  this  figure  drops  to  5%.  If 
restrictive  measures  were  imposed  on  certain  nationalities  based  on  the  existence  or 

53 

 
absence of readmission agreements, this would unfairly penalise seafarers and jeopardise 
the entire industry. 

II. Open public consultation 

The public consultation was open for 10 weeks (24 November 2017 – 2 February 2018) 
and attracted a total of 1929 responses, of which 1849 were from individual respondents 
and  80  represented  organisations.  Respondents  answering  on  behalf  of  an  organisation 
could also upload a document in order to provide additional information or raise specific 
points  which  were  not  covered  by  the  questionnaire.60  As  the  contributions  by 
organisations corresponded to the opinions expressed during the stakeholder consultation 
(see above), this summary focuses on the responses by individuals.61 

A  large  share  of  the  responses  received  from  respondents  with  Omani  or  Moroccan 
nationality  or  residence  (1385  responses,  72%)  are  suspected  to  be  part  of  campaigns, 
due to the frequency of submissions during a specific period of time and similar patterns 
in responses. These responses are not included in the general assessment, but are instead 
considered separately below. 

The  survey  attracted  responses  from  a  broad  range  of  nationalities,  but  with  a 
weighting towards Belarus (20%) and Russia (18%).62 Nationals of Colombia (5%) and 
Ukraine  (2%)  submitted  responses  despite 
these  nationalities  being  visa-free. 
Respondents had generally applied for Schengen visas in the last five years (89%), with 
more  than  95%  reporting  that  their  visa  was  issued.  63%  of  respondents  travel 
frequently to the Schengen area (more than twice per year).  

As purpose of travel, 43% of respondents named tourism, 21% business or professional 
purposes,  16%  participation  in    political,  scientific,  cultural,  sports  or  religious  events, 
and 11% participation in short-term internship or exchange programmes. Family visits as 
travel purpose accounted for 5% of the replies, with 4% of respondents citing unspecified 
other reasons. 

60  

61 

62  

The list of organisations that submitted additional information can be found at the end of this 
summary. 
 When interpreting the results of the consultation, it is important to note that respondents to the 
open internet-based survey were self-selected. It is therefore not possible to assume that they are 
representative of the wider population of visa applicants worldwide. 
This figure, as all others within this section, excludes respondents who offered no or incomplete 
answers. For example, figures relating to respondent nationality exclude nine responses that gave 
blank or ambiguous information. 

54 

 
 
                                                            
What is your most frequent purpose of travel to the EU? (n=422) 

11% 

16% 

4% 

5% 

21% 

43% 

Tourism

Business/professional

Political, scientific, cultural,
sports, religious event
Short-term internship/exchange
programme
Family visit

Other

In order to apply for a visa, most respondents (90%) did not have to travel abroad. Of 
respondents  who  did  have  to  travel,  including  internal  travel,  many  had  to  travel 
substantial distances. 13% of respondents travelled at least 500km, and 17% travelled for 
five  hours  or  more.  Most  respondents  (78%)  considered  that  the  three-month  limit  for 
lodging  short-stay  visa  applications  before  the  trip  could  be  more  flexible,  helping 
applicants to avoid peak periods/long waiting times at consulates and/or better plan their 
visits. A majority of respondents knew of the opportunity to lodge applications directly at 
consulates (75%), but 15% decided to apply via an external service provider. 

It is  a  general practice  for consulates to  require applicants  to  make  an  appointment  to 
lodge  their  visa  application.  The  appointments  are  supposed  to  take  place  within  two 
weeks  of  the  dates  on  which  they  are  requested.  However,  28%  of  respondents  who 
required appointments signalled that they did not get appointments within two weeks. In 
addition,  30%  of  respondents  believed  the  two-week  timeframe  to  be  unacceptable,  as 
consulates  do  not  allow  urgent  applications  to  be  made  directly  without  appointments. 
On  the  other  hand,  29%  of  respondents  considered  a  two-week  timeframe  for 
appointments  to  be  acceptable,  given  that  in  urgent  cases,  the  requirement  to  make 
appointments is waived. 

With regard to facilitations for repeat applicants, only 16% of frequent travellers had 
been offered any such benefits. Of this group, the most common benefit was receipt of 
multiple-entry  visas  for  longer  periods  than  applied  for  (60%).  Other  less-frequent 
benefits  cited  on  multiple  occasions  included  not  having  to  apply  in  person  (11%)  and 
not  having 
journey  purpose  (6%), 
accommodation (6%), or situation in home country (5%). 

to  present  certain  document(s)  regarding 

55 

 
 
 
 
If you are a frequent traveller and have previously had several 
visas, have you been offered any benefits because of this? (n=330) 

16% 

Yes

No

84% 

While respondents paid visa fees of either 60 or 35 EUR, the average indirect cost of the 
visa  application  can  be  even  higher:  applicants  reported  spending  on  average  EUR  45 
for  travel  medical  insurance  and  around  EUR  60  for  travelling  to  the  consulate  or  visa 
application centre (with a wide distribution: some respondents reported costs of EUR 20 
or less, while others had to spend more than EUR 100 to reach the consulate or external 
service  provider).  The  time  required  to  collect  supporting  documents  and  lodge  a  visa 
application  was  repeatedly  mentioned  as  a  significant  cause  of  additional  costs.  The 
length  of  the  procedure  was  also  identified  as  the  most  difficult  aspect  of  the  visa 
procedure by 26% or respondents. 

What did you find most difficult about the visa procedure? 
- Length of the procedure (n=408) 

11% 

18% 

23% 

26% 

23% 

56 

1 (most difficult)

2

3

4

5 (least difficult)

 
 
 
 
 
The  entire  visa  procedure  took  between  10  and 30  days  for  around  half of  respondents 
(47%), while 40% were able to receive their visas in under 10 days. 13% of respondents 
reported that it took more than one month before they could collect their passports. 

81% of respondents had applied for multiple-entry visas, either because of their regular 
travel needs (64%) or because they had been told that this was the best way to obtain at 
least  a  single-entry  visa  (17%).  While  82%  of  respondents  who  were  issued  visas  had 
received multiple-entry visas, the largest share of respondents (66%) reported receiving 
visas with validity of less than one year. Only 5% of respondents reported receiving visas 
with validity of between four and five years. Of respondents who received multiple-entry 
visas,  around  half  (53%)  reported  having  taken  or  intending  to  take  between  one  and 
three spontaneous trips to the EU during their visas' validity periods. 

If your last visa was for multiple entries, 
what was the period of validity? (n=318) 

5% 

3% 

6% 

28% 

Less than 6 months

6 months - 1 year

1 - 2 years

2 - 3 years

3 - 4 years

4 - 5 years

21% 

38% 

Selected responses to the open questions on obtaining MEVs: 

After having obtained several multiple entry Schengen visas, I was issued a single entry 
visa by the German Embassy despite my request of a multiple entry one and submitting 
insurance  for  180  days.  I  had  another  trip  to  Austria  literally  10  days  after  my  return 
from  Germany  so  I  applied  for  another  Schengen  visa  at  the  Austrian  Embassy  which 
took  longer  than  usual  so  I  had  to  retrieve  my  passport  one  day  before  departure  to 
Germany and send it back after my return. That was undue hassle. 

A respondent from Jordan 

Last  year  I  received  a  one-year  Greek  multiple  entry  visa  and  travelled  to  Schengen 
countries 3 times. Since I used it correctly, this year I received a three-year Greek visa. 

57 

 
 
  
 
 
 
It's very nice and right, but the most countries don't give such long visas even to active 
travellers. 

A respondent from Russia 

I have found that some countries give multiple entry visa for longer duration (8 months 
and  3  years  in  my  case)  considering  your  past  travels  to  Schengen  countries  but  other 
countries […] did not consider my multiple entry request despite of showing my years of 
travel through Schengen countries. In fact, I lived in Spain for over 4 years in the past, 
and even that was not considered. I found this dissimilarity between Schengen states for 
difficult. 

A respondent from Ireland 

Use of multiple entry visas makes travel to EU countries so much easier that the border 
doesn't  feel  like  an  Iron  Curtain  anymore.  It  facilitates  the  short  occasional  trips,  for 
business  or  personal  purposes.  I  think  getting  multi  visas  should  be  encouraged, 
especially for young people. 

A respondent from Russia 

I found that some consulates are more reluctant to give a multiple entry long term visa. 

A respondent from Israel 

There are certain documents that one Member State might require whereas others might 
not.  That  said,  the  bulk  of  the  required  documents  are  identical.  Moreover,  Member 
States'  willingness  to  issue  visas  for  multiple  entries  with  longer  validity  period  varies 
extensively […]. 

A respondent from Turkey 

When respondents were asked to rate different aspects of the visa procedure according 
to their difficulty, the length of the procedure was rated as "most difficult" by the greatest 
proportion  of  respondents  (26%),  followed  by  the  total  cost  of  the  procedure  including 
the visa fee (24%) and the requirement to apply in person (24%). Conversely, obtaining 
travel  medical  insurance  was  rated  "least  difficult"  by  the  greatest  proportion  of 
respondents  (46%),  followed  by  the  behaviour  of  the  officials/persons  involved  in  the 
processing  (29%)  and  getting  access  to  information  about  the  visa  procedure  process 
(29%). 

79% of respondents' experiences would not deter them from travelling to the Schengen 
area again. Around half of frequent travellers noticed no changes to the visa procedure in 
recent  years (55%),  while 23%  thought  the procedure  had improved and a further 22% 
thought the procedure had become worse. 

Among respondents who had experience of applying at different consulates, 37% stated 
that  there  were  notable  differences  between  Member  States.  Where  issues  existed, 
these included differing documentation requirements, differing policies on the validity of 
the issued visas, and varying consideration of previous travel and visa history. However, 
among  respondents  who  also  had  experience  of  applying  for  visas  to  the  UK,  Ireland, 
Canada,  the  US,  Japan,  Australia  or  New  Zealand,  65%  considered  the  Schengen  visa 
procedure to be easier and more straightforward. 

Respondents'  comments  in  the  free-text  fields  generally  supported  the  answers  given 
elsewhere in the questionnaire. Most frequently, respondents criticised the requirement to 

58 

 
 
 
 
 
 
buy plane tickets in advance, the level of the visa fee in comparison to average salaries 
(especially for young people, families and retired persons), the insufficient consideration 
of prior visa and travel history, and the difficulty in obtaining long-validity MEVs. Some 
respondents  also  complained  that  refusals  could  appear  illogical  and  did  not  fully 
consider  individual  circumstances,  while  others  took  issue  with  the  behaviour  of  staff 
members  at  consulates  or  external  service  providers,  leading  them  to  conclude  that  the 
process was humiliating. 

Suspected campaigns 

The public consultation received responses from two suspected campaigns. Beginning in 
the  morning  of  14  January  2018,  1094  responses  were  submitted  by  respondents  with 
Omani  nationality  or  residence.  These  responses  demonstrate  patterns  suggesting 
automatic  or  semi-automatic  submission,  for  example  the  submission  of  659  responses 
(60%) almost every minute between 8.43am and 15.00 on 14 January 2018. However, the 
responses also bear signs of authentic content, for example a range of relevant free-text 
comments. The responses broadly match the public consultation's wider results. 

Beginning in the evening of 22 January 2018, the public consultation also received 291 
responses  from  respondents  with  Moroccan  nationality  or  residence.  222  of  these 
responses  (76%)  were  received  in  a  48-hour  period  following  midnight  on  23  January 
2018.  The  responses  again  bear  signs  of  authenticity,  for  example  a  range  of  relevant 
free-text comments, and broadly match the public consultation's wider results. 

III. Overall messages from the consultation 

The  consultation  provided  a  good  evidence  base  for  improving  the  visa  procedure  and 
showed  that  on  a  variety  of  topics,  there  was  a  large  consensus  between  stakeholders, 
including visa applicants. This is most notable regarding the different practices between 
Member  States  when  issuing  long-validity  multiple-entry  visas,  where  the  lack  of 
harmonisation  and  predictability  was  criticised  by  applicants  in  the  public  consultation 
and  by  stakeholders,  just  as  Member  States  and  Members  of  the  European  Parliament 
acknowledged the need for further harmonisation. Contrary to Member States, applicants 
are not favourable to increasing the visa fee. However, their responses showed that this is 
not the decisive factor in the overall cost of travel or the visa application, and stakeholder 
groups were not overwhelmingly hostile to a modest increase.  

Views  diverged  more  strongly  on  other  issues  raised  in  the  consultation,  notably  the 
digitalisation of the visa procedure and the possible further  individualisation of visa 
requirements. These matters therefore appear to need further discussion and reflection. 

59 

 
 
 
 
 
 
 
List of organisations that submitted position papers or additional information  

  Alibaba Group, People's Republic of China. 
  Allied for Startups, Belgium. 
  Analytical  Centre  on  Globalization  and  Regional  Cooperation  (ACGRC), 

Armenia. 

  Armenian Progressive Youth NGO, Armenia. 
  Association of Corporate Travel Executives, United States of America. 
  BV Kustvaartbedrijf Moerman, The Netherlands. 
  Chamber of Shipping of America, United States of America 
  Cirque du Soleil, Canada. 
  Confcommercio – Confturismo, Italy. 
  Confederación Española de Hoteles y Alojamientos Turísticos, Spain. 
  Coordinating Committee for International Voluntary Service (CCIVS), France. 
  Council for Global Immigration, United States of America. 
  Cruise Lines International Association (CLIA) Europe, Belgium. 
  Deutsche Sportjugend im DOSB e.V., Germany. 
  ECTAA - National travel agents' and tour operators' association, Belgium. 
  European Olympic Committees, Italy. 
  European Students' Union, Belgium. 
  European Tourism Association, Belgium. 
  European Tourism Manifesto for Growth and Jobs, Belgium. 
  European Travel Commission, Belgium. 
  Feld Entertainment, Inc., United States of America 
  Global Business Travel Association, United States of America. 
  Hong Kong Shipowners Association, Hong Kong 
  HOTREC – The Umbrella Association of Hotels, Restaurants, Pubs and Cafés in 

 
 
 
 

Europe, Belgium. 
International Air Transport Association, Canada. 
International Association of Amusement Parks and Attractions, Belgium. 
International Chamber of Shipping, United Kingdom. 
International  Organization  for  Migration  (IOM)  -  UN  Migration  Agency, 
Switzerland. 
 
ITAMA MOBILITY, France. 
  Justice and Peace, The Netherlands. 
  Network for the European Private Sector in Tourism, Belgium. 
  Newland Chase, United Kingdom. 
  Pearle*- Live Performance Europe, Belgium. 
  Public Union of Belarusian Pensioners "Nasha Pakalenne", Belarus. 
  Royal Association of Netherlands Shipowners (KVNR), The Netherlands. 
  Royal Caribbean Cruises Ltd., United States of America. 
  Service Civil International - Catalonia Branch, Spain. 
  Service Civil International - Deutscher Zweig e.V., Germany. 
  The Offshore Partners B.V., The Netherlands. 
  UEFA - Union of European Football Associations, Switzerland. 
  UK Chamber of Shipping, United Kingdom. 
  UNIMED - Unione delle Università del Mediterraneo, Italy. 
  Union of Greek Shipowners (UGS), Greece. 

60 

 
  VisaWie? Gegen Diskriminierende Visaverfahren, Germany. 
  Voluntary Workcamps Association of Nigeria, Nigeria. 
  World Travel & Tourism Council, United Kingdom.  
  Joined  contribution  of  Educational  and  Cultural  Bridges,  APY  –  Armenian 
Progressive Youth, Youth Alliance Via Networking, United Youth, and Yeghvard 
youth ecological NGO. 

  Joined contribution of European Community Shipowners' Associations, European 
Transport  Workers'  Federation,  International  Chamber  of  Shipping,  and 
International Transport Workers' Federation. 

The responses to the open public consultation that respondents agreed could be published 
will be available on the dedicated consultation webpage. 

61 

 
 
 
Annex 3: Who is affected and how? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

1.1. 

Insufficient financial resources 

Who? 

Citizens/Consumers 

Administrations 

How? 

Increasing the current common visa fee from EUR 60 to EUR 80 will lead to additional costs 
for visa applicants. 

Member States (consulates in third countries acting as the visa-issuing authorities) will benefit 
from  more financial resources due to increased visa fees. This will allow for better staffing, 
better training of the consulate staff and faster procedures. 

Businesses 

No direct implications. 

Change in travel behaviour, and hence impact on businesses in the travel and tourism industry, 
is expected to be negligible.  

1.2.  Repeated visa procedures 

Who? 

Citizens/Consumers 

How? 

Frequent  travellers,  especially  business  people,  family  members  and  affluent  tourists,  will 
benefit from more MEV with longer validity, reducing the number of times they have to apply 
for  a visa  and  thus  the  expenses  they  have  to  bear.  This  will  increase  their  ability  to  travel 
spontaneously to the Schengen area. 

Administrations 

Member States' visa-issuing authorities will benefit from lower number of visa applications. 
They will therefore be able to make savings and focus on the first-time applicants. 

Businesses 

No direct implications. 

Holders of MEV with long validity will be more flexible in planning and are more likely to 
make spontaneous trips and tour less-visited regions in the Schengen area, bringing additional 
revenue to businesses in the travel and tourism industry, strengthening their competitiveness 
and employment. 

1.3.  Return of irregular migrants 

Who? 

Citizens/Consumers 

How? 

If  and  where  the  negative  incentives  are  applied,  visa  applicants  who  are  nationals  of  the 
concerned  third  country  may  experience  more  difficult  procedures  when  applying  for 
Schengen visa. The concerned groups, i.e. in the first phase holders of diplomatic and service 
passports and in the second phase holders of ordinary passports, will incur additional costs or 
will not be granted MEV as a result of these measures. 

The European citizens and society at large will benefit from higher rates of return of irregular 
migrants,  resulting  in  higher  security  and  a deterrent  effect  on  potential  future  irregular 
migrants. 

62 

 
 
 
Administrations 

The  improved  return  rates  will  have  positive  impacts  in  terms  of  cost  savings  for  Member 
States' authorities and better acceptance of the EU migration policy. 

Businesses 

No direct implications. 

The  proposed  measures  would  be  taken  against  countries  with  high  levels  of  irregular 
migration, which generally do not carry great importance for the EU in terms of tourism. The 
overall impact on businesses in the travel and tourism industry will therefore be non-existent 
or very weak. 

2.  SUMMARY OF COSTS AND BENEFITS 

The  tables  below  summarise  the  costs  and  benefits  for  the  preferred  option.  Given  the  lack  of 
available  data,  the  tables  have  been  filled  to  the  extent  possible.  Many  benefits  cannot  be 
monetised.  For  instance,  Member  States  do  not  provide  data  on  the  costs  of  housing  irregular 
migrants or other administrative costs. Similarly there are no precise data available on Member 
States' costs of issuing visas. Higher security cannot be monetised either.  

I. Overview of Benefits – Preferred options 

Description 

Amount 

Comments 

Direct benefits 

Additional revenue from visa fee 

EUR 205 million 

Member  States'  visa-issuing  authorities  are  the 
beneficiaries. 

Savings in administrative costs (due 
to more issuing of MEV with long 
validity and higher return rates) 

Savings in visa application costs 

Revenue from increased tourism and 
travel (due to more MEV with long 
validity) 

Higher security (due to more 
financial resources for visa 
processing and higher return rates) 

Not quantifiable due to 
lack of data  

Member States' visa, asylum and police 
authorities are the main beneficiaries. 

Not quantifiable due to 
lack of data 

Frequent  travellers  will  benefit  from  more  MEV 
with long validity. 

Indirect benefits 

Not quantifiable due to 
lack of data 

The  travel  and  tourism  industry  across  the 
Schengen area will be the main beneficiary. 

Not quantifiable in 
principle 

Main  beneficiary  are  Member  States'  societies  at 
large. 

As  regards  the  costs,  the  increase  of  the  visa  fee  will  only  create  costs  for  applicants  in  third 
countries. No costs are expected as a result of issuing more MEV with long validity. The costs 
incurred  by  negative  incentives  in  the  visa  area  linked  to  readmission  will  depend  on  whether 
negative incentives in visa policy will be applied to third countries and in how many instances. 
Direct costs might arise for visa applicants in third countries, and indirect costs might arise for 
tourism businesses in the EU. Those costs cannot be quantified, but are expected to be low. 

63 

 
 
 
 
II. Overview of costs – Preferred option (million EUR) 

Citizens/Consumers  

Businesses 

Administrations 

Preferred options 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

1C1 

2C2 

3C2 

Direct costs 

Indirect costs 

Direct costs 

Indirect costs 

Direct costs 

Indirect costs 

- 

- 

- 

- 

n/a 

n/a 

20563 

- 

- 

- 

n/a 

n/a 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

n/a 

n/a 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

63  

Per year, for visa applicants in third countries. 

64 

 
 
 
 
                                                            
Annex 4: Update on the implementation of the Visa Code 

1.  Introduction 

The Visa Code64 sets out the procedures and conditions for issuing visas for short stays in 
the  Schengen  area.  It  replaced  and  consolidated  all  previous  legal  acts  governing  visa-
issuing  conditions  and  procedures.  One  of  its  overarching  aims  was  therefore  the 
simplification  and  harmonisation  of  the  way  Member  States  issue  Schengen  visas.  Its 
main  objective  is  to  prevent  migratory  and  security  risks  while  at  the  same  time 
facilitating legitimate travel. 

Two years after all provisions of the Visa Code became applicable, the Commission was 
required to report to the European Parliament and the Council on the implementation of 
the regulation, with an examination of the results achieved. The Commission presented 
its evaluation in a report65 and accompanying staff working document66 on 1 April 2014. 
As  there  have  been  no  substantive  changes  to  the  Visa  Code  since  these  reports  were 
published,  their  findings  remain  generally  valid  today.  Nonetheless,  as  the  political 
context  has  significantly  changed  in  the  past  four  years  and  the  Commission  services 
have  gathered  more  experience  on  the  practical  implementation  of  the  Visa  Code,  the 
present  annex  provides  an  updated  set  of  data  and  evidence  compared  to  the  2014 
evaluation. 

2.  Context 

Anticipating  the  2014  evaluation,  in  November  2012  the  Commission  published  a  first 
Communication on the "Implementation and development of the common visa policy to 
spur growth"67. Both this Communication and the title of the 2014 evaluation ("A smarter 
visa policy for economic growth") reflect one of the main concerns at the time: the weak 
economic outlook following the economic crisis since 2008 provided the background for 
efforts  to  leverage  all  possible  EU  policies  to  spur  growth.  The  focus  was  therefore 
placed on the facilitation of legitimate travel in order to harness its potential for growth 
and  jobs  creation.  As  the  2014  evaluation  noted,  the  direct,  indirect  and  induced  lost 
contribution  to  GDP  resulting  from  visa  requirements  amounts  to  anywhere  between 
EUR4.2 to 12.6 billion, translating to between 80 000 and 250 000 lost jobs. 

Although  the  Visa  Code  does  not  explicitly  mention  the  objective  of  economic  growth 
and  jobs  creation,  it  is  clear  that  legitimate  travel,  be  it  for  business,  touristic,  cultural, 
family or other reasons, brings economic benefits to the EU. The Visa Code's objective 

64  

65  

66  

67  

Regulation (EC) No 819/2009 of the European Parliament and of the Council of 13 July 2009 
establishing a Community Code on Visas, OJ L 243, 15.9.2009, p.1. 
Report from the Commission to the European Parliament and the Council: A smarter visa policy for 
economic growth; COM(2014)165 final of 1 April 2014. 
Evaluation of the implementation of Regulation (EC) No 810/2009 of the European Parliament and 
Council establishing a Community Code on Visas (Visa Code); SWD(2014 101) final of 1 April 
2014. 
COM(2012)649. 

65 

 
                                                            
of facilitating the entry into the Schengen area of bona fide applicants therefore continues 
to be highly relevant, as it is in the EU's own interest to be 'open' to travellers that boost 
trade  and  growth.  Furthermore,  contacts  between  peoples  and  cultures  promote  mutual 
understanding  and  dialogue,  contributing  to  the  objectives  of  the  EU  in  its  external 
relations  with  third  countries.  As  the  2014  evaluation  noted,  the  provisions  in  the  Visa 
Code  that  allow  consulates  to  distinguish  between  unknown  applicants  and  those  who 
have  a  positive  visa  record  are  not  applied  sufficiently  harmonised  manner,  leading  to 
lengthy and cumbersome visa procedures even for frequent travellers. This continues to 
be the case. 

The migration crisis that reached its peak in 2015 and the terror attacks in recent years, 
however,  have  shifted  the  political  debate  on  the  Schengen  area  in  general  and  visa 
policy in particular towards a reassessment of the balance between migration and security 
concerns,  economic  considerations  and  general  external  relations.  Since  the  2014 
evaluation  was  published,  the  Visa  Code's  objectives  of  preventing  irregular  migration 
and security risks  have therefore come  into much sharper focus. All available evidence 
shows that the application of the Visa Code by the Member States effectively minimises 
migratory and security risks; holders of short-stay visas were not implicated in either the 
migratory crisis or the terror attacks. Neither the Member States nor the results of studies 
and  of  the  stakeholder  consultation  identify  security  risks  or  problems  arising  from  the 
Visa  Code.  The  full  world-wide  roll-out  of  the  Visa  Information  System  (VIS),  which 
was completed in February 2016 and which contains electronic records of all short-stay 
visa  applications,  further  contributed  to  reducing  migratory  and  security  risks  and 
reinforcing the integrity of the Schengen visa procedure.68 

Even so, the changed political context meant that visa policy came into focus as a tool for 
achieving  progress  in  relations  with  third  countries,  as  the  experience  with  visa 
liberalisation had already shown. In this manner, visa policy was called upon to be used 
more effectively in the EU's cooperation with third countries, specifically in the field of 
migration  management.  Accordingly,  the  European  Council  of  June  2017  called  for 
"reassessing visa policy towards third countries, as needed" as a means of achieving real 
progress  in  return  and  readmission  policy.  As  the  Visa  Code  was  not  designed  with  a 
view  towards  being  used  as  leverage  towards  individual  third  countries,  but  rather as  a 
means to standardise visa issuing procedures and conditions, it is not entirely adapted to 
the  new  political  context.  The  Commission  recognised  this  changed  reality  in  its 
Communication  on  the  Delivery  of  the  European  Agenda  on  Migration  of  September 
201769,  where  it  stated  that  "some  visa-issuing  rules  (for  instance  those related  to  visas 
with long validity and visa fees) should be reviewed to ensure that they can play a part in 
our readmission policy." The detailed options for how this could be implemented in the 
legislation are examined in this Impact Assessment. 

68  

69  

The VIS legal framework was subject to a separate evaluation (COM(2016) 655 final) which will 
be followed up by a separate initiative, according to the Commission Work Programme for 2018.  
COM(2017)558. 

66 

 
                                                            
3.  Recent evidence on the implementation of the Visa Code 

3.1. General considerations 

The  comprehensive  evaluation  of  the  implementation  of  the  Visa  Code  concluded  that 
the legislation had achieved its overarching objective by modernising and standardising 
visa procedures and by contributing to the protection of the external borders. While it is 
impossible to prove the direct impact of the Visa  Code on the  number  of visas  applied 
for,  the  clarification  of  the  legal  framework  has  contributed  to  a  significant  increase  in 
the volume of visa applications processed by the consulates of Member States. As shown 
in table 1 below, the worldwide applications for Schengen visas increased by more than 
50% between 2009 (before the entry into force of the Visa Code) and 2016, from 10.2 to 
15.2 million. While there has been a decline since the peak reached in 2013, this can be 
attributed  to  economic  difficulties  in  Russia,  the  number  one  source  country  for  visa 
applications. Preliminary figures for 2017 suggest that the number of applications could 
have been around 16 million again. 

Table 1: Schengen visa applications worldwide, 2009-2016 

Schengen 
State 
Austria 
Belgium 
Czech 
Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Iceland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Norway 
Poland 
Portugal 
Slovakia 
Slovenia 
Spain 
Sweden 
Switzerland 

Total 
Schengen 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

300.210 
194.029 

280.328 
215.978 

283.540 
242.857 

304.798 
233.490 

313.579 
233.273 

266.356 
219.758 

259.167 
239.500 

268.388 
219.687 

Change 
09-16 
-10,6% 
13,2% 

456.503 

546.410 

581.931 

603.484 

646.719 

519.819 

421.355 

489.920 

7,3% 

82.064 
95.837 
795.554 
1.592.527 
1.615.792 
616.051 
273.325 
493 
1.087.521 
120.379 
208.029 
5.493 
31.730 
333.965 
103.251 
586.115 
117.189 
64.953 
101.435 
854.496 
195.943 
383.207 

85.646 
120.135 
1.020.825 
1.965.777 
1.730.875 
620.270 
253.321 
562 
1.327.086 
137.432 
266.048 
7.822 
41.754 
386.759 
130.837 
695.990 
125.832 
58.607 
52.508 
1.143.753 
206.077 
391.720 

94.310 
144.567 
1.259.643 
2.130.471 
1.707.197 
768.246 
288.415 
636 
1.516.237 
163.309 
345.765 
9.051 
33.858 
428.206 
151.071 
912.988 
142.754 
71.313 
39.735 
1.518.641 
220.567 
428.189 

100.402 
175.360 
1.392.048 
2.321.534 
1.844.704 
1.001.341 
322.646 
1.088 
1.706.536 
182.496 
416.851 
10.555 
53.777 
440.056 
130.933 
1.091.395 
148.489 
75.720 
42.127 
1.836.868 
215.763 
464.512 

105.119 
201.056 
1.569.961 
2.551.196 
2.062.979 
1.531.383 
356.869 
2.821 
2.036.829 
205.230 
471.838 
11.222 
79.559 
458.824 
197.826 
1.126.150 
159.421 
131.194 
38.885 
2.080.175 
200.543 
512.797 

109.694 
170.731 
1.205.034 
2.894.996 
2.061.137 
1.375.287 
309.894 
3.923 
2.164.545 
207.185 
463.709 
11.567 
56.886 
485.267 
179.550 
1.125.520 
183.216 
104.988 
26.492 
1.923.016 
191.009 
466.329 

123.951 
130.197 
784.286 
3.356.165 
2.022.870 
876.786 
290.798 
3.987 
2.023.343 
164.000 
423.189 
10.267 
39.445 
520.809 
185.557 
970.907 
192.220 
76.491 
26.895 
1.629.753 
192.852 
481.886 

145.143 
122.872 
550.046 
3.265.919 
2.004.235 
986.032 
295.226 
5.771 
1.806.938 
165.814 
421.143 
9.902 
27.767 
558.101 
188.737 
1.096.465 
204.596 
62.472 
25.876 
1.583.848 
227.005 
460.653 

76,9% 
28,2% 
-30,9% 
105,1% 
24,0% 
60,1% 
8,0% 
1070,6% 
66,2% 
37,7% 
102,4% 
80,3% 
-12,5% 
67,1% 
82,8% 
87,1% 
74,6% 
-3,8% 
-74,5% 
85,4% 
15,9% 
20,2% 

10.216.091  11.812.352  13.483.497  15.116.973  17.285.448  16.725.908  15.446.676  15.192.556 

51,2% 

The  official  visa  statistics,  which  are  compiled  by  the  Commission  in  accordance  with 
Article 46 of the Visa Code based on submissions by the Member States, do not contain 
data on the length of validity of the issued visas, nor on the nationality of the applicants 
(although the location of the consulate where the application was submitted can be used 
as a proxy for nationality, with the exception of countries where the nationals themselves 

67 

 
 
are  not  subject  to  the  visa  requirement,  such  as  the  UK,  US  or  UAE).  The  lack  of 
statistical data was already identified as a weakness in the 2014 evaluation and the issue 
persists to date. However, since all short-stay visa applications are now recorded in the 
Visa Information System, there is potential for producing more detailed visa statistics in 
the near future.70 

Despite the scarcity of statistical data – which was already noted in the 2014 evaluation – 
the Commission has accumulated extensive experience in the implementation of the Visa 
Code  from  its  regular  monitoring  activities,  complaints  and  petitions  by  citizens, 
exchanges on practical issues with Member States, questions raised by Members of the 
European Parliament and Schengen evaluations. The latter are 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, and since 2015 have 
been carried out for 15 Member States71 that fully apply the Visa Code. The evaluations 
consisted of a week-long visit to two consulates72 by a mixed team of Commission and 
Member  State  experts,  examining  the  correct  application  of  the  Visa  Code  and  related 
legal provisions in practice. The findings are described in an evaluation report, which is 
classified  as  EU  restricted,  and  lead  to  Council  recommendations  to  the  evaluated 
Member State to remedy any shortcomings identified during the evaluation. 

During  the  evaluations,  the  experts  observed  overall  compliance  with  the  essential 
provisions  of  the  legal  framework  in  most  cases,  including  in  general  a  careful 
assessment  of  applicants'  migratory  risk.  However,  they  also  noted  cross-cutting 
shortcomings  in  the  application  of  the  Visa  Code,  which  corroborate  certain  findings 
already  contained  in  the  2014  evaluation.  Despite  a  common  regulatory  framework, 
Member  States'  visa-issuing  practices  still  diverge  on  a  number  of  aspects  and  both 
consular  staff  and  applicants  still  view  Schengen  visas  very  much  as  "national"  visas. 
This contributes to competition between Member States in "attractive markets" as well as 
visa shopping and weakens the perception of Schengen as a common travel area. 

3.2. Multiple-entry visas 

Long-validity multiple-entry visas are one of the most effective facilitations that can be 
given  to  bona  fide  frequent  travellers,  as  they  reduce  administrative  burdens  for 
applicants and consulates alike. Due to the lack of detailed data on the validity period of 
issued visas, it is not possible to draw definite overall conclusions on patterns for certain 
locations or certain Member States regarding the number of long-validity multiple-entry 
visas. 

The available visa statistics do show, however, the rate of multiple-entry visas issued by 
the Member States' consulates, even if there is no information on their length of validity 

70  

71  

72  

See point 3.2 of the report from the Commission on the implementation of the VIS Regulation, 
COM(2016)655. 
Austria, Belgium, Germany, the Netherlands, Luxembourg, Italy, Greece, Malta, France, Denmark, 
Iceland, Sweden, Portugal, Spain and Norway. 
A consulate and the central visa authority in the case of Luxembourg and Iceland. 

68 

 
                                                            
(Chart  1).  In  general,  the  share  of  MEVs  among  all  issued  visas  has  been  slowly 
increasing  in  the  past  few  years.  The  data  confirms,  however,  the  persistent  large 
variation in Member States' practices regarding the issuing of multiple-entry visas: While 
the MEVs issued by some Member States are barely more than 10% of all visas issued, 
almost  all  of  the  visas  issued  by  other  Member  States  are  MEVs.  While  some  of  this 
variance  can  be  explained  by  the  different  consular  network  of  Member  States  and  the 
resulting  difference  in  the  applicants'  profiles,  it  is  clear  that  the  divergent  practices  of 
Member  States  regarding  MEVs  remain  a  problem.  The  results  of  the  Schengen 
evaluations  confirm  vastly  differing  approaches  between  Member  States  in  the  same 
location on issuing single-entry or multiple-entry visas, especially to first-time travellers, 
and on the length of validity of the visas issued. 

Chart 1: MEVs as a percentage of total visas issued by Member State 
The chart shows the range of MEV issuance rates across Member States as well as the median, first and 
third quartile values. 

d
s
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s
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f
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p
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100,0

90,0

80,0

70,0

60,0

50,0

40,0

30,0

20,0

10,0

0,0

2013

2014

2015

2016

3.3. Visa refusals 

Chart 2 shows the percentage of visa applications that are refused by the consulates of the 
Member  States.  The  average  refusal  rate  has  increased  slightly  in  the  past  few  years, 
which is mainly due to changes in the pool of applicants: with several nationalities being 
granted visa-free status over the same time period, the share of applicants from countries 
with a higher migratory risk has slowly increased. In the same manner, the variation in 
refusal  rates  between  Member  States  is  explained  by  the  different  consular  networks, 
with  some  Member  States  receiving  the  vast  majority  of  visa  applications  in  countries 

69 

 
 
 
 
 
 
 
 
 
 
 
 
with  low  migratory  or  security  risk  and  a  consequently  low  refusal  rate  (e.g.,  Russia). 
Other  Member  States  have  a  larger  consular  network  and  receive  more  applications  in 
certain African or Asian countries where refusal rates can be 30% or higher, leading to a 
higher  overall  refusal  rate.  The  Commission's  regular  monitoring  and  Schengen 
evaluations  confirm  that  there  is  no  systematic  problem  with  divergent  standards  and 
practices regarding the assessment of individual visa applications and the appreciation of 
migratory  and  security  risk  between  Member  States.  In  general,  consulates  conduct  a 
careful and individual assessment of applicants' migratory risk and any cases where this 
might have been different are extremely rare and isolated. 

Chart 2: Refusal rates as a percentage of total visas applied for by Member States 
The  chart  shows  the  range  of  refusal  rates  across  Member  States  as  well  as  the  median,  first  and  third 
quartile values. 

2016

2015

2014

2013

0

5

10

15
Refusals as a percentage of total visas applied for (%) 

20

25

30

3.4. Visas issued at external border crossing points 

While  visa-required  travellers  must  normally  be  in  possession  of  a  valid  visa  before 
arriving  at  the  external  border,  in  exceptional  cases  visas  may  also  be  issued  at  border 
crossing points according to Article 35 of the Visa Code. Many of the applicants at the 
borders are seafarers. Chart 3 shows that in the past four years, the number of such visas 
has  continuously  declined,  with  less  than  100 000  visas  being  issued  at  the  border  in 
2016. One reason for this are the improvements made in the consular coverage (see 3.5. 
below), which made it easier for applicants to apply for visas ahead of their trip, even on 
short notice in emergency situations. 

70 

 
 
 
Chart 3: Short-stay visas issued at the external borders 

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160.000

140.000

120.000

100.000

80.000

60.000

40.000

20.000

0

2013

2014

2015

2016

3.5. Consular coverage and cooperation 

The  2014  evaluation  expressed  concerns  about  the  progress  achieved  regarding  full 
consular coverage for the benefit of applicants. It noted that in many countries, applicants 
still had to travel large distances to the nearest consulate or visa application centre of the 
competent  Member  State,  which  was  costly  and  time-consuming  and  a  barrier  to 
facilitating legitimate travel. 

The situation has evolved quite favourably since 2014, however. As table 2 below shows, 
there  has  been  an  overall  increase  of  almost  30%  in  'visa  access  points',  i.e.  locations 
where  applications  for  short-stay  visas  can  be  lodged.  Most  of  this  progress  is  due  to 
outsourcing to external service providers, which has grown from 134 locations in 2014 to 
1263 locations in early 2018, i.e. by more than 800%. Progress has also been made with 
respect  to  representation  agreements  between  Member  States,  with  such  forms  of 
consular cooperation increasing by more than 3% over the  past four years. Conversely, 
the Member States' own consular networks have generally shrunk, with almost a quarter 
fewer locations  in  early 2018 than in 2014. Much  of this reduction is a direct effect of 
national  budget  cuts  that  forced  Member  States  to  rationalise  and  reorient  their 
diplomatic and consular representations abroad. Insufficient revenues from the visa fee to 
cover administrative costs also played a role in this development. 

71 

 
 
 
 
 
 
 
 
Table 2: Consular coverage and cooperation – visa access points by type, 2014-2018 

2014 

2018 

Change 2014-2018 
(%) 

Consulates 
External service providers (ESPs) 
Consulate and ESP in same location 
Representation agreements 
Honorary consulates accepting visa applications 
TOTAL visa access points 

1341 
134 
314 
1864 
134 
3787 

1012 
1263 
583 
1922 
127 
4907 

-24.5 
842.5 
85.7 
3.1 
-5.2 
29.6 

3.6. Local Schengen Cooperation 

In  the  Staff  Working  Document  accompanying  the  2014,  the  Commission  noted  that 
progress was slow on establishing harmonised lists of supporting documents, which is a 
key role of Local Schengen Cooperation according to Article 48(1)(a) of the Visa Code. 
The evaluation therefore concluded that a wide variety of divergent practices continued 
to exist between Member States in the same location, which harmed the objective of the 
Visa Code to harmonise the way Member States issue visas. If there is clarity about the 
supporting documents that need to be submitted with a visa application, this reduces the 
burden  on  applicants  and  consulates  alike,  and  further  reduces  incentives  for  visa 
shopping. 

Chart  4:  Commission  Implementing  Decisions  establishing  the  lists  of  supporting 
documents to be presented by Schengen visa applicants in specific countries 

60

50

40

30

20

10

0

Commission Implementing
Decisions (cumulative)

Countries (LSCs) covered

2011

2012

2013

2014

2015

2016

2017

On  this  matter,  too,  significant  progress  has  been  made  since  2014.  As  Chart  4  shows, 
Commission  Implementing  Decisions  giving  legal  effect  to  the  harmonised  lists  drawn 
up  in  Local  Schengen  Cooperation  now  cover  54  third  countries,  following  a  steady 
increase year over year. This trend is expected to increase in the coming years, reducing 
the  problems  that  applicants  report  having  with  supporting  documents.  While  the 

72 

 
 
 
 
Schengen  evaluations  revealed  some  deficiencies  in  the  implementation  of  the 
harmonised  lists  in  practice,  with  certain  consulates  still  deviating  from  them,  the 
situation  is  expected  to  improve:  Member  States  are  increasingly  aware  of  the  added 
value  of  Local  Schengen  Cooperation  and  in  the  stakeholder  consultation  generally 
supported an expansion of its role, beyond drawing up lists of supporting documents. 

3.7. Changes in the visa lists 

Apart from requirements for airport transit visas, the rules specifying the countries whose 
nationals require visas to enter the Schengen area are not laid down in the Visa Code, but 
in  Council  Regulation  (EC)  No  539/2001.  Two  annexes  to  that  Regulation  specify  the 
visa-required  and  visa-free  countries,  respectively.  While  not  part  of  the  Visa  Code, 
changes  to  these  annexes  obviously  have  an  impact  on  the  number  and  distribution  of 
visa applications that must be processed by the consulates of the Member States, as well 
as on the resources that are necessary and the revenue gained from visa fees. 

As table 3 shows, the top ten source countries for visa applications have remained largely 
stable  since  201373,  but  with  vastly  different  growth  rates.  While  the  applications  from 
Eastern  European  countries  (Russian  Federation,  Ukraine  and  Belarus)  have  declined, 
there  has  been  a  remarkable  increase  in  applications  from  China,  India,  Algeria  and 
Morocco  of  more  than  35%  each.  While  applications  from  Russia  and  Belarus  are 
expected  to  recover  somewhat,  the  general  trend  is  likely  to  continue  pointing  towards 
disproportionate growth in applications lodged in Africa and Asia. As Ukrainian citizens 
have been visa-free since 11 June 2017, the realignment in visa application patterns will 
be even more pronounced. 

Table 3: Number of visas applied for in top 10 countries by visa application total 

Russian Federation 
China 
Ukraine 
Turkey 
India 
Algeria 
Belarus 
Morocco 
Saudi Arabia 
Thailand 

TOTAL 

2013 

2014 

2015 

2016 

6,995,141 
1,497,178 
1,589,963 
779,464 
522,106 
445,517 
777,813 
401,092 
276,984 
233,211 
13,518,469 

5,768,182 
1,800,369 
1,387,086 
813,339 
568,216 
593,624 
881,404 
434,652 
308,879 
219,015 
12,774,766 

3,467,317 
2,381,818 
1,233,530 
900,789 
708,386 
735,040 
752,782 
493,642 
367,028 
255,319 
11,295,651 

3,177,621 
2,185,927 
1,411,950 
937,487 
792,271 
744,213 
695,615 
555,142 
345,006 
278,832 
11,124,064 

Change 
2013-2016 
(%) 

-54.57 
46.00 
-11.20 
20.27 
51.75 
67.04 
-10.57 
38.41 
24.56 
19.56 
-17.71 

The impact of moving a country from the visa-required to the visa-free list can be seen 
most  recently  in  the  cases  of  Moldova,  Colombia  and  Peru.  Nationals  from  these 

73   With the sole exception of 2014, in which the United Arab Emirates replaced Thailand in position 

10. 

73 

 
 
 
                                                            
countries became visa-free in 2014, 2015 and 2016, respectively. Table 4 summarises the 
decline  in  visa  applications  lodged  in  these  countries  following  the  visa  waiver,  which 
exceed 95% in the cases of Moldova and Colombia and reached 75% for Peru74. Similar 
effects  can  be  expected  from  Georgia  and  Ukraine,  the  two  most  recent  countries  that 
became visa free. However, a comparable outcome did not take place in the United Arab 
Emirates,  which  also  became  visa-free  in  2015:  The  high  proportion  of  third-country 
nationals in the UAE – often from South Asia – who continued to remain subject to the 
visa requirement resulted in only a modest decline in the number of applications by 4%. 

Table 4: Visa applications lodged in third countries that were moved to the visa-free 
list since 2014 
The years in brackets indicate when the respective visa waiver became effective 

2013 

2014 

2015 

2016 

Moldova (2014) 
United Arab Emirates (2015) 
Colombia (2015) 
Peru (2016) 
Georgia (2017) 
Ukraine (2017) 

TOTAL 

53,319 
210,270 
128,443 
54,163 
82,156 
1,589,963 
2,118,314 

13,932 
253,765 
133,200 
59,309 
93,126 
1,387,086 
1,940,418 

2,314 
224,202 
133,095 
66,950 
100,549 
1,233,530 
1,760,640 

2,069 
201,995 
2,223 
13,590 
106,024 
1,411,950 
1,737,851 

Change 
2013-2016 
(%) 

-96.1 
-3.9 
-98.3 
-74.9 
29.1 
-11.2 
-18.0 

4.  Conclusion 

Several  findings  of  the  comprehensive  evaluation  of  the  Visa  Code  conducted  in  2014 
remain  valid  today.  First  among  these  is  the  continuing  lack  of  harmonisation  between 
Member  States  regarding  the  issuing  of  multiple-entry  visas  with  long  validity  to 
facilitate  legitimate  (frequent)  travel  by  bona  fide  applicants.  The  impact  assessment 
examines  in  detail the  different  options  for  remedying  this  problem.  The  complications 
caused by the lack of detailed visa statistics also persist, as do a series of minor technical 
issues identified in the 2014 report. This includes the application form, which could be 
simplified, the deadlines for lodging applications, which could be extended, and the legal 
framework for cooperation with external service providers, which could be strengthened. 

Conversely,  some  of  the  problem  areas  identified  in  the  2014  evaluation  have  seen 
significant  progress.  After  a  slow  start,  Local  Schengen  Cooperation  in  an  increasing 
number  of  locations  is  fulfilling  its  role  in  drawing  up  harmonised  lists  of  supporting 
documents,  reducing  a  key  source  for  divergent  practices  between  Member  States.  As 
shown  in  the  stakeholder  consultation,  Local  Schengen  Cooperation  seems  to  be  an 
instrument  that  is  appreciated  by  Member  States,  so  its  legal  framework  could  be 
strengthened. 

74  

Since the visa waiver for Peru was not yet in effect for the whole year 2016. 

74 

 
 
 
                                                            
Progress has notably been made also with regard to the expansion of consular coverage, 
making it easier for travellers to lodge their applications at an external service provider or 
a  consulate  representing  the  competent  Member  State.  This  problem  is  therefore  much 
less  pressing  than  it  was  in  2014.  At  the  same  time,  the  closure  of  consulates  over  the 
past  four  years  reflects  at  least  in  part  the  fact  that  the  current  level  of  the  visa  fee  is 
insufficient  to  cover  the  administrative  costs  of  Member  States,  an  issue  which  is 
examined in the impact assessment. 

The most important developments since 2014 do not concern the implementation of the 
Visa Code per se, but the migratory and security environment that affects the Schengen 
area as a whole. Whereas the jobs and growth potential of the common visa policy was 
very much at the centre of attention four years ago, leveraging visa policy in managing 
migration  challenges  has  now  also  moved  to  the  forefront  of  policy  objectives.  The 
impact  assessment  therefore  examines  different  options  for  designing  the  link  between 
visa policy and the EU's readmission policy. 

75 

 
 
 
 
Annex 5: Visa fee 

Part 1: Summary of the questionnaire survey on the visa fee (2016) 

  The Commission carried out a questionnaire survey among Member States on 

various aspects linked to establishing the level of the visa fee 

o  cost of processing a visa application;  
o  methodology to be followed to make a (common) calculation;  
o  suggestions for the basic visa fee;  
o  should the flat rate visa fee be maintained or a progressive fee be charged 

depending on the length of validity of the issued visa;  

o  should  a  higher  visa  fee  be  charged  to  nationals  of  third  countries  that 

charge 'exorbitant' visa fees to EU citizens ('reciprocity'). 

  21 out of 30 Schengen Member States responded. 
  3 Member States are in favour of maintaining the fee at current level. All others 
favour increasing the fee. No Member State is in favour of lowering the visa fee. 
  Member States generally favour the visa fee to correspond to the administrative 
costs. 2 Member States suggested a harmonised methodology for calculating the 
administrative costs.  

  3 Member States stressed the importance of a regular review of the visa fee level 

to reflect the actual situation. 

  8  Member  States  suggested  specific  amounts,  ranging  from  65  to  143  EUR 

(basic fee). 

  11  Member  States  suggested  a  "flat  rate"  visa  fee,  while  5  favour  a 

differentiated visa fee, suggesting different models:  

o  for reasons of simplicity: only 2 different fees: SEV and MEV;  
o  airport  transit  visa:  40  EUR;  others  100  EUR;  application  at  border 

crossing point: 200 EUR;  

o  airport transit visa: 40 EUR; 6 month visa (SEV or MEV): 60 EUR; 1 year 
visa:  90  EUR;  2  year  visa:  90  EUR;  3  year  visa:  120  EUR;  4  year  visa: 
120 EUR; 5 year visa: 150 EUR; 

o  starting  with  60  EUR,  every  additional  year  progressively  increases  the 

costs (60-120-180-240-300). 

  On  visa  fee  reciprocity  only  9  Member  States  replied.  Most  of  them  want  to 
increase  the  fees  in  case  of  very  high  fees  charged  by  a  third  country,  except  3 
(which foresee practical problems in implementing reciprocity). 

  10  Member  States  responded  to  the  question  of  methodology  for  calculating 
administrative costs but only 2 provided concrete calculations; others suggested 
some factors to be included into the calculation of administrative costs. There is 
consensus that the following factors should be included: 
o  overall costs of infrastructure like property; 
o  IT-systems;  
o  staff and staff related costs; 
o 
o  visa sticker production. 

logistics; 

  Some Member States also suggested the following factors to be included: 

o  administrative costs of issuing visas at the embassies/consulates and at the 

borders;  

76 

 
o  migration court of justice (average expenditures of appeals) / costs related 

to legal disputes, legal activities like court fees; 

o  costs of headquarters (MFA, MOI); 
o  whole  process  from  website  information  on  visa  applications  to  internal 

appeal procedures handled by the consulates/MFAs; 

o  costs of ongoing operation and travelling; 
o  costs of operating systems concerning biometry like BIONET, BIODEV, 

VISABIO; 

o  costs of delivering visas to the borders; 
o  costs of training. 

  Two different calculation methods were proposed (see part 2 for details): 

Method Member State 1: 

𝑎𝑑𝑚𝑖𝑛𝑖𝑠𝑡𝑟𝑎𝑡𝑖𝑣𝑒 𝑐𝑜𝑠𝑡𝑠 (𝑝𝑒𝑟 𝑣𝑖𝑠𝑎 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛) 

 =

total costs of visa − costs of national visa − revenues of visa facilitation
number of full paying applicants

Method Member State 2:  

𝑎𝑑𝑚𝑖𝑛𝑖𝑠𝑡𝑟𝑎𝑡𝑖𝑣𝑒 𝑐𝑜𝑠𝑡𝑠 (𝑝𝑒𝑟 𝑣𝑖𝑠𝑎 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛) 

= 𝑎𝑣𝑒𝑟𝑎𝑔𝑒 𝑝𝑟𝑜𝑐𝑒𝑠𝑠𝑖𝑛𝑔 𝑡𝑖𝑚𝑒 𝑜𝑓 𝑜𝑛𝑒 𝑣𝑖𝑠𝑎 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 ∗

ℎ𝑜𝑢𝑟𝑙𝑦 𝑤𝑎𝑔𝑒75
60 𝑚𝑖𝑛

75  

Including direct, indirect cost like rent of locations, salaries, IT, central overhead costs etc. 

77 

 
 
 
 
 
 
 
                                                            
Part 2: Calculation of administrative costs (provided by two Member States) 

Member State 1: 

The costs are calculated as follows76: 

Number 
255 
381,50 

Price 
45.000 
31.000 

Total costs C-visa 

Personnel77: 
Overhead78 
ICT-costs79 
Other costs80 

subtotal 
Costs national visa 

Total costs 
(43.351.000-2.910.000) 
Revenues per year 

Total 
24.502.500 
11.826.500 
  5.692.000 
  1.330.000 

43.351.000 
  2.910.000 

40.441.000 

24.200.000 

Number of visa per year 
No. of full paying visa applicants 
Total costs 
Revenues visa facilitation 
To finance 
Costs per full paying applicant  
(37.230.508/309.030) 

    466.933 
    309.030 
40.441.000 
  3.210.492 
37.230.508 
120 

Member State 2 (Denmark): 

The Ministry of Foreign Affairs in Denmark has calculated the average cost price per 
visa case. The calculation of the cost price for handling one visa application at a Danish 
Embassy/Mission handling visa cases are as follows: 

The average case processing time per visa case is approximately 80 minutes including all 
steps in the case handling process.    

On average these 80 minutes consist of 20 % posted staff and 80 % local staff.  

76  
77  
78  

79  
80  

Numbers are an average of 2012, 2013 and 2014. 
Personnel working on visa (abroad and in the capital) 
Overhead (including personnel not directly working on visa, information, organisation, finances, 
administration, communication, accommodation) 
Specific ICT-costs (software and hardware) 
Other costs related to visa (visa stickers, visa meetings, special assessments etc.) 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                            
The average cost price per hour for posted staff at a Danish Embassy/Mission is 
calculated to approximately 1,645.00 Danish Kroner = EUR 221.00. 1 minute = EUR 
3.68 x 80 minutes = EUR 295.00 for 80 minutes. 20 % of 80 minutes = 16 minutes = 
EUR 3.68 x 16 = EUR 58.90 as part of the handling of a visa case. . 

The average cost price per hour for local staff at a Danish Embassy/Mission is calculated 
to approx imately 585.00 Danish Kroner = EUR 78.60. 1 minute = EUR 1.31 x 80 
minutes = EUR 104.85 for 80 minutes. 80 % of 80 minutes = 64 minutes = EUR 1.31 x 
64 = EUR 83.85 as part of the handling of a visa case. 

The total cost price per visa case is EUR approx. 58.90 + EUR 83.85 = EUR 143.00 
(rounded up). 

79 

 
 
 
Part 3: Other countries' visa fees 

The main objective of the visa fee is to cover the administrative and operational costs of 
the visa-issuing procedure; however, it also has a regulatory effect of the visa fees as it 
helps  to  moderate  the  number  of  applications  which  would  be  refused.  Yet,  its  amount 
should not prevent legitimate applicants from travelling and cause unnecessary obstacles 
to tourism and business.  

The  visa  fees  imposed  by  different  countries  vary  depending  on  many  aspects.  While 
respective countries apply various criteria, the most common variables determining visa 
fees are: 

  Visa category (e.g., tourism, business, family visit), 
  Number of entries (single, multiple) 
  Length of validity, 
  Applicant's  nationality  and/or  legal  status  in  the  country  where  the 

application is submitted, 

  Country or location where the application is submitted, 
  Channel used for submitting the application (e.g. paper, online). 

Additionally, it is increasingly becoming a common practice to outsource the collection 
of  visa  applications  to  external  service  providers.  The  service  fee  charged  by  some 
service providers can actually double the real cost of visa.81 

The first three factors are directly related to the visa and its nature. Business visas can be 
more expensive than tourist visas. The differentiation between multiple- and single-entry 
visa  and  transit  visa,  and  the  length  of  validity  of  the  visa  are  often  also  determining 
factors. For instance, China applies a visa fee of EUR 30 for a single-entry visa, EUR 50 
for double entries, EUR 70 for multiple entries up to 6 months and EUR 100 for up to 12 
months to most non-Schengen countries' nationals.  

The  applicant's  citizenship  or  legal  status  in  the  country  where  the  application  is 
submitted  have  a  significant  weight  when  determining  the  visa  fee  for  many  countries. 
This criterion reflects the international relations between the concerned countries as well 
as  migratory risk,  economic and business relations and reciprocity. China, for instance, 
applies  a  fee  of  EUR  140  to  visa  to  Argentinian  citizens  while  fees  for  other  South 
American nationals vary from EUR 30 – 100; Romanian citizens have to pay EUR 90 – 
190 compared to the flat fee of EUR 60 for the Schengen area countries and EUR 30  – 
100 for other third countries. 

The country where the application is submitted and processed and the channel used for 
submitting the application directly determine the real operational costs related to granting 
visa  borne  by  the  issuing  state.  Certain  countries  have  implemented  electronic  visa 

81  

Chinese Visa Application Service Centre applies an application service fee of EUR 65.45 to normal 
applications of Schengen countries' citizens which results in a total fee of EUR 125.45. 

80 

 
                                                            
application  systems  which  are  more  cost-efficient.  The  fee  for  applicants  using  e-visa 
procedures is therefore usually lower compared to the traditional (paper) visa procedures. 
Additionally, the visa granted on the arrival is usually also cheaper. For instance, Turkey 
applies an electronic visa fee of USD 20 (EUR 17) to Austrian citizens, while the fee for 
visa  on  arrival  is  EUR  25.  However,  although  there  are  various  channels  which  finally 
help to reduce the costs and lower the final visa fee, states tend to limit its use only for 
citizens of selected countries due to security concerns and/or other reasons.  

The following table shows the wide variation in visa fees charged by the top 10 tourist 
destinations  according  the  total  number  of  international  tourist  arrivals  in  2017.82  The 
Schengen area countries are exempted.  

Country 

Australia 

China 

Japan 

Malaysia 

Mexico 

Visa fee 

Fee in EUR83 

Comment 

AUD 140 

EUR 90 

MEV valid 12 months 

EUR 30-190  MEV up to 12 months 

JPY 3.000-6.000  EUR 22-47 

MEV 

MYR 6-50 

EUR 1,24-10  MEV up to 12 months 

USD 36 

EUR 30 

MEV up to 180 days 

New Zealand 

NZD 170 

EUR 100 

MEV up to 9 months 

Thailand 

Turkey 

THB 1.000 

EUR 25 

Per entry, MEV up to 6 months 

EUR 20-50 

Visa on arrival 

United Kingdom 

GBP 89 

EUR 100 

MEV up to 6 months 

United States 

USD 160 

EUR 133 

MEV up to 10 years 

The actual operational costs of processing visa applications are a determining factor for 
setting the visa fee. The economic strength and purchasing power of the issuing country, 
and hence the costs for human resources, have a strong correlation with the visa fee.  

The  correlation  between  a country's  visa  fee  and  its  economic  development  can  be 
observed comparing the table above with the graph below showing the nominal GDP per 
capita  and  the  GDP  at  purchasing  power  parity  (PPP)  per  capita  of  the  selected 
countries.84 

82  

UNWTO Tourism Highlights: 2017 Edition, https://www.e-
unwto.org/doi/book/10.18111/9789284419029. 

83   When the visa fee is not officially stated in EUR, the presented value is indicative.  
84  

The World Bank Group, https://data.worldbank.org/indicator/NY.GDP.PCAP.PP.CD. 

81 

 
 
 
 
                                                            
GDP per capita (USD) in 2016 - top tourist destinations 

United States

Australia

United Kingdom

Japan

New Zealand

Malaysia

Turkey

Mexico

Thailand

China

0

10.000

20.000

30.000

40.000

50.000

60.000

GDP PPP

nominal GDP

The top tourist destinations can be divided into two groups of countries, whereby the visa 
fee  roughly  corresponds  with  the  economic  development,  with  the  exception  of  Japan. 
One  group,  comprising  Australia,  New  Zealand,  the  United  Kingdom  and  the  United 
States,  applies  visa  fees  in  the  range  of  EUR  90  to  133.  The  second  group,  Malaysia, 
Turkey, Mexico, Thailand and China, requires on average a lower visa fee compared to 
the first  group. Furthermore, countries in  the  second group have  usually more complex 
visa fee system, whereas the first group applies a simpler system. Japan would fall under 
the category of higher GDP per capita; however the considerably lower visa fee makes it 
an exception. 

Average  GDP  (PPP)  per  capita  in  the  European  Union  reached  EUR  33,060  (USD 
39,838) in 2016.85 The Schengen area therefore clearly belongs to the first group of states 
with regard to their economic performance. The current Schengen visa fee of EUR 60 is 
therefore rather low compared to other countries in the same group. 

EU citizens are exempted from the visa requirement by many third countries. Those third 
countries  that  still  do  require  visas  do  not  always  apply  the  same  visa  fees  to  all  EU 
citizens.   

By  way  of  example,  the  following  table  shows  visa  fees  applied to  Belgian citizens  by 
selected third countries 

Country 

Angola 

Visa fee 

Fee in EUR86 
EUR 75 
EUR 120 

Comment 

SEV up to 30 days – ordinary 
SEV - urgent (10 days) 

85  

The World Bank Group, idem. Iceland: USD 51.399, Norway: USD 59.385, Switzerland: USD 
63.741. 

86   When the visa fee is not officially stated in EUR, the presented value is indicative.  

82 

 
 
 
                                                            
Algeria 

India 

Iran 

Ghana 

Jordan 

Myanmar 

Nigeria 

Pakistan 

Russia 

Saudi Arabia 

Vietnam 

EUR 190 

SEV - express (5 days) 

EUR 60 
EUR 90 
EUR 95 
EUR 190 
EUR 60 
EUR 70 
EUR 80 
EUR 70 
EUR 160-260 
EUR 67.50 
EUR 97.50 
EUR 187.50 
EUR 40 
EUR 50 
EUR 190 
EUR 380 
EUR 420 
EUR 74 
EUR 92 
EUR 60 
EUR 180 
EUR 3587 
EUR 123.50 or 
more 
EUR 29 
EUR 50 
EUR 79 
EUR 113 
EUR 130 

SEV  
MEV more than 90 days 
SEV/MEV up to 1 year - tourist 
MEV up to 5 years - tourist 
SEV 
TEV (two-entry visa) 
MEV 
SEV 
MEV 3 months – 1 year 
SEV 2 months 
TEV 3 months 
MEV 6 months 
Tourist visa 
Business SEV  
Business MEV 3 months 
Business MEV 6 months 
Business MEV 1 year 
SEV 
MEV  
SEV 
MEV 

SEV/TEV 

MEV Business visit visa 

SEV 3 months 
MEV 3 months 
MEV 6 months 
MEV 1 year 
MEV 5 years 

USD 88 
USD 110 

USD 10+25 
USD 10+50 
USD 95 
USD 135 
USD 155 

Also in that comparison the Schengen visa fee, which is a "flat-rate" fee both for SEV 
and MEV of up to 5 years, is rather at the lower end. 

87  

Based on EU-Russia Visa Facilitation Agreement. 

83 

 
 
 
 
 
 
 
 
 
 
 
 
                                                            
Part 4: Calculation of additional revenues from policy options 1C1, 1C2, 1C3 and 1C4 

84 

Estimation of visa feesOption 1C1Option 1C2Option 1C3Option 1C4Visa fee (in €)Total revenue (in €)Additional fee Additional fee Additional fee Additional fee Total number of visa applications 201716000000of which VFA countries (30%)480000035168000000Total number non VFA countries11200000of which children aged 6-11 (4.4%)492800351724800052464000157392000251232000052464000of which children aged 0-5 (3.3%)36960000other fee exemptions (2%)22400000of which full fees101136006060681600020202272000404045440006060681600020202272000of which MEV 1 year + (15%) - adults15170404060681600of which MEV 1 year + (15%) - children 6-1173920201478400Total 792064000204736000411936000619136000266896000increase in %25,848416352,0079185578,1674208133,696267 
 
 
 
Annex 6: Inbound tourism to the EU/Schengen countries  

Key facts and figures: 

  The  EU/Schengen  Member  States  rank  among  the  world's  leading  tourist 
destinations.  In  2016,  there  were  approximately  875  million  arrivals  at  tourist 
accommodations in Schengen countries, up from 635 million in 2009.88  

 

In  2016  the  tourism  industry  contributed  to  the  EU's  GDP  by  10.2%  and  to  the 
EU's labour market by 11.6%.89 

  Visa-required  travellers  represent  a  growing  share  of  all  tourists  in  the  EU  and 
have  the  strongest  growth  rates,  both  in  absolute  numbers  and  in  terms  of 
expenditure.  The  numbers  of  arrivals  of  visa-required  travellers90  at  tourist 
accommodations in Schengen countries increased by 175% from 2009 to 2016 (to 
37.8 million), while the overall number of arrivals increased by only 38%.91 

 

In  absolute  numbers,  there  were  approximately  11  million  arrivals  from  China, 
6.5 million  from  Russia,  3.1  million  from  African  countries,  and  2.4  million 
arrivals from Turkey at tourist accommodations in the Schengen area in 2016.92 

  Some  of  the  visa-required  nationals  rank  among  the  highest  spenders  in 
international  tourism  worldwide  with  Chinese  leading  the  global  expenditure 
ranking.  Expenditure  by  Chinese  outbound  tourists  grew  by  12%  to  USD  261 
billion,  consolidating  China's  position  as  the  number  one  source  market  in  the 
world  since 2012.93  The  growth  in  the  first  half  of  2017  was  19%,  compared  to 
the same period in 2016.94 

  Additionally,  other  visa  required  travellers  showed  double-digit  growth  in 
outbound tourism expenditure in 2016, for instance India (+16%), Qatar (+11%), 
Thailand (+11%), Vietnam (+28%) and Egypt (+19%).95 In the first half of 2017, 
tourism spending by Russian travellers grew by 27% after some years of declines, 
showing the recovery of this important market for the EU.96 

88  

Eurostat database, Arrivals at tourist accommodation establishments by country/world region of 
residence of the tourist, data updated on 07/11/2017. Those figures do not correspond to the overall 
numbers of travellers or trips, as tourists often stay at different accommodations during one trip. 
89   World Travel & Tourism Council, https://www.wttc.org/research/economic-research/economic-

90  

91  
92  
93  

94 
95  

96  

impact-analysis/. 
As figures are not available for all third-country nationals and sometimes only by region, only an 
approximation is possible. The following countries/regions were counted as visa-required for this 
purpose: Africa, China (including Hong Kong), other Asian countries (excluding Japan and South 
Korea), Russia, Turkey. 
Eurostat database, idem. 
Eurostat database, idem. 
UNWTO press release PR 17046, 12 April 2017, http://media.unwto.org/press-release/2017-04-
12/chinese-tourists-spent-12-more-travelling-abroad-2016. 
UNWTO, European Union Short-Term Tourism Trends, Volume 1, 2017-5. 
UNWTO, Tourism Highlights, 2017 Edition, http://mkt.unwto.org/publication/unwto-tourism-
highlights. 
UNWTO, European Union Short-Term Tourism Trends, Volume 1, 2017-5. 

85 

 
                                                            
  Europe's market share of Asian outbound tourism remains relatively low. Out of 
the  total  of  86.3  million  outbound  trips  made  by  Chinese  in  2016,  about  46.7% 
were  long-haul,  but  only  12.2%  were  made  to  Europe  (including  non-EU 
countries).  The  numbers  are  similar  for  India,  despite  an  even  bigger  share  of 
long-haul trips (16.7 million trips, 96.2% long-haul, 14.0% to Europe).97  

The following table presents data on global outbound tourism expenditure of Schengen 
visa required travellers from selected countries in million USD.98  

Country of 
origin 

China 
India 
Indonesia 
Kuwait 
Nigeria 
Philippines 
Qatar 
Russia 
Saudi Arabia 
Thailand 

2011 

2012 

2013 

2014 

2015 

72,585 
13,699 
8,653 
8,879 
9,533 
6,055 
7,813 
37,343 
18,202 
7,534 

101,977 
14,107 
9,055 
10,073 
9,240 
7,140 
10,702 
48,096 
17,986 
8,095 

128,576 
13,884 
10,280 
10,567 
9,150 
8,400 
11,729 
59,504 
18,648 
8,238 

234,662 
17,492 
10,263 
12,280 
9,068 
11,130 
12,871 
55,383 
25,137 
8,824 

292,200 
17,686 
9,800 
13,148 
9,200 
11,868 
11,641 
38,434 
20,366 
9,539 

Increase 
2011-2015 
303% 
29% 
13% 
48% 
-3% 
96% 
49% 
3% 
12% 
27% 

The following graph shows the steady tourism growth in the Schengen area, with the year 
2009  taken  as  a  baseline.  The  blue  line  represents  a  growing  share  of  visa-required 
travellers' arrivals at tourist accommodations, and hence their growing importance for the 
tourism industry in the Schengen area, while the red line illustrates the development of 
total arrivals to tourist accommodations.99 

Increase of visa-required/all travellers' arrivals at tourist accommodations 

200%

175%

150%

125%

100%

75%

50%

25%

0%

2009

2010

2011

2012

2013

2014

2015

2016

Visa required travellers

All travellers

97 

ETC, European Tourism in 2017: trends and Prospects (Q3/2017), http://www.etc-
corporate.org/reports/european-tourism-2017-trends-and-prospects-(q3-2017). 

98   World Tourism Organization (2017), Compendium of Tourism Statistics dataset [Electronic], 
UNWTO, Madrid, data updated on 25/09/2017.  Available data are not fully comprehensive. 
Eurostat database, Arrivals at tourist accommodation establishments by country/world region of 
residence of the tourist, data updated on 07/11/2017. 

99  

86 

 
 
 
                                                            
Annex 7: Elements carried over from the 2014 proposal  

The following elements of the 2014 Visa Code recast proposal are expected to be carried 
over to the new proposal100, with the aim of introducing procedural facilitations for visa 
applications and in view of simplifying, clarifying and streamlining existing provisions. 

Procedural facilitations 

Provision 
Deadline for lodging 
applications before the 
start of the intended trip 

Change 
Deadline extended from 3 to 
6 months for all applicants 
and to 9 months for seafarers 

Applicants should apply as a 
minimum 2 weeks before 
their intended travel. 

Maximum standard 
processing time reduced from 
15 to 10 days 
Maximum processing time for 
exceptional cases reduced 
from 60 to 45 days 
Member States will have the 
possibility of allowing 
applications at land and sea 
borders during a limited 
periods and under specific 
conditions  
Rules on who may lodge an 
application on behalf of the 
applicant have been clarified 

Clarification to allow for the 
use of modern means of 
communication (phone, 
Skype) to conduct interviews 
during the examination, 
where necessary. 
Form will be simplified and 
reorganised 
Entries have been added to 
ensure that the refused person 
is given detailed information 
on the appeal procedures 

Processing time 

Visas applied for at the 
border 

Practical arrangements for 
lodging an application  

Interviews of applicants 

Application form 

Refusal from 

Expected impacts 
This will allow applicants to better plan 
ahead and avoid waiting times during peak 
season. Flight tickets will also be cheaper as 
a result, leading to reduced costs for visa 
holders. For consulates the work load will 
be more evenly spread over the year.  
Sea crews typically have contracts of 8-9 
months during which they work in the high 
seas and can therefore not apply for a visa 
in view of their signing off the ship (in the 
EU, to return to their home country). 
Legal clarification, as many Member States 
already apply such deadlines. This will 
leave consulates sufficient time to assess 
applications, given also the proposed 
maximum processing time (10 days). This 
will not prevent late submission in 
individual cases. 
The shortening of decision-making 
deadlines will reduce the overall time for 
applying for a visa, which is one of the main 
difficulties raised by respondents in the 
open public consultation.  

Where Member States make use of this 
possibility, this will promote short-term 
tourism at short notice, most likely in the 
summer period. This will reduce costs and 
hassle for such tourists.  

Persons whose biometric data are already 
stored in the VIS will not have to go to the 
consulate or the external service provider to 
lodge their application, which will save 
them time and money. 
This measure, where used by Member 
States, will avoid that the applicant has to 
come in person to the consulate (after 
having lodged the application). This will 
save applicants time and money.  

This will make the form more user-friendly. 

This will give the person concerned precise 
information on the deadline and procedures 
to respect when appealing a negative 
decision 

100  

Some of the provisions will be amended from the original proposal to take account of positions 
expressed in the negotiations between the co-legislators.  

87 

 
                                                            
Clarification and streamlining  

Provision 
Definition of 'seafarers' 

Airport transit visa 
(ATV) requirements 

Member States' 
competence for 
examining and deciding 
on applications 

Prior consultation 

Verification of 
compliance with the 
90/180-days rule  

Cooperation with 
external service 
providers (ESP) 

Representation 
arrangements 

Cooperation between 
Member States 

Local Schengen 
cooperation 
(LSC) 

Operational annexes 

Expected impacts 
This clarification will ensure equal 
treatment of all categories of staff working 
on ships and allow for the smooth rotation 
of staff in the the shipping industry. 
This clarification will facilitate travel and 
airline boarding and controls at borders, for 
the persons concerned, airline ground staff 
and border guards. 

Clarification. Applicants will know better 
where to lodge the application. Member 
States will know who is competent. 
Currently the criterion of 'main' purpose of 
a trip is less precise and interpreted 
differently by Member States. 

This will contribute to shortening 
processing time and is in the interest of 
both applicants and the case-handling 
Member State. 
The Commission will be able to ensure 
timely information to other Member States 
and allow Member States to prepare at 
technical level and to inform the public.   
Clarification for both Member States and 
applicants. 

Improved monitoring of ESP activities, 
especially as regards data protection. 

This will simplify the conclusion of 
representation arrangements and contribute 
to shortening the processing time 

More transparency about representation. 

Enhanced consular coverage/presence and 
optimised use of Member States' resources. 

More efficient cooperation between 
Member States at local level.  

Simplification. Deletion of obsolete rules. 
Clarification in new operational 
instructions. 

Change 
Clarification to ensure that all 
staff working on ships benefit 
from the various procedural 
facilitations. 
Clarification of the rules 
regarding the exemption from 
the ATV requirement to persons 
holding certain residence and 
entry permits 
In case of one trip visiting 
several Member States or of 
several separate trips within a 
short time frame, the length of 
the intended stay will determine 
the main destination and thus 
which Member State is 
competent.  
Member States are required to 
reply as soon as possible to 
consultation requests 

Deadlines for timely 
notification to the Commission 
on introduction/withdrawal of 
prior consultation  
Clarification that earlier stays 
on the basis of a national long 
stay visa or a residence permit 
are not to be counted when 
verifying compliance with the 
90/180-days rule. 
Strengthening of rules 
regarding Member States' 
monitoring of ESP to ensure 
systematic and regular 
inspections and reporting. 
The represented Member State 
will not be able to require to be 
consulted during the 
examination procedure. 
Deadlines for timely 
information by Member States 
on representation arrangements 
More flexible rules to allow 
Member States to increase their 
consular coverage and develop 
cooperation with other MS. 
Strengthening of provisions to 
ensure that Member States carry 
out the mandatory tasks 
regarding harmonisation of 
practices and that EU 
Delegations ensure the 
coordination of LSC. 
Deletion of annexes on filling 
in and affixing the visa sticker 

88 

 
 
 
Annex 8: Sensitivity analysis of MCA  

This annex contains a sensitivity analysis of the qualitative assessment of policy options 
using the multi-criteria analysis (MCA) approach. It compares the aggregate impact score 
of  the  various  options  under  the  original  weighting  of  impact  criteria  (as  elaborated  in 
section  6.2)  with  the  impact  score  that  options  would  obtain  if  equal  weighting  were 
given to all specific impact criteria. The purpose is to assess the sensitivity of the MCA 
to such changes. The assessment of options against general principles (i.e. effectiveness, 
proportionality,  feasibility  and  coherence)  is  not  affected  by  different  weighting  of 
impact criteria and is therefore not taken into account in this annex. 

1. 

INSUFFICIENT FINANCIAL RESOURCES 

The following tables show the original weighting used for the assessment in section 6.2.1 
and  the  alternative  equal  weighting.  After  assigning  the  same  weighting  to  all  impact 
criteria  for  the  visa  fee  policy  options,  the  overall  impact  score  does  not  change 
significantly  and  the  ranking  order  remains  the  same.  The  option  1C3  (fee  of  120 
EUR) records the highest score, followed by the option 1C2 (100 EUR). Options 1C1 (80 
EUR) and 1C4 (80 EUR for MEV/SEV up to 6 months, 120 EUR for 1-5 years MEV) 
still largely record the same impact score. 

Impact criteria 

Weight 

Options 

Financial resources 
Integrity / security of 
Schengen area 
Changes in travel 
behaviour 
Aggregate impact score 

40% 
20% 

40% 

100% 

Impact criteria 

Weight 

Financial resources 
Integrity / security of 
Schengen area 
Changes in travel 
behaviour 
Aggregate impact score 

33% 
33% 

33% 

100% 

2.  REPEATED VISA PROCEDURES 

1A 
0 
0 

0 

0 

1A 
0 
0 

0 

0 

1B 
+1 
-1 

1C1 
+1 
+1 

1C2 
+2 
+2 

1C3 
+3 
+3 

1C4 
+1 
+1 

0 

0 

-1 

-2 

0 

+0.2 

+0.6 

+0.8 

+1.0 

+0.6 

Options 

1C1 
+1 
+1 

1C2 
+2 
+2 

1C3 
+3 
+3 

1C4 
+1 
+1 

0 

-1 

-2 

0 

+0.7 

+1.0 

+1.3 

+0.7 

1B 
+1 
-1 

0 

0 

The following tables show the original weighting used for the assessment in section 6.2.2 
and  the  alternative  equal  weighting.  The  overall  impact  score  of  the  policy  options  for 
repeated visa procedures does not change significantly and the  ranking order remains 
the  same  after  assigning  the  same  weighting  to  all  impact  criteria.  The  option  2D 
(standard  MEV  of  2-5  years)  still  records  the  highest  score,  followed  by  options  2C1 
(general MEV cascade) and preferred 2C2 (general and country MEV cascades). 

89 

 
 
 
Impact criteria 

Weight 

Cost savings for Member 
States  
Cost savings for frequent 
travellers 
Changes in travel 
behaviour 
Aggregate impact score 

20% 

20% 

60% 

100% 

Impact criteria 

Weight 

Cost savings for Member 
States  
Cost savings for frequent 
travellers 
Changes in travel 
behaviour 
Aggregate impact score 

33% 

33% 

33% 

100% 

2A 
0 

0 

0 

0 

2A 
0 

0 

0 

0 

Options 

2C1 
+2 

2C2 
+2 

2C3 
+1 

+3 

+3 

+3 

+3 

+2 

+2 

2D 
+4 

+5 

+4 

2B 
0 

+1 

+1 

+0.8 

+2.8 

+2.8 

+1.8 

+4.2 

Options 

2C1 
+2 

2C2 
+2 

2C3 
+1 

+3 

+3 

+3 

+3 

+2 

+2 

2D 
+4 

+5 

+4 

2B 
0 

+1 

+1 

+0.7 

+2.7 

+2.7 

+1.7 

+4.3 

3.  RETURN OF IRREGULAR MIGRANTS  

The following tables show the original weighting used for the assessment in section 6.2.3 
and  the  alternative  equal  weighting.  The  policy  option  3C1  (negative  incentives  – 
maximum approach)  obtains  the negative score of  -0.3 after  equalling weighting  of the 
impact  criteria,  which  makes  it  the  least  favourable  option.  The  score  of  the  preferred 
option  3C2  (negative  incentives  –  targeted  approach)  ranks  equally  with  the  remaining 
options 3A (status quo) and 3B (positive incentives). 

Impact criteria 

Weight 

Options 

Improved return rates 
Changes in travel behaviour 
External relations / image of EU 
Aggregate impact score 

60% 
10% 
30% 
100% 

Impact criteria 

Weight 

Improved return rates 
Changes in travel behaviour 
External relations / image of EU 
Aggregate impact score 

33% 
33% 
33% 
100% 

3A 
0 
0 
0 
0 

3A 
0 
0 
0 
0 

3B 
0 
0 
0 
0 

3C1 
+2 
-1 
-2 
+0.5 

Options 

3B 
0 
0 
0 
0 

3C1 
+2 
-1 
-2 
-0.3 

3C2 
+2 
-1 
-1 
+0.8 

3C2 
+2 
-1 
-1 
0 

90