COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on strengthening the security of identity cards of Union citizens and of residence documents issued to Union citizens and their family members exercising their right of free movement
Date: 2018-04-17
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: EU national, European citizenship, external border of the EU, foreign national, free movement of persons, freedom of movement, identity document, personal data, residence permit

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 17.4.2018 SWD(2018) 110 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on strengthening the security of identity cards of Union citizens and of residence documents issued to Union citizens and their family members exercising their right of free movement {COM(2018) 212 final} - {SWD(2018) 111 final}  
 
 
1 

POLICY AND LEGAL CONTEXT ....................................................................................... 4 

1.1. 
1.2. 

Introduction ............................................................................................................................... 4 
Policy and legal context ............................................................................................................ 4 

2 

PROBLEM DEFINITION ....................................................................................................... 9 

2.1.  What are the problems (and their drivers)? ............................................................................... 9 
Insufficient acceptance of ID and residence documents in another Member State .............. 9 
2.1.1. 

2.1.2. 

2.1.3. 

Document fraud and lack of authentication of ID and residence documents ..................... 11 

Complexity of issuance and administration of ID and residence documents ..................... 14 

2.2.  How will the problem evolve? ................................................................................................ 15 

3  WHY SHOULD THE EU ACT? ........................................................................................... 18 

3.1. 
3.2. 
3.3. 

Legal basis ............................................................................................................................... 18 
Subsidiarity: Necessity of EU action ....................................................................................... 18 
Subsidiarity: Added value of EU action .................................................................................. 20 

4 

OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 20 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 21 

5.1.  What if there is no EU action? ................................................................................................ 22 
Policy Option ID – format and security of ID cards ................................................................ 25 
5.2. 
Policy Option RES – format and security of residence documents ......................................... 29 
5.3. 
5.4. 
Policy option PROCESS – process regarding the issuance of ID cards and residence 
documents,  as  well  as  Member  States  sharing  information  about  the  related 
processes ................................................................................................................................. 30 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 31 

6.1. 
6.2. 
6.3. 

Impacts of the options for ID cards ......................................................................................... 33 
Impacts of the options for residence documents ..................................................................... 41 
Impacts of the options for PROCESS ..................................................................................... 46 

7 

HOW DO THE OPTIONS COMPARE? .............................................................................. 49 

7.1.  Comparing the options for ID cards ........................................................................................ 49 
7.2.  Comparing the options for residence documents..................................................................... 52 
7.3.  Comparing the options for PROCESS .................................................................................... 54 
7.4.  How sensitive are the preferred options to using different weights for the criteria? ............... 56 

8 

PREFERRED OPTION ......................................................................................................... 56 

8.1. 
The preferred options .............................................................................................................. 56 
8.2.  Combined impact of the preferred options .............................................................................. 57 
8.3.  REFIT (simplification and improved efficiency) .................................................................... 61 

9 

HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 62 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................. 64 

ANNEX 2: STAKEHOLDER CONSULTATION ........................................................................ 67 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 80 

ANNEX 4: ANALYTICAL METHODS ....................................................................................... 84 

ANNEX 5: SCOPE OF INITIATIVE (ID CARDS AND RESIDENCE DOCUMENTS) ......... 102 

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ANNEX 6: CONSEQUENCES TO PROBLEMS IDENTIFIED ................................................ 109 

ANNEX 7: POLICY OPTIONS - DETAILS ............................................................................... 121 

ANNEX 8: THE PREFERRED OPTION(S) - DETAILS ........................................................... 123 

ANNEX 9: MONITORING AND EVALUATION OF IMPACTS - DETAILS ........................ 128 

ANNEX 10: IMPACT OF PREFERRED OPTION PER MEMBER STATE ............................ 129 

2 

 
 
Glossary 

Term or acronym 

Meaning or definition 

DOVID 

EES 

eID 

eID card  

Diffractive Optical Variable Image Device  

Entry Exit System  

Electronic identity 

Card  with  a  chip  on  which  electronic  information  for 
identification purposes can be stored 

eIDAS Regulation 

electronic IDentification, Authentication and trust Services 

FADO 

GDPR 

ICAO 

ID card 

MRTD 

MRZ 

OVD 

PKD 

PKI 

PRADO 

REFIT 

RFID chip 

SIS 

SLTD 

TCN 

False and Authentic Documents Online 

General Data Protection Regulation 

International Civil Aviation Organisation 

Identity card 

Machine readable travel document 

Machine readable zone 

Optically variable device 

Public key directory 

Public key infrastructure 

Public register of travel and identity documents 

Regulatory Fitness and Performance Programme  

Radio-frequency identification chip 

Schengen information system 

Stolen and Lost Travel Document  

Third country national 

TCN FAM 

Third country national family members 

TFEU 

YEA 

Treaty on the functioning of the European Union 

Your Europe Advice 

3 

 
 
 
 
1 

POLICY AND LEGAL CONTEXT 

1.1. 

Introduction 

European citizens are increasingly mobile. They make hundreds of millions of journeys every 
year  within  the  EU  or  entering  and  leaving  its  external  borders.  More  than  15  million  EU 
citizens reside in another EU country and more than 11 million working in another Member 
State1. European students and young people increasingly use their free movement rights to do 
an ERASMUS in another EU country or when joining the European Solidarity Corps. 

The free movement of EU citizens relies on ID cards, which can be used by EU citizens as 
travel  documents  and  also  to  establish  their  identity  when  exercising  their  right  to  live  in 
another country ('mobile citizens') after three months. These mobile citizens – and their non-
EU family members – also receive documents to prove their residence in their host Member 
State.  These  documents  (registration  certificates,  residence  cards  and  permanent  residence 
cards for EU citizens and their non-EU family members) are not travel documents. However, 
residence  cards  of  non-EU  family  members  of  mobile  EU  citizens  used  together  with  a 
passport give the right to travel visa-free if they travel with or join the EU citizen.  

There  is  no  standardisation  at  the  EU  level  of  the  information  all  these  documents  contain 
and/or of their security features. There are currently about 250 different versions of ID cards 
and  residence  documents  in  valid  circulation  in  the  European  Union.  This  diversity  creates 
insufficient  acceptance  by  public  and  private  entities  of  both  ID  cards  and  residence 
documents. Insufficient security of both ID cards and residence documents for non-EU family 
members hampers the free movement of citizens and undermines security within borders. In 
addition, there have been a number of problems reported related to the issuance, handling and 
administration of all these documents.  

This initiative addresses difficulties in exercising free movement and aims to increase security 
within  the  European  Union.  Security  and  free  movement  are  inherently  linked:  in  the 
Preamble to the Treaty on the European Union the Member States are “resolved to facilitate 
the  free  movement  of  persons,  while  ensuring  the  safety  and  security  of  their  peoples,  by 
ensuring an area of freedom, security and justice (…)” 
This Impact Assessment is based on the findings of an external study2, a public consultation 
and stakeholder consultation3 and other sources. (See Annex 5 for more details on the scope.) 

1.2. 

Policy and legal context 

Europeans  consider  free  movement  to  be  a  major  achievement  of  European  integration.  It 
covers the right to enter and leave territory of another Member State, as well as the right to 
stay  there.  Measures  regarding  free  movement  are  inseparable  from  measures  introduced  to 
guarantee security within the European Union.  

The  most  relevant  EU  instrument  in  this  context  is  the  Free  Movement  Directive 
(2004/38/EC)4 which establishes the conditions for the exercise of the right of free movement 

1 2016 annual report on intra-EU labour mobility (2015 data). 
2 CSES: ‘EU policy initiatives on residence and identity documents to facilitate the exercise of the right of free 
movement’, August 2017 
3 See Annex 2. 

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and  residence  (both  temporary  and  permanent)  for  EU  citizens  and  their  family  members. 
This directive lays down that, in conjunction with a valid ID card or passport, EU citizens and 
their  family  members  may  enter  and  live  in  another  Member  State  (subject  to  exceptional 
restrictions) and may register for residence documentation. The Directive, however, does not 
regulate  the  format  and  minimum  standards  for  ID  cards  to  be  used  to  enter  or  leave  EU 
Member  States.  In  the  same  way,  it  does  not  provide  for  specific  standards  as  regards 
residence documents issued to EU citizens and their non-EU family members.  

EU law already provides for standards for security features and biometrics in passports and 
travel  documents  issued  by  Member  States5  and  on  uniform  formats  for  visas6  and 
residence  permits  for  third  country  nationals.7  These  standards  are  also  used  for  local 
border permits8 and permits issued in the framework of the EU legal migration acquis, but not 
for the documents under consideration in this impact assessment. In 25 October 2017, a new 
common  design  for  the  residence  permit  for  third-country  nationals  was  adopted  to 
improve its security features9. This ‘uniform format’ may be used for another purpose, such 
as for residence and permanent residence cards for third country national family members of 
mobile EU citizens ("TCN FAM cards"), if this purpose is clearly indicated on the card10.  
The Schengen Borders Code11 sets out procedures for checks on EU and non-EU nationals at 
the external borders. Border guards have to perform these checks quickly and efficiently and 
rely  on  technologies/databases,  training  and  guidance  tools  to  enable  them  to  verify  travel 
documents, including identity cards. The recent amendment of the Schengen Borders Code12 
makes it obligatory to check all persons and verify their travel documents, regardless of the 
holder’s nationality, against the Schengen  Information  System (SIS) and the Interpol Stolen 
and Lost Travel Document (SLTD) database. The security features of electronic identity (eID) 
documents  should  also  be  checked  when  technically  possible.  Holders  of  eID  documents 
should be able to use e-gates, freeing up time for border guards to handle other travellers. 

To  contribute  to  the  modernisation  of  the  border  management  at  the  external  Schengen 
borders,  to  help  Member  States  dealing  with  ever  increasing  number  of  travellers,  and  to 
identify  over-stays  and  contribute  to  EU  security,  a  Regulation  establishing  an  Entry  Exit 
System (EES)13 has been recently adopted. This system will register the entry and exit data of 

4 Directive 2004/38/EC of the European Parliament and of the Council of 29 April 2004 on the right of citizens 
of the Union and their family members to move and reside freely within the territory of Member States (OJ L 
158, 30.4.2004, p. 77). 
5 Regulation (EC) No 2252/2004 (OJ L 385, 29.12.2004, p.1). UK and IE are not part of this measure. 
6 Regulation (EC) No 1683/95 (OJ L 164, 14.7.1995, p.1). 
7 Regulation (EC) No 1030/2002 (OJ L 157, 15.6.2002, p.1). 
8 Regulation (EC) No 1931/2006 (OJ L 405, 30.12.2006, p. 1). 
9  Regulation  (EU)  2017/1954  of  the  European  Parliament  and  of  the  Council  of  25  October  2017  amending 
Council  Regulation (EC)  No 1030/2002 laying down  a  uniform  format  for residence permits  for  third-country 
nationals (amended in 2017) 
10 Art. 5a of Council Regulation 1030/2002. 
11 Regulation (EU) 2016/399 of the European Parliament and of the Council of 9 March 2016 on a Union Code 
on the rules governing the movement of persons across borders (Schengen Borders Code) (OJ L 77, 23.3.2016, 
p. 1). 
12  Regulation  (EU)  2017/458  of  the  European  Parliament  and  of  the  Council  of  15  March  2017  amending 
Regulation (EU) 2016/399 as regards the reinforcement of checks against relevant databases at external borders. 
13 Regulation (EU) 2017/2226 of the European Parliament and of the Council of 30 November 2017 establishing 
an  Entry/Exit System  (EES) to  register  entry and  exit data  and refusal of  entry  data of  third-country  nationals 

5 

 
 
                                                                                                                                                         
 
non-EU nationals crossing the EU’s external borders who are admitted for a short stay into the 
Schengen  area  (maximum  90  days  in  any  180-day  period)  including  third  country  family 
members  of  EU  citizens  exercising  their  free  movement  rights14.  However,  this  system  will 
not register data for third country family member holders of a residence card, as their right to 
stay/reside is not limited to a short term stay. The system is expected to be operational by the 
end of 2020.  

Again  in  relation  to  short  stays,  in  November  2016  the  Commission  presented  a  legislative 
proposal  to  establish  the  European  Travel  Information  and  Authorisation  System 
(ETIAS).  This  initiative  aims  to  improve  control  over  who  is  allowed  to  enter  the  EU  and 
who is  admitted  for a short  stay into the Schengen  area  (maximum 90 days  in  any 180-day 
period),  including  the  third  country  family  members  of  EU  citizens  exercising  their  free 
movement  rights.  Like  the  EES,  the  ETIAS  legislative  proposal  excludes  the registration  of 
both  EU  citizens  and  of  third  country  nationals  holding  a  residence  card15,  given  that  their 
rights to reside are different. 

The  initiative  addresses  applications  of  ID  card  and  residence  documents  where  a  person  is 
mobile, crosses a border, travels or temporarily or permanently moves to another country with 
the intention of residing there. When moving to and residing in other countries certain actions, 
such  as  registration  at  school  or  opening  a  bank  account  are  carried  out.  Usually  this  will 
require  personal  interaction.  The  ID  cards  and  residence  documents  addressed  should  help 
citizens do these things. 

In  the  future  a  lot  of  these  actions,  however,  might  be  carried  electronically.  ID  cards  and 
residence documents can also serve as platforms for electronic functionalities such as eID16, 
digital  signature,  etc.  which  are  key  to  accessing  electronic  services  abroad.  ID  cards  and 
residence  documents  are  also  used  by  EU  citizens  and  their  non-EU  family  members  to 
identify  themselves  to  public  and  private  entities  for  instance  at  polling  stations  during 
European  elections17  or  to  buy  specific  products.  They  enable  the  completion  of  certain 
administrative  formalities online (e.g. birth  certificate requests) or  access to  certain services 
(waste recycling facilities in a municipality), for instance18.  

This  initiative  supports  this  development,  however  improvement  of  cross-border  access  to 
services is mainly tackled by other initiatives, such as the eIDAS Regulation and the Single 
Digital Gateway. 

crossing the external borders of the Member States and determining the conditions for access to the EES for law 
enforcement  purposes,  and  amending  the  Convention  implementing  the  Schengen  Agreement  and  Regulations 
(EC) No 767/2008 and (EU) No 1077/2011 
14 Notwithstanding this registration, non-EU family members of EU mobile citizens have the right to stay when 
they join or accompany the mobile EU citizen. 
15 http://europa.eu/rapid/press-release_IP-16-3674_en.htm  
16  eID  functionality  is  included  in  16  Member  States  ID  cards  (see  Annex  5  Table  2.2)  and  3  Member  States 
residence cards (BE, LV, SK). 
17 Council Directive 93/109/EC laying down detailed arrangements for the exercise of the right to vote and stand 
as  a  candidate  in  election  to the  European Parliament  for  citizens  of  the  Union  residing  in  a  Member  State  of 
which they are not nationals (OJ L 329 of 30.12.1993, p. 34) 
18 This functionality is attached to national cards with eID functionality in some Member States, such as Belgium 
and Estonia. 

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Technical  and  data  protection  requirements  will  have  to  be  respected,  so  that  the  main 
functionalities  of  ID  cards  and  residence  documents  (proof  of  identity  and  residence  and 
travel documents) are not jeopardised. 

The  eIDAS  Regulation  ('Regulation  on  electronic  Identification  and  Authentication 
Services’)19 entered fully into force on 1 July 2016. This Regulation introduced the EU-wide 
mutual  recognition  of  electronic  identifications  in  access  to  public  services.  The  eIDAS 
Regulation  helps  citizens  moving  to  another  Member  State  by  requiring  electronic 
identification  means  to  be  recognised  in  another  Member  States.  One  of  the  means  is  to 
include  electronic  identification  on  the  identity  card.  The  Regulation  is  aligned  with  the 
objectives  of  the  Digital  Agenda  for  Europe20,  one  of  the  seven  pillars  of  the  Europe  2020 
Strategy21 and thus plays a key role in achieving growth and security in the European Union22. 

In May 2017 the Commission submitted a proposal for a  Regulation on the Single Digital 
Gateway 23. The General Approach reached in November 201724 states that users should have 
easy, online access to information about, inter alia, travel documents (including ID cards) and 
residence documents via the ‘single portal’. 
The European Commission 2018 Work Programme (REFIT)25 includes the presentation of 
a  legislative  initiative  to  improve  the  security  of  ID  cards  and  residence  documents  of  EU 
citizens and of their non-EU family members. 26  

There is support for an initiative on ID cards and residence documents at political level. This 
initiative  addresses  the  Council's  repeated  calls  to  improve  the  security  of  identity  and 
residence documents27. Most recently, in 2017, it adopted two sets of Council Conclusions28, 

19 Regulation (EU) No. 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification  and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive 
1999/93/EC (OJ L 257, 28.8.2014, p. 73–114). 
20 Communication from the Commission to the European Parliament, the Council, the European Economic and 
Social  Committee  and  the  Committee  of  the  Regions,  ‘A  Digital  Agenda  for  Europe’,  COM/2010/0245  final, 
(2010). 
21  EUROPE  2020  A  strategy  for  smart,  sustainable  and  inclusive  growth,  COM/2010/2020  final,  (2010).  The 
Europe 2020 Strategy is Europe’s ten-year jobs and growth strategy. 
22  eID  has  been  praised  as  “important  enabler  of  data  protection  and  the  prevention  of  online  fraud.” 
https://ec.europa.eu/digital-single-market/en/e-identification#Article  
23 COM 2017) 256 final: Proposal for a Regulation of the European Parliament and the Council on establishing a 
single digital gateway to provide information, procedures, assistance and problem solving services and amending 
Regulation (EU) No 1024/2012. 
24 Council document 8838/17 + ADD 1. 
25 This topic was also discussed in the framework of the REFIT Platform, which encouraged the Commission to 
analyse the feasibility of harmonising identity and residence documents, or any of their key features, with a view 
to  facilitating  free  movement  and  tackling  the  challenges  faced  by  EU  mobile  citizens  in  their  host  countries 
(REFIT Platform Opinion on the submission by a citizen (LtL 242) on Identity and Travel Documents, 7 June 
2017). 
26 The adoption of a legal proposal on ID cards and residence documents is scheduled for 17 April 2018 as part 
of a security package. 
27 Already in 2005, Member States unanimously adopted Council Conclusions on minimum standards relating to 
the security of issuing processes for Member States’ identity cards (Council doc. 14390/05). This was followed 
by a Resolution in 2006 http://register.consilium.europa.eu/doc/srv?l=EN&f=ST%2014938%202006%20INIT. 
28 Council Conclusions on the Commission Action plan to strengthen the European response to travel document 
fraud adopted on 27 March 2017 http://www.consilium.europa.eu/en/press/press-releases/2017/03/27/jha-travel-
document-fraud. 

7 

 
 
                                                 
 
recognising  the  crucial  importance  of  secured  travel  and  identity  documents  to  tackle  the 
phenomenon of travel document fraud, underlining the importance of security standards of ID 
cards and residence documents, and called on the  Commission  to  ensure appropriate  follow 
up. These Conclusions followed the Commission's presentation of its:  

  2017 citizenship report, in which the Commission committed analyse policy options to 

improve the security of identity cards and residence documents 

  2016  Communication  on  security  and  mobility29,  in  which  the  Commission 

highlighted the need for quality and certainty in identity documents, and 

  2016  Action  Plan  on  document  security  of  December  201630,  in  which  the 
Commission  addresses  travel  document  fraud  including  identity  cards  and  residence 
documents. 

The European Parliament in its Resolution on the EU Citizenship Report 2017, adopted on 
12  December  201731,  supported  the  possibility  of  introducing  a  European  identity  card  in 
addition to national identification documents. 

At technical level there is a more mixed response to a potential initiative, depending on the 
Member State and the part of the national administration answering. Member States experts in 
charge of borders largely support harmonisation of security features of ID cards and residence 
cards, whereas national experts from the FREEMO expert group (in charge of free movement) 
support  to  a  lesser  extent  harmonisation  of  the  security  features  for  ID  cards  and  residence 
documents. 32 

EU citizens and their family members responding to the open public consultation were largely 
in favour of an EU intervention on ID cards and residence documents largely support the idea 
of  an  EU  intervention.  Around  70%  of  respondents  supported  it  for  ID  cards,  with  almost 
75% supporting strong or very strong security features. 70% would even support a European 
format for ID card.  

Certain civil society organisations support Member States phasing out of paper-based identity 
cards as soon as possible and argue for minimum harmonisation as regards security features 
and format but without the need ‘that the ID cards should necessarily look exactly the same’.  

More details from the stakeholder consultations are presented in Annex 2. 

on 

the  EU  Citizenship  Report 

Council  Conclusion 
2017 
http://data.consilium.europa.eu/doc/document/ST-9080-2017-INIT/en/pdf 
29 COM(2016) 602 final. 
30 COM(2016) 790 final. 
31http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P8-TA-2017-
0487+0+DOC+PDF+V0//EN 
32 On 24 answers, 15 explicitly supported common security features for ID cards and residence documents (more 
particularly for third country nationals family members), but only two expressly disagreed. 

11  May 

adopted 

2017 

on 

8 

 
 
 
 
                                                                                                                                                         
2 

PROBLEM DEFINITION 

Figure 2.1 Problem Tree – Initiative on ID and residence documents 

S
R
E
V
R
D

I

S
M
E
L
B
O
R
P

S
E
C
N
E
U
Q
E
S
N
O
C

PROBLEM DRIVERS 

A.  Differences  and  inconsistency  in  nomenclature,  format,  design  and  layout,  type,  substrate,  period  of  validity, 
functionality and use of ID and residence documents  

B. Failure to include basic and advanced security features in documents 

C. Insufficient coordination of Member States on the production of documents and the information they contain 

D.  Lack  of  awareness  of  documents,  the  rights  linked  to  them,  as  well  as  lack  of  training  of  the  persons  checking  the 
documents 

E. Bureaucratic, lengthy and not citizen-friendly procedures regarding the issuance and renewal of documents 

1. Insufficient acceptance of ID and residence documents in another Member State 

2. Document fraud and lack of authentication of ID and residence documents. 
3. Complexity of issuance and administration of ID and residence documents 

PROBLEMS 

Citizens 

Burden and cost for EU citizens and their family members when travelling 

Burden and cost for mobile* EU citizens and their family members  

CONSEQUENCES 

Intra-EU mobility more difficult or expensive 

Public authorities 
/Member States 

Threat to the security of the EU and its Member States 

Burdensome and costly administrative procedures 

Private sector 

Burdensome and costly administrative procedures 

"*": EU citizens who have exercised their right to freely move and reside within the EU. 
For more details see Annex 6.  

2.1.  What are the problems (and their drivers)? 

2.1.1.  Insufficient  acceptance  of  ID  and  residence  documents  in  another 

Member State 

Up to 370 of the 440 million citizens in 26 Member States (DK and UK do not issue ID cards) 
could hold national ID cards. While Member States are obliged to accept each other’s (at least 
86 currently circulated versions33  of)  national  ID cards as  travel documents  on the basis of 
the EU free movement acquis, there are no EU identity document standards (see Table 2.1 in 
Annex 5 for examples of national ID cards issued).  

Member States do not apply a common format, minimum standard information or minimum 
production standards. Public and private actors must nonetheless all treat all these ID cards, of 
variable quality, as being of equal evidential value.  

33 CSES study 

9 

 
 
                                                 
 
 
 
This  creates  problems:  because  of  the  inconsistent  design  and  information  provided,  it  is 
often  challenging  even  to  identify  ID  cards  as  such  and  verify  they  are  validly  issued.  This 
causes citizens to be wrongly turned away at the border or refused boarding on flights, and to 
be unable to access public or private services they are entitled to. These problems discourage 
citizens from exercising their rights to move freely in the Union. Along with the issues of 
security and authentication considered below, this means that despite  the legal obligation to 
recognise each other's documents, in practice ID cards issued in one Member State are often 
not accepted in another.  

Compared  to  ID  cards  residence  documents  have  a  narrower  function  and  use.  They  are 
usually not used as stand-alone documents but in combination with an identity document to 
register  with  an  administration,  access  a  service  or  TCN  family  members  to  cross  a  border 
without a visa. The order of magnitude of the problems associated with residence documents 
is therefore somewhat narrower than those for ID cards. 

It is estimated that there are at least 181 different types of residence documents issued in the 
EU with no consistent terminology applied, great variety in their format, the information they 
bear, and – if needed – their security features.34  

Not  all  residence  documents  include  the  most  relevant  data  (e.g.  date  and  place  of  issue). 
Regarding  residence  documents  for  EU  citizens  there  are  at  least  15  Member  States35  and 
regarding  TCN  FAM  residence  documents  10  Member  States36  where  no  translation  of  the 
title to another EU language is provided.  

Not  every  Member  State  issues  all  the  various  types  of  residence  documents,  and  certain 
residence documents, in particular registration certificates, are still very often issued on plain 
paper  (see Annex  5,  Table  2.3  for  more  details).  There  is  also  some  considerable  confusion 
over  the  legal  status  and  the  distinctive  role  of  the  various  types  of  residence  documents.37 
This confusion and inconsistency among residence documents creates problems for mobile 
EU citizens when they have to prove their residence in other Member States. 

As regards insufficient acceptance of documents, there is only indirect evidence, as no public 
or private entity collects statistics on this. The indirect evidence relies upon citizens affected 
by  this  who  subsequently  report  this  incident  directly  to  us  or  via  Your  Europe  Advice, 
SOLVIT, consultations, REFIT, surveys or other channels. What can be said is that dozens of 
non-acceptance cases have been reported very regularly throughout the years and that certain 
incidents of non-acceptance can be attributed to documents issued by certain Member States. 
Of  the  250  respondents  to  the  open  public  consultation,  over  a  third  reported  difficulties 
regarding acceptance of their national ID cards as proof of ID when dealing with public and 
private services.   

34 CSES study 
35  AT,  DE,  EL,  ES,  FI,  FR,  IE,  HU,  IT,  LU,  MT,  PL,  PT,  SK  and  UK;  the  situation  for  five  countries  is 
unknown. 
36 AT, BE, ES, FR, IT, LU, MT, PL, SK and UK 
37 For instance, some EU citizens had been living in Bulgaria using the wrong residence document for several 
years. On their arrival in the host country they were issued a one year’s residence card instead of an EU citizen 
registration certificate. Your Europe Advice, Quarterly Feedback report January-April 2016, page 26.  

10 

 
 
 
                                                 
Consequences  

The  problems  related  to  the  lack  of  acceptance  of  ID  and  residence  documents  have  interrelated 
consequences for mobile EU citizens, authorities, including border guards, and private sector entities 
(for more details see Annex 6 – sections 2 and 3).  

-  Difficulties  with  document  acceptance  cause  delays  for  citizens  when  using  national  ID  cards  as 
proof  of  identity  or  residence  documents  as  proof  of  residence  to  access  basic  social  services 
(healthcare, childcare etc.), banking and other services in other Member States.  

-  The  use  of  differing  residence  documents  for  TCN  family  members  at  borders  increases  delays  or 
even  exposes  people  to  the  risk  of  being  wrongly  refused  entry  or  passage.  For  instance  Italian  and 
Greek  paper  ID  cards  are  frequently  rejected  at  certain  border  checks  (e.g.  in  UK,  Germany  and 
Spain).    The  fact  that  border  control  officials  are  not  always  familiar  with  the  various  identity 
documents  in  circulation  can  also  result  in  more  profound  consequences,  or  at  least,  delays  and 
inconvenience  for  citizens  when  exercising  their  right  of  free  movement  due  to  lengthy  document 
checks. Furthermore, there is a constant and costly need for border control agencies to provide training 
to officials to deal with the huge variety of different documents and to ensure they are able to detect 
fraudulent documents.  

2.1.2.  Document  fraud  and  lack  of  authentication  of  ID  and  residence 

documents  

Swift  and  reliable  authentication  of  a  document  and  its  holder  requires  a  high  quality 
document.  While there are currently no EU standards for national identity  documents, there 
are international standards for machine readable travel documents set out in DOC 930338 
by the International Civil Aviation Organization (ICAO) providing for global interoperability 
in  respect  of  documentary  recognition,  authentication  and  security  characteristics.  The 
Passport Regulation39 which harmonises the security features for passports in the EU, applies 
this standard, including the parts on biometric e-passports. This can be considered the current 
state-of-the-art in the EU for secure travel documents. 

Some  ID  cards  and  TCN  FAM  residence  cards  are  not  up  to  those  standards  regarding 
document security (see Annex 5, Tables 2.2 and 2.3 for more details). This does not allow for 
their swift and reliable authentication. Some Member States include biometric data in their ID 
cards  and  TCN  FAM  residence  cards  and  others  do  not.40  Physical  security  features  also 
differ, such as printing techniques and UV (ultraviolet) features.  

This  makes  fraud  based  on  the  ‘weakest  link’  easier.  Documents  are  particularly  prone  to 
fraud where they lack key security features or where issuing Member States do not ensure that 
the  digital  data  contained  in  the  contactless  (RFID)  chip  are  sufficiently  protected.  Forged 
cards  and  the  prevention  and  detection  of  fraud  create  costs  for  private  and  public  sector 
entities.  

38 This standard is divided into parts which deal with different types of travel document (passport, various sizes 
of ID cards etc.), and different aspects (biometric identification, electronic security mechanisms). Part 3 provides 
Specifications  Common  to  all  Machine  Readable  Travel  Documents,  and  can  be  considered  the  absolute 
minimum  in  terms  of  document  interoperability.  Parts  9  to  12  deal  with  biometrics,  its  storage,  security 
mechanisms and public key infrastructures (PKI). 
39  Council  Regulation  (EC)  No  2252/2004  of  13  December  2004  on  standards  for  security  features  and 
biometrics in passports and travel documents issued by Member States. 
40 13 countries do not use biometrics for their ID cards, as well as five not for their TCN FAM cards.  

11 

 
 
                                                 
Three Member States41 issue ID cards without a functional machine readable zone as set by 
ICAO DOC 9303 for travel documents. Seven countries42 issue ID cards without a RFID chip. 
Thirteen Member States43 do not include any biometric data. Facial images and fingerprints – 
included in passports – provide assurance in cases where there is a doubt on the identity of the 
card holder.44 Machine readability and RFID chips facilitate this. (See Annex 5, Table 2.2 for 
more details.)  

For  ID  card  holders,  this  negatively  affects  the  interoperability  and  efficiency  of  border 
checks  across  the  EU.  It  means  that  citizens  cannot  use  them  in  automatic  e-gates,  and  it 
means that they are much more likable to be tampered with, much harder to authenticate, thus 
more susceptible to being misused, which increases the likelihood that they will be rejected 
wrongly,  or  that  false  or  misused  documents  will  be  allowed  to  circulate.  Security  in  the 
Union  is  reduced,  citizens  are  disadvantaged  and  risk  and  cost  for  authorities  and  private 
service providers is increased.  
Where  TCN  FAM  residence  card  are  falsified  exploiting  weak  document  standards45,  their 
bearers could be wrongly exempted from the visa obligation at external borders.  

A  wider  security  risk  to  the  European  Union  stems  from  the  fact  that,  once  a  person  has 
entered the Schengen Area using a fraudulent document, they can travel on to other Schengen 
Member States without in principle facing another document inspection.46 

The  European  Border  and  Coast  Guard  Agency  (FRONTEX)  has  collected  statistics  on 
fraudulent  ID  and  residence  documents  over  the  last  years.  The  number  of  documents 
detected does not seem very high (38 870 ID cards from 2013-2017) but this is based upon a 
small sample of random checks.  

Table: Document fraud data by FRONTEX (for further details see Annex 6 - section 1)  

Fraudulent ID cards (all 
reasons) 2013-2017 

38 870 

Top 3 countries 2017 
Counterfeit ID cards 
Romania (775) 
Italy (752) 
Greece (636) 

Top 3 countries 2017 
Stolen blank ID 
Italy (816) 
France (26) 
Poland (7) 

Top 3 countries 2017 
Photo substituted ID 
Italy (367) 
Greece (185) 
France (45) 

of 

IT 

ID 

the 

50% 

cards 

2017, 

around 

covering 

from  April 

41 EL, FR, and IT: This affects around 88.4 million cards. Only EL has mandatory cards from age 14 and above. 
FR  and  IT  cards  are  optional.  According  to  figures  from  the  IT  authorities  549  IT  communes  will  deliver 
electronic 
population 
(http://servizidemografici.interno.it/it/cie/informazioni). 
42 AT, EL, FR, IT, PL, RO, and SI 
43 AT, EE, EL, FI, FR, HR, IT (applies to paper cards), MT, PL, RO, SI, SK. BG is excluded from this list as it 
should deliver contactless ID cards with biometrics from 2018. 
44  It  is  recognised  in  the  current  travel  document  standards  that  the  only  method  of  relating  the  person 
irrevocably  to  his  travel  document  is  to  have  a  physiological  characteristic,  i.e.  a  biometric,  of  that  person 
associated  with  his  travel  document  in  a  tamper-proof  manner.  Following  five-year  investigation  into  the 
operational  needs  for  a biometric  identifier  which balances  effectiveness  to  achieve  this identification  purpose 
with  practicality  privacy  laws,  ICAO  specified  that  facial  recognition  become  the  globally  interoperable 
biometric technology, accessed contactlessly, with fingerprints or iris recognitions as options in support. 
45 Only 12 Member States issue residence documents for TCN family members which adapt the uniform format 
(including  biometric  identifiers)  of  residence  permits  for  TCNs  (Council  regulation  (EC)  No  1030/2002  as 
amended by Council Regulation (EC) No 380/2008). 
46 The exception are random checks conducted on intra-Schengen flights  

12 

 
 
                                                 
In its 2017 annual risk analysis, FRONTEX underlined that EU Member States’ ID cards with 
fewer security features were facing a higher risk of document fraud, in particular those issued 
by  Italy,  Greece,  Romania  and  Bulgaria.  Less  secure  travel  documents  can  be  more  easily 
forged and so are more vulnerable than well-secured ones”47. 

In  its  analysis  FRONTEX  specified  that  Italian  ID  cards  are  the  most  reported  fraudulent 
documents,  especially  counterfeited  and  stolen  blanks  Italian  ID  cards.  The  impostor 
phenomenon  recorded  9%  increase  and  remained  the  second  most  reported  fraud  type  in 
2017. 

There  is  a  4%  decrease  on  the  external  EU  borders,  while  there  is  a  9%  increase  on  intra-
EU/Schengen  movements.  Top  nationalities  using  fraudulent  documents  are  Ukrainians, 
Moroccans,  Albanians  and  Iranians,  while  fraudulent  EU  documents,  in  particular  ID  cards 
were  the  most  commonly  used.  Air  routes  accounted  for  74%  of  all  detections,  while  UK 
(38%), Germany (13%) and Ireland (12%) are the most affected points of destinations. 

By type of fraud the trend depicts 71% on document fraud versus 29% on identity fraud. In 
the  later,  72%  are  impostors  and  28%  are  fraudulently  obtained  genuine  documents. 
Counterfeits  represent  53%  of  the  document  fraud  and  are  more  frequent  on  less  secure 
documents.  

According to FRONTEX while at the external borders passports are slightly on the lead, on 
the  intra-EU/Schengen  movements  the  ID  cards  are  by  far  the  most  fraudulently  document 
used.   

The precise cost of fraud is difficult to estimate but the costs to citizens who are victims of 
identity theft48, and/or their insurers can be considerable, especially when their ID is used to 
make purchases or carry out monetary transactions. 0.8 M individuals in the EU are affected 
by  identity  theft  (0.2%  of  the  EU’s  population)  with  an  average  individual  loss  of  around 
EUR 250 or EUR 2bn at the EU level.49 ID documents account around 16% of all types of ID 
thefts50, and the average time victims spend trying to resolve each incident of ID abuse theft is 
up  to  12  hours  and  the  average  out-of-pocket  cost  to  victim  to  resolve  each  identity  theft 
abuse is estimated EUR 354.51 

In  order  to  ensure  a  high  level  of  border  control,  access  to  sensitive  security  relevant 
document data such as fingerprints, is required. Keys to read this data need to be exchanged 

47  At  the  same  time,  the  agency  underlined  that  it  may  be  easier  for  border  authorities  to  detect  less  secure 
documents than well secured ones.  
48  OECD  considers  that  there  is  identity  theft  “when  a  party  acquires,  transfers,  possesses  or  uses  personal 
information of a natural or legal person in an unauthorised manner with the intent to commit, or in connection 
with, fraud or other crimes”. It not includes identity documents but also logins, passwords, bank account details 
and credit card numbers. 
49  Study  for  an  Impact  Assessment  on  a  Proposal  for  a  New  Legal  Framework  on  Identity  Theft,  European 
Commission (2012), Centre for Strategy and evaluation services 
50 US figures: Federal Trade Commission, https://www.iii.org/fact-statistic/facts-statistics-identity-theft-and-
cybercrime#Identity%20theft%20and%20fraud%20complaints 
51  Center  of  Identity  of  the  University  of  Texas  at  Austin  estimate.  “Public  authorities  can  also  be  victims  of 
identity theft when their means of identification are used by someone else. This could be done via illegal access 
to data bases, the forgery of official documents etc. Similar to businesses, public authorities are also used as a 
source  of 
including  staff  and  clients”; 
https://identity.utexas.edu/mitigating-the-impact-of-identity-theft-on-the-economy 

to  access  personal  data  of  data  subjects, 

information 

13 

 
 
                                                 
among Member States on a bilateral basis. However, the keys to access data change over time 
and they are not always communicated immediately to the relevant national authorities.  

Member States do not cooperate enough in other areas affecting the swift authentication of ID 
and  residence  documents.  For  example,  the  Council  has  established  two  web  registries  on 
documents  issued  by  Member  States52,  but  many  ID  cards  and  residence  documents  are 
missing in practice because Member State authorities do not always update them in practice.  

Consequences 

-  Since  the  authenticity  of  documents  needs  to  be  checked  carefully,  border  checks  can  take  longer 
when documents lack up-to-date format and security features. For instance, while Directive 2004/38 
provides  that  EU  citizens  can  travel  between  Member  States  on  the  basis  of  their  ID  cards,  Italian 
citizens reported being advised by UK border officials to apply for a passport if they want to enter the 
UK  the  next  time  as  the  Italian  ID  card  was  “just  a  piece  of  paper”,53  thus  being  confronted  with 
obstacles  to  their  free  movement.  In  turn,  paper  documents  make  it  more  challenging  to  identify 
whether the person is the rightful holder. 

-  Even  though  Member  States  are  supposed  to  exchange  information  about  all  the  documents  they 
issue,  including  valid  ID  cards,54  this  is  often  not  done.55  In  the  Czech  Republic,  10  valid  ID  card 
versions have accumulated over time and never been phased out. The information shared about them is 
incomplete, which does not assist easy authentication of documents, which leads both to obstacles to 
free movement and to security risks.  

- In France and Spain, security gaps have been identified by imposters using genuine ID documents, a 
much larger problem than counterfeited documents. In France, these are often African migrants who 
speak French fluently, pretend to be French nationals or residents.  

- In Poland, human traffickers often help Ukrainian citizens enter Poland, obtain a Polish ID and use 
that to travel to the UK. Swedish police officers confirmed problems with imposters, stating that it is 
increasingly  difficult  to  detect  cases  where  persons  use  genuine  documents  belonging  to  another, 
similar-looking person, i.e. confusing the ‘life image’ and the image on the document. Biometric data, 
such as fingerprints and facial image, are important to stop this.  

2.1.3.  Complexity  of  issuance  and  administration  of  ID  and  residence 

documents 

Apart  from  the  legally  incorrect  application  of  the  free  movement  acquis  by  Member  State 
administrations  which  is  not  the  subject  of  this  initiative56,  problems  arise  for  EU  citizens 
regarding the issuance and administrative handling of ID cards and residence documents.  

For example, currently not all Member States offer their citizens the opportunity to request ID 
cards outside their country57. As a consequence, EU citizens need to travel back to their home 

52  One  public,  PRADO  (Public  Register  of  Travel  and  Identity  Documents),  and  another  restricted  to  the 
competent administrations, FADO (False and Authentic Documents Online) 
53 Experience of Italian nationals travelling to Heathrow airport reported in the CSES study. Reticence of UK 
border guards also reported in the public consultation. 
54 Joint Action of 3 December 1998 adopted by the Council on the basis of Art. K.3 of the Treaty on European 
Union concerning the setting up of a European Image Archiving System (FADO) (OJ L 333; 9.12.1998, p.4) 
55 See section 4.4 of the Commission’s Action Plan on travel document fraud, mentioned above. 
56  SOLVIT  intervenes  when  national  authorities  apply  EU  law  incorrectly  and  cause  problems  to  mobile  EU 
citizens. 25% of the cases handled by SOLVIT in 2017 refer to problems related to free movement of persons 
and  the  right to  reside. Very  often  these problems  are  linked  to visa-free  denials  and  residence documents  for 
family members of EU mobile citizens. 

14 

 
 
                                                 
country to request ID cards, resulting in considerably higher costs. Summing up the number 
of  expatriates  from  those  seven  countries  suggests  that  approximately  4.6  M  people  are 
affected  by  this.58  Most  Member  States  also  charge  either  shipping  costs  or  a  considerably 
higher fee when documents are requested from abroad.59 

The  typical  timeframe  for  obtaining  registration  certificates  varies  between  Member  States. 
Six  EU  countries  usually  issues  registration  certificates  quickly  following  a  successful 
application.60 However, EU citizens can face delays and excessive formalities when applying 
in other countries. Examples of this have been reported in BE, DE61, ES, IE62, SE63, and UK. 
Although documents are more likely to be issued more quickly if citizens are able to apply for 
ID and residence documentation online, very few Member States64 do this. 

Consequences 

Delays  can  cause  applicants  significant  inconvenience  if  they  are  obliged  to  wait  weeks  or  even 
months to obtain a registration certificate. An example from the YEA database concerns a Bulgarian 
national who moved to Belgium: “[the Bulgarian national] was told that this procedure [to obtain the 
registration  certificate]  may  last  2  months.  Moreover,  his  bank  is  asking  him  [for]  this  registration 
certificate to enable him to operate with his bank account where he is paid, and his boss also requires 
him this document.” 

In  Spain  the  procedure  for  obtaining  a  residence  document  requires  three  separate  visits  to  the 
immigration  office  before  family  members  can  obtain  a  card.  The  family  member  requests  an 
appointment at the first visit. Once a letter with an appointment is received, s/he must make a second 
visit  to  provide  fingerprints,  signature,  photo  and  pay  a  fee.  At  the  third  visit,  s/he  collects  the  card 
(this can be done by a proxy). An NGO65 representative underlined that the abovementioned process 
can be expensive for applicants. This is especially the case if they do not live in a regional capital and 
need  to  travel  an  hour  or more  to  visit  the  immigration  office,  which  also  entails  a  potential  cost  in 
terms of lost working days. For further details see Annex 6 – section 3. 

2.2.  How will the problem evolve? 

It  is  assumed  that  some  aspects  of  the  problems  identified  will  improve  slightly  with  time 
because  Member  States  will  gradually  upgrade  their  documents.  For  instance  Bulgaria  has 
announced to introduce new ID cards in 2018. Belgium will add mandatory fingerprints to the 
national ID cards by 2019. Greece has started a tendering process to replace its current paper 

57 Croatia, Czech Republic, Finland, Hungary, Malta, Romania, Spain do not. 
58http://ec.europa.eu/eurostat/statistics-explained/index.php/Migration_and_migrant_population_statistics 
(Numbers used for the calculation is based on Figure 6.)  
59 Only in 6 countries no extra fees are charged (BE, BG, CY, FR, IT, PL). 
60 CY, ES, HU, LU, PL and PT. Article 8(2) Directive 2004/38/EC provides: “The deadline for registration may 
not  be  less  than  three  months  from  the  date  of  arrival.  A  registration  certificate  shall  be  issued  immediately, 
stating the name and address of the person registering and the date of the registration. Failure to comply with 
the  registration  requirement may  render  the  person  concerned  liable  to  proportionate  and non-discriminatory 
sanctions.”  
61 YEA, Quarterly Feedback report July-September 2015. 
62 YEA, Quarterly Feedback report October-December 2015. 
63 YEA, Quarterly Feedback report October-December 2014.  
64 Application can be done online in Finland and in the United-Kingdom, and the applicant has then to go to the 
administration to get the document. 
65 Centro de Investigaciones en Derechos Humanos (CIDH) PRO IGUAL. 

15 

 
 
                                                                                                                                                         
ID cards. Moreover, EL, IE, PT and RO have recently established the uniform format for their 
TCN  FAM  residence  documents  (see  Annex  5,  Tables  2.2  and  2.3  for  a  more  detailed 
overview about the state of play).  

Such  improvements  are  more  likely  to  address  the  problems  of  non-acceptance  based  on 
appearance  because  it  may  be  sufficient  to  issue  documents  with  a  more  modern  "look  and 
feel"  to  make  documents  more  acceptable  to  private  or  public  services,  whereas  to  actually 
tackle  the  problem  of  document  fraud  more  ambitious  changes  would  be  needed  with 
substantial inclusion of security features (including biometrics).  

It  is  clear  that  Member  States  have  not  consistently  converged  on  such  improvements,  as 
while  a number have recently updated the appearance of their ID cards, they have not  been 
consistent  in  the  security  features  that  they  have  introduced,  and  some  have  not  introduced 
biometrics,  for  instance.66  Moreover,  as  the  general  security  level  is  shaped  by  the  weakest 
link, a single country issuing weak documents remains sufficient to undermine the overall EU 
security.  For  instance,  an  unsecure  Italian  ID  card  could  be  misused  to  enter  Germany  by 
plane. 

Since there is e a clear upward trend as regards mobility and travel, it is also likely that any 
gains  through  unilateral  upgrades  will  be  outweighed  by  the  absolute  increase  in  fraud 
expected through this development.  

Table: Mobility figures 

Mobility area 

Period 

Increase/Decrease/Totals 

Mobile EU citizens (taking residence) 

Workers67 
Retired69 
Students70 (Erasmus +) 

Travel (all reasons)72 
Border crossings (EU/EEA/CH citizens only, 
entering and leaving Schengen zone)73  

2014-2015 
2015 
2015-2016 
Travel 
2014-2015 
2020-202574 

+5.3% (2014: 11.1 million68, 2015: 11.3 million) 
(2015: 1.4 million) 
+15.4% (2015: 628 000,712016: 725 000 movers) 

-0.9% (2014: 1.17 billion, 2015: 1.16 billion trips) 
+4.2% (2025: 586 million crossings total (417 air; 
112 land; 57 sea)) 

In 2015 residents (aged 15 and above) from within the EU28 made an estimated 1.2 billion 
trips for personal or business purposes which crossed an internal or external EU border.75 As 

66 E.g. CZ, FI? And PL have not introduced biometrics in their recently issued ID cards. 
67 Ibid 
68 2015 Annual Report on Labour Mobility http://ec.europa.eu/social/BlobServlet?docId=15881&langId=en. 
69 2016 Annual Report on intra-EU Labour Mobility. 
70 Erasmus+ Annual report 2016  
https://ec.europa.eu/programmes/erasmus-plus/sites/erasmusplus2/files/annual_report_2016.pdf 
71 Erasmus+ Annual Report 2015 
https://ec.europa.eu/programmes/erasmus-plus/sites/erasmusplus/files/erasmus-plus-annual-report-2015.pdf 
72  Tables  on  cross  border 
explained/index.php/Tourism_statistics 
73 Technical Study on Smart Borders (October 2014):  
https://ec.europa.eu/home-affairs/sites/homeaffairs/files/what-we-do/policies/borders-and-visas/smart-
borders/docs/smart_borders_executive_summary_en.pdf. 
74 Figures derived by extrapolation based on stakeholder consultation for Technical Study. 
75 http://ec.europa.eu/eurostat/statistics-explained/index.php/Tourism_statistics 

trips  of  EU  citizens  (all  reasons)  http://ec.europa.eu/eurostat/statistics-

16 

 
 
                                                 
the volume of EU travel continues to rise, the pressure on the external border and on checks 
within the territory will also continue to grow.  

Simultaneously, the number of EU citizens working or studying in a Member State other than 
that of their nationality is also steadily increasing. In 2015 around 11.3 million EU28 citizens 
were working in a Member State other than their country of citizenship. This is an increase of 
5.3% on 201476.  
Intra-EU mobility reached an annual growth rate of over 5% in recent years77 and this trend is 
expected  to  continue.  It  is  estimated  that  up  to  19.6  million  citizens  could  be  affected  by 
problems  related  to  residence  in  another  Member  State  in  the  three  years  up  to  201978. 
Furthermore,  due  to  a  high  number  of  citizens  travelling  in the  EU,  many  citizens could  be 
affected  by  problems  in  relation  to  ID  cards  when  travelling  from  one  Member  State  to 
another, or when they reside outside their home country.79 

Public authorities and private service providers such as banks or airlines will continue to have 
to handle a large and evolving variety of ID and residence documents presented to them by 
EU  citizens,  which  requires  continuous  training  as  an  ongoing  cost.  Even  if  mutual 
understanding  regarding  currently  validly  circulating  documents  improves  the  cost  of 
maintaining awareness of diverse and probably further diverging documents will remain.  

The  missing  and  inconsistent  security  features  in  documents  will  continue  to  raise  security 
and  border  management  related  issues.  Even  if  it  is  assumed  that  Member  States  will 
incrementally adapt to new technology when issuing such documents and gradually improve 
the  security  of  ID  and  residence  documents,  the  remaining  inconsistency  of  identity  and 
residence  documents,  the  lack  of  simultaneous  and  coordinated  action  and  the  lack  of 
consistent  and  timely  communication,  will  make  the  overall  problems  with  acceptance  and 
verification persist.  
Although the number of fraud detections fluctuates instead of showing a clear upward trend80, 
it  can  still  be  expected  that  pressure  on  border  control  officials  will  be  higher  in  the 
foreseeable  future  due  to  the  upward  trend  in  the  number  of  journeys,  increased  security 
concerns,  increased  requirements  for  document  controls  and  the  general  pressure  on 
maintaining efficiency while keeping costs down.  

The legitimacy of the principle of free movement will continue to be undermined by its abuse 
by  counterfeiters  and  fraudsters.  Action in  relation  to  ID  cards  is  particularly  urgent  from  a 
security perspective as otherwise the situation is likely to deteriorate81.  

on 

See 

Report 

2016  Annual 

76  2016  Annual  Report  on  intra-EU  Labour  Mobility,  Elena  Fries-Tersch,  Tugce  Tugran  and  Harriet  Bradley, 
Second edition May 2017, ISSN: 2529-3281 http://ec.europa.eu/social/BlobServlet?docId=17165&langId=en. 
77 
intra-EU 
http://ec.europa.eu/social/BlobServlet?docId=17165&langId=en  
78 CSES study 
79 CSES study 
80 It should be noted though that detected fraudulent documents cannot be equalised with the actual number of 
fraudulent documents since obviously not every fraudulent document will be detected. The figures can therefore 
only be used as proxy indicator.  
81 According to these data, the number of detected fraudulent ID cards has increased from 6 500 in 2013 to 9 226 
in 2015, and the number of such residence documents decreased from 3 073 in 2013 to 2 320 in 2015. 

Labour  Mobility 

issued  May 

2017 

17 

 
 
                                                 
As  a  result,  while  there  is  an  increasing  need  to  use  identity  and  residence  documents  and, 
security  gaps  notwithstanding,  the  considerable  resultant  difficulties  in  exercising  free 
movement rights will remain or increase.  

3  WHY SHOULD THE EU ACT? 

3.1.  Legal basis  

The  Treaties  provide  for  the  necessary  legal  basis  for  the  initiative.  Article  20  TFEU  (Part 
Two  of  TFEU  on  non-discrimination  and  citizenship  of  the  Union)  establishes  Union 
citizenship  and  Article  21  TFEU  refers  to  the  right  to  move  and  reside  freely  within  the 
territory of the Member States. Article 21 provides for the possibility for the Union to act and 
adopt  provisions  with  a  view  to  facilitating  the  right  to  move  and  reside  freely  within  the 
territory  of  the  Member  States  if  action  to  attain  this  objective  is  necessary  to  facilitate  the 
exercise of this right. The ordinary legislative procedure applies. 

Article 77 (3) TFEU (in Part Three, Title V of the TFEU on an area of freedom, security and 
justice) participates to the policies on border checks, asylum and migration and provides that 
the Council may adopt  provisions concerning  passports, identity cards, residence  permits or 
any  other  such  document  if  action  by  the  Union  should  prove  necessary  to  facilitate  the 
exercise of the right to move and reside freely (Article 20(2)(a) TFEU) if the Treaties have 
not provided the necessary powers. In such cases a special legislative procedure applies: the 
Council shall act unanimously after consulting the European Parliament. The UK and Ireland 
have  a  flexible  opt-out  from  the  legislation  adopted  in  the  area  of  freedom,  security  and 
justice,82 and Denmark does not take part in the adoption of measures pursuant to this Title83.  

3.2. 

Subsidiarity: Necessity of EU action 

Individual Member States have been using their scope for initiatives to improve security and 
support the right to free movement in relation to ID and residence documents. For example, 
some Member States have established web registries allowing both public and private sector 
entities to check the authenticity of documents. However, a common approach to enhancing 
the security features of documents and establishing the data that documents should provide as 
a minimum is still missing and results in continuing problems across Member States and an 
open door to document fraud.  

If  measures  are  not  taken  consistently  they  will  result  in  even  more  problems  for  European 
citizens,  national  authorities  and  businesses.  National  measures  are  subject  to  the  obvious 
limitation  that  their  direct  benefits  are  largely  or  exclusively  confined  to  a  single  Member 
State  (or  several  Member  States  in  case  of  data  exchange  and  other  forms  of  cooperation), 
whereas  addressing  systemic  problems  in  relation  to  free  movement  clearly  requires  action 
with an EU-wide dimension.  

There are also real obstacles to free movement (e.g. no acceptance of the visa exemption for 
TCN family members), a lack of awareness with respect to ID and residence documentation 
(e.g.  no  awareness  that  residence  documents  are  not  travel  documents),  and  administrative 

82 Protocol (No21) on the position of the United Kingdom and Ireland in respect of the Area of freedom, security 
and justice. 
83 Treaty of Amsterdam, Protocol on the position of Denmark. 

18 

 
 
                                                 
delays in respect of ID and residence documentation (e.g. a long waiting time after submitting 
an application and before receiving registration certificates).  

Border control authorities and private sector entities are often ill-informed about specific ID 
and residence requirements, while databases are not updated and the exchange of information 
does  not  take  place  regularly.  The  national  authorities  or  private  sector  services  lack 
information about ID cards and residence requirements elsewhere in the EU.  

Relying on uncoordinated national initiatives is likely to entail a lack of focus on improving 
the sharing of information and practical cooperation between EU Member States.  

Member  States  cannot  improve  the  current  situation  by  acting  alone,  since  the  underlying 
problem  is  that  cross-border  acceptance  and  verification  of  ID  and  residence  documents  is 
hampered due to the problem drivers and root causes described in section 2.1. There is a high 
likelihood  that  such  problems  will  persist.  Economic  discrepancies  in  Europe,  and  citizens’ 
increased  mobility,  knowledge  of  foreign  languages  and  ease  of  travel  across  Europe  drive 
citizens to use their ID and residence documents to exercise their rights. 

Since  the  unanimously  adopted  Council  Conclusions  from  2005,  where  Member  States 
unanimously  agreed  to  work  together  to  establish  minimum  security  standards  for  national 
identity  cards,  including  inter  alia  “to  use  as  a  starting  point  the  technical  specifications 
established  for  the  integration  of  biometrics  in  the  passport  in  accordance  with  Regulation 
(EC)  2252/2004”84,  there  have  been  a  number  of  political  agreements  and  repeated  calls  to 
improve  the  security  of  identity  and  residence  documents.  Only  recently  another  set  of 
Council Conclusions have been adopted that underpin the same issue.85  

The  Commission  itself  has  made  successive  calls  for  such  action,  including  in  its 
Communication  on  Security  and  mobility86  in  2016,  not  to  mention  its  Action  Plan  on 
document security of December 201687. 

Despite  some  progress  having  been  achieved,  a  considerable  number  of  countries  still  issue 
weak documents (13 Member States use no biometrics for their ID cards and at least 16 do not 
use the uniform format including biometrics for their family member residence documents).  

It  is  therefore  unlikely  that  any  further  non-binding  guidelines,  political  agreements  or 
recommendations  (either  from  the  Council  or  the  Commission)  would  achieve  sufficient 
progress and address the problems within an acceptable time frame. 

Stakeholder views:  
While  the  Council  Conclusions  of  201788  (and  with  them  the  security  and  border  protection 
community) stress the need to reinforce document security, within the free movement community 15 
out of 19 Member States, agreed that common security features and a certain or partial harmonisation 

84 http://europa.eu/rapid/press-release_PRES-05-296_en.pdf  
85 See p 5 footnote 14. Council Conclusions on the Commission Action plan to strengthen the European response 
to 
travel  document  fraud  adopted  on  27  March  2017  http://www.consilium.europa.eu/en/press/press-
releases/2017/03/27/jha-traveldocument-fraud. Council Conclusion on the EU Citizenship Report 2017 adopted 
on 11 May 2017 http://data.consilium.europa.eu/doc/document/ST-9080-2017-INIT/en/pdf  
86 COM(2016) 602 final 
87 COM(2016) 790 final 
88 See FN 28 

19 

 
 
                                                 
are required for ID cards. 15 out of 17 Member States also support this for residence documents, and 
in particular for TCN FAM residence cards. 89  

Some  Member  States  authorities  in  the  field  of  free  movement  did  not  express  any  preferences  for 
action (e.g. in BE, SE) or favoured the status quo (e.g. authorities in AT, PL) as they did not feel that 
there are serious obstacles to free movement due to the diversity of ID and residence documentation. 
Some of them were not aware of any of their citizens experiencing problems in other Member States, 
and  several  others  argued  that  the  EU  should  not  intervene  on  ID  cards,  as  it  is  a  national  identity 
issue. 
Over  two  thirds  of  the  EU  citizens  who  responded  to  the  open  public  consultation90  were  for  an  ID 
card  harmonised  at  EU  level,  and  a  huge  majority  (almost  9  out  of  10)  of  those  with  experience  of 
residence documents saw the advantages of EU harmonisation. 

3.3. 

Subsidiarity: Added value of EU action 

EU  action  can  add  considerable  value  in  addressing  the  challenges  mentioned  above.  The 
current situation affects the security within the EU and at its borders and the opportunity for 
EU  citizens  fully  to  enjoy  their  free  movement  rights.  External  borders  and  the  European 
Union as a whole have been placed under considerable strain lately. Ongoing challenges have 
underlined the inextricable link between free movement of persons inside the EU and robust 
external  border  management.  Measures  to  enhance  security  checks  on  persons  entering  the 
EU  and  to  improve  external  border  management  are  weakened  if  the  main  instrument  for 
identifying citizens is problematic even within a national context. 

Looking  at  the  ‘weakest  link’,  it  is  essential  that  all  Member  States  comply  with  minimum 
standards as regards ID and residence document security and features in order to maintain an 
adequate level of security within the EU and its borders.  

The  issuance,  handling  and  administration  of  ID  and  residence  documents  are  a  national 
matter. Nevertheless, good administrative practices around the issuance of documents should 
be effectively communicated across the EU and properly trained at EU level.  

As a result, the objectives of any initiative to remedy this situation could not be achieved at a 
national level and there is a strong argument for EU action. Even if the documents originate 
from a national competence (notably ID cards), they all have an intrinsic European dimension 
because of their interconnection with the exercise of free movement. 

4  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

The objectives of this EU policy initiative are to: 

 
 

improve security within the EU and at its borders, and 
facilitate and promote the EU citizens’ and their family members’ right to move 
and reside freely within the EU.  

Such  goals  complement  and  reinforce  each  other,  as  security  and  free  movement  are 
inherently  linked.  The  abolition  of  internal  border  controls  in  the  Schengen  Area  relies  on 
authorities  in  the  Member  States  following  certain  minimum  standards  with  regard  to 
document and border security.  

89 Consultation in the context of the CSES study 
90 See Annex 2, section 4, results of open public consultation 

20 

 
 
                                                 
The  specific  objectives  of  the  initiative  are  to  reduce  document  fraud,  to  improve  the 
acceptance  and  authentication  of  the  ID  and  residence  documents  and  improve  the 
identification of people based on them, in answer to the problems detailed in section 2.1. In 
particular document fraud (see section 2.1.2) is aggravated by the wide variety of documents 
and their lack of security features. 

Another specific objective is to raise awareness among citizens, national authorities and the 
private sector about the documents issued, and the right to free movement linked to them. 

A cross-cutting overall goal is to simplify daily life for EU citizens, cut red tape and lower 
costs both for citizens and private and public entities, by reducing administrative barriers 
for citizens and their family members related to the use of ID cards and residence documents, 
in the exercise of their rights, as well as in the issuance and administrative processes related to 
the  documents.  For  example,  citizens  and  their  family  members  are  often  unable  to  access 
certain services with their ID and residence documents due to the national authority or private 
sector actor’s non-acceptance of those documents. They are at once faced with administrative 
delays and hurdles when requesting documents. This results in costs and barriers for them.  

The  various  policy  options  analysed  here  intend  to  achieve  these  objectives  and  tackle  the 
problems  identified  in  section  2.1  and  the  individuals  concerned  by  this  initiative  are  EU 
citizens and their family members. 

5  WHAT ARE THE AVAILABLE POLICY OPTIONS? 
Currently there is no significant91 hard or soft law at EU level as regards format, security or 
process related issues for ID cards and residence documents issued to EU citizens and their 
family  members.92  It  is  therefore  neither  necessary  nor  possible  to  include  an  option  in  this 
assessment which could aim to do less or simplify an existing EU framework. 
293 out of 28 Member States do not issue ID cards (Denmark and the United Kingdom). Their 
citizens  travel  in  the  EU  with  their  passports  which  already  include  security  features  and 
therefore  do  not  pose  the  security  risks  under  discussion.  Six  Member  States  do  not  issue 
registration  certificates  for  EU  mobile  citizens.  Nationals  of  those  Member  States  could 
encounter  occasional  problems  when  exercising  their  free  movement  rights  without  these 
documents.  However,  requiring  these  Member  States  to  introduce  or  reintroduce  such 
documents  would  place  a  substantial  administrative  burden  both  on  citizens  and  on  the 
authorities,  for  modest  benefit  to  a  limited  group  of  citizens.  As  a  consequence,  this  is 
excluded from all the policy options considered.94  

There  is  no  evidence  to  support  the  case  for  optional  harmonisation  in  this  context,  as  this 
would not tackle the problems arising from the current diversity of documents. Member States 
might not feel sufficiently encouraged to adopt the necessary changes on an optional basis.  

91 The Council Conclusions on common minimum security standards for national identity cards (1-2 December 
2005) were not properly followed up. 
92  With  the  exception  of  TCN  family  member  residence  cards  for  which  the  uniform  format  as  laid  out  in 
Council Regulation (EC) No 1030/2002 (as amended by Council Regulation (EC) No 380/2008 and is optional.  
93 Ireland’s passport card qualifies as ID card in function according to Art. 4 and 5 of Directive 2004/38/EC. 
94  Any  non-compliance  with  the  legal  requirement  to  produce  specific  residence  documents  pursuant  to  the 
provisions  of  Directive  2004/38/EC  is  not  subject  of  this  initiative  but  a  matter  of  the  usual  monitoring  and 
infringement procedures. 

21 

 
 
                                                 
The intervention logic with a view to the policy options chosen is presented in Figure 5.1. 

5.1.  What if there is no EU action? 

The  baseline  scenarios  for  the  format  and  security  issues  for  ID  cards  and  residence 
documentation,  and  for  the  process  related  issues  are  to  maintain  the  status  quo.  Three 
baselines are therefore considered. 

At baseline, the situation remains unchanged. Pressure at external borders will increase, and 
more persons are going to try to irregularly enter the EU and want to exercise free movement 
by  means  of  document  fraud95  (see  also  section  2.2).  ID  cards  and  residence  documents 
continue to be regulated differently across EU Member States. Based on the experience of the 
Council Conclusion of 200596, voluntary alignment is not happening or does so at such a slow 
a pace that it constitutes a security risk within the EU. 

There  is  no  evidence  that  there  will  be  swift  convergence  regarding  the  choice  of  substrate 
(paper,  laminated  paper,  plastic)  and  format  (ID-1,  ID-2,  A4  paper  document),  and  security 
features will still vary providing an opportunity for forgers to target the documents of those 
countries  where  the  standards  are  relatively  low.97  Currently,  only  2  out  of  13  Member 
States98 issuing ID cards not compliant with ICAO Doc 9303 plan to upgrade their ID cards’ 
design in the near future. 

Member  States'  policies  towards  harmonisation  will  still  show  discrepancies  between  EU 
Member States as policies will continue to be uneven and asymmetrical. For instance, the DE 
authorities  recently  introduced  e-gates  at  airports,  but  due  to  lacking  interoperability,  the  e-
gates can only be used with DE national ID cards. Moreover, differences will be kept among 
Member States with regard to the use of ID cards to access public and private sector services.  

Under  the  “no  policy  change”  scenario,  some  measures  for  residence  documents  are  also 
already  underway,  e.g.  DE  and  ES  both  recently  abolished  residence  cards  for  EU  citizens, 
but  there  is  no  coordination  whatsoever  of  these  policies.  Cross-border  use  of  electronic 
identity  (eID)  functions  was  boosted  by  EU  legislation  (eIDAS  Regulation).99  Nevertheless 
the development of an eID infrastructure is technically challenging and expensive, and a lot of 
Member States are still quite slow in introducing national ID cards with eID function100. If the 
status  quo  is  maintained,  this  could  lead  to  continued  uncertainty  among  citizens  as  to 
whether they can use eID features with their cards in other Member States. 

95 CSES study 
96 Council doc. 14390/05 
97 For example, the FRONTEX Risk Analysis for 2016 mentions that the “number of persons aiming to get to the 
UK  with  fraudulent  documents  significantly  increased  (+70%)  compared  to  2014.  This  trend  is  mostly 
attributable to the increasing number of Albanian nationals often misusing Italian and Greek ID cards. 
98 E.g. BG is already implementing its plan and should deliver ICAO compliant ID cards from 2018. 
99 Regulation (EU) No. 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification  and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive 
1999/93/EC. 
100  Member  States  tend  to  develop  eID  features  with  restricted  use,  i.e.  only  for  their  nationals  or  with  a 
technology  allowing  only  access  to  national  administration.  Implementation  of  eIDAS  needs  a  lot  of  work  as 
regards the technologies used and exchange of information between Member States. Without encouragement to 
open the services across the national borders and to non-nationals, there should certainly be some progress but 
very slow and subject to the individual good will of Member States. 

22 

 
 
                                                 
There  are  currently  big  differences  with  regard  to  the  process-related  aspects  of  ID  and 
residence  documents,  and  these  will  remain  or  even  increase  with  the  growing  mobility  of 
citizens.101  Whereas  several  countries  already  have  online  application  systems  for  residence 
cards102,  the  administrative  inconveniences,  in  particular  the  considerable  delays  around  the 
issuance of residence documents will also remain. Furthermore, some nationals will continue 
to not be able to request an ID card when being abroad. 

101  From  the  over  20  million  visits  to  the  Your  Europe  portal  in  2017,  more  than  30%  were  to  the  travel  and 
residence formalities section. In its turn, YEA replied to more than 8 000 enquiries related to entry procedures 
and residence rights representing more than 35% of the total number of enquiries received last year. Under the 
baseline scenario EU mobile citizens and their family members will be able to still count on the information on 
EU rights published in the Your Europe portal and personalised advice from YEA. 
102 This includes EE and DK (piloting the digitalisation of application procedures for residence documents). 

23 

 
 
 
                                                 
Figure 5.1:   Intervention logic of options (ID and residence documents) 

PROBLEMS 

1. Insufficient acceptance of documents 
2. Document fraud and lack of authentication 
of documents 
3. Complexity of issuance and administration 
of documents 

DRIVERS OF THE PROBLEMS ADDRESSED 
BY THIS INITIATIVE 

and 

A.  Differences 
nomenclature,  format,  design  and 
type, 
of 
functionality and use of documents 

substrate, 

period 

inconsistency 

in 
layout, 
validity, 

B.  Failure  to  include  basic  and  advanced 
security features in documents 

C.  No  coordination  of  Member  States  on  the 
production of documents and the information 
they contain  

D. Lack of awareness of documents, the rights 
linked  to  them,  as  well  as  lack  of  training  of 
the persons checking the documents  

E.  Bureaucratic, 
lengthy  and  not  citizen-
friendly procedures regarding the issuance and 
renewal of documents 

GENERAL OBJECTIVES  

I.  Improve  security  within  the  EU 
and at its borders 

II.  Facilitate  the  citizens’  right  to 
freely move and reside in the EU 

SPECIFIC OBJECTIVES  

a) Improve acceptance of 
documents  
b) Reduce document fraud 
c) Improve authentication of 
documents 

d) Improve identification of 
persons based upon documents 

e) Raise awareness among all 
stakeholders about documents, 
rights linked to them, including 
training 

f) Simplify daily life for citizens, 
cut red tape and lower costs for 
all stakeholders 

24 

OPTIONS TO FULFILL THE OBJECTIVES OF THE 
INITIATIVE 

Policy option 0: Baseline scenario – No changes 

Policy options ID – format and security of ID cards 
ID  SOFT)  Non-legislative  measures  related  to  ID  cards 
(including on eID functionality) 
ID 1) ID SOFT + Minimum common  requirements for ID 
format and security (incl. optional eID functionality) 
ID 2) ID SOFT +1 + Common format for ID cards  
ID 3) ID SOFT + EU ID cards in addition 

Policy  options  RES  –  format  and  security  of 
residence documents 
RES SOFT) Non-legislative measures related to residence 
documents  
RES  1)  RES  SOFT  +  Harmonise  a  limited  amount  of 
residence document data 
RES  2)  RES  SOFT  +  1  +  Common  format  for  TCN  family 
member residence documents  
RES 3) RES SOFT + 1 + Common format for all residence 
documents 

Policy options – “process” 
PROCESS  SOFT)  Promote  more  and  better  options  for 
requesting and receiving documents  
PROCESS  1)  PROCESS  SOFT  +  Issue  ID  cards  through 
consular networks of all MS 

 
 
 
 
 
 
 
 
 
 
 
 
 
5.2. 

Policy Option ID – format and security of ID cards 

Option ID SOFT) Non-legislative measures related to ID cards 

The  suggested  soft  law  measures  would  be  mainly  directed  at  preparing  stakeholders  in  the 
best possible way to deal with the legislative diversity in the EU.  

Awareness  raising  measures  across  the  EU  to  inform  citizens  better  about  various 
obligations and rights in relation to their documents (e.g. through the Your Europe Portal, the 
Single Digital Gateway103 and information campaigns with target groups in frequent contact 
with mobile citizens such as universities and employers from other EU countries). 

Soft reinforcement of the authority of SOLVIT centres within their national administration in 
order to simplify the daily lives of mobile citizens in relation to residence documents. 

Capacity-building  and  training  organised  through  an  EU-wide  network.  For  example, 
training organised via FRONTEX104, CEPOL or OSCE105 for border control officials.  

Enhanced administrative cooperation can focus on engaging in best practice sharing with 
regard to detecting fraudulent documents and practices and on exchanging views about having 
the necessary equipment in place to check ID cards. 106  

With  regard  to  the  practicalities  of  enhanced  administrative  cooperation  and  the  further 
refinement  of  the  technical  standards  for  the  documents,  the  expertise  of  the  Article  6 
Committee will be of particular use107 and beneficial to discuss matters in relation to security 
features of ID cards and residence documents108. Other groups composed by Member States 
experts, such as the FREEMO expert group109 or Schengen related structures, should also be 
involved.  

103 Council document 8838/17 + ADD 1: General Approach to COM 2017) 256 final: Proposal for a Regulation 
of  the  European  Parliament  and  the  Council  on  establishing  a  single  digital  gateway  to  provide  information, 
procedures, assistance and problem solving services and amending Regulation (EU) No 1024/2012 
104 To respond to the vulnerabilities in the travel document inspection process, FRONTEX provides training for 
border  guard  officials  on  document  security.  FRONTEX  also  provides  consular  staff  training  for  visa  issuing 
staff of EU Member States in third countries (3 per year) and ‘road shows’ which are information sessions and 
one-week-trainings at airports aimed at first-line officers. At a national level, there are also training courses to 
help ensure improved border control procedures to check ID cards. . 
105 See further details in the draft report on the implementation of the Action Plan to strengthen the EU response 
to travel document fraud. 
106 FRONTEX recently launched a technical report - EXP-DOC/ TECH-DOC 1-2017- on "the legal, operational, 
and  technical  requirements  for  document  inspection  equipment  to  be  deployed  during  FRONTEX  Joint 
Operations". It takes account of the current European and international legislation/guidance and seeks to provide 
specific requirements and functionalities for equipment to be purchased by FRONTEX in the context of control 
operations. 
107 The Article 6 Committee was set up by Council Regulation (EC) No 1683/95 of 29 May 1995 laying down a 
uniform format for visas. It is a comitology committee composed of Member States representatives and chaired 
by  the  Commission,  tasked  with  establishing  the  technical  specifications  of  the  uniform  formats  for  visas  and 
residence permits for third country nationals, passports, and other documents under EU competence.  
108 Member States will be encouraged to look into the integration of features that make ID cards more accessible 
and user-friendly to people with disabilities, such as visually impairment. See also feedback from Civil Society 
Organisations during the Open Public Consultation (September-December 2017. 
109 Register number E02397 
http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2397&NewSearch
=1&NewSearch=1. 

25 

 
 
                                                 
Databases or web registries use by Member State authorities shall be fostered. For example, 
the role of FADO110 could be further developed as an information sharing tool.  

To  designate  a  structured  Points  of  Contact  network,  as  main  entry  and  exit  points  for 
information exchange in each EU Member State, to provide a route for enquiries from another 
Member State being routed through to the correct authority111. 

To  inform  citizens  about  the  usefulness  and  functioning  of  eID  functions  on  their  (ID  or 
residence)  documents  to  access  public  and  private  services,  in  particular  as  regards  the 
possibility  for  cross-border  transactions  in  the  Internal  Market  (which  are  facilitated  by  the 
eIDAS Regulation112). To exploit the full potential of cards with eID functionality across the 
EU,  the  interoperability  of  eID  infrastructure  of  the  Member  States  will  also  need  to  be 
improved.  The  respective  forums  and  working  groups  will  be  used  for  this.  Recent  policy 
developments for managing EU sector specific “identities” of citizens (e.g. social security113, 
taxation114, and student mobility115) will be taken into account. 

Option ID 1) ID SOFT) + Minimum common requirements for ID format and security  

In  addition  to  the  non-legislative  measures  under  ID  SOFT  this  option  involves  legislative 
action at EU level to promote the minimum harmonisation of ID card features. This largely 
mirrors the approach taken for passports of EU citizens.116 This will address the objective to 
improve internal security but also facilitate free movement.  

Firstly, it is required that the ID or identity card should actually be named as such (rather than 
other terms currently used in some Member States)117. Secondly, Member States shall require 
that  ID  cards  are  regularly  renewed  for  security  reasons.  A  maximum  validity  period  of  10 
years for ID cards is proposed118 (except where under national law facilitation for a specific 
age group is foreseen, i.e. senior citizens; see Annex 5, Table 2.2 for more details on validity 
regimes).  

This  option  also  includes  adopting  a  format  with  some  common  features  such  as  the 
information on the card and minimum security features taking into account ICAO Doc 9303 

110  FADO  is  the  summary  name  for  a  trio  of  information  and  technology  systems:  Expert  FADO,  iFADO 
(Intranet  FADO)  and  PRADO  (Public  Register  of  Authentic  Documents  Online).  It  is  a  European  image 
archiving system, set up on the basis of the Council Joint Action 98/700/JHA with a view to helping Member 
States  in  managing  and  identifying  authentic  and  false  documents.  Subsystem  iFADO  is  intended  for  law 
enforcement and document issuing authorities, while PRADO subsystem, available via internet, aims at the ‘non-
document-expert’ community. 
111 Responding to some extent to citizen request LtL 242 submitted to the REFIT platform. 
112 Regulation (EU) No. 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification  and  trust  services  for  electronic  transactions  in  the  internal  market  and  repealing  Directive 
1999/93/EC. 
113 The European Social Security Number aims to create a EU personal identifier for mobile persons whose data 
will be exchanged in the context of the new Electronic Exchange of Social Security Information. 
114  The  Commission has  launched  a  cooperative project whereby information  about  tax identification numbers 
that Member States choose to publish is available on a single webpage (European TIN Portal). 
115  "EU  student  card",  see  COM(2017)  673  final,  Strengthening  European  Identity  through  Education  and 
Culture, p.5. 
116 Council Regulation (EC) No 2252/2004 (OJ L 385, 29.12.2004, p.1) and Commission Implementing Decision 
C(2013) 6181. UK and IE are not part of this measure. 
117  See  IE  ‘passport  card’ or PT  ‘citizen  card’.  In  this  way border  control  officials  can  more  easily  detect  if  a 
document is an ID card and thus if it enables the holder to travel across borders. 
118 This would be in line with ICAO recommended practice set out in Chicago Convention Annex 9 (Facilitation) 
for Passports (arguments in Note 1 is also applicable for ID Cards) 

26 

 
 
                                                 
(see Annex 7, Table 5.1 for detailed list of mandatory features). Member States can however 
freely choose the colour of the ID card. Given the key objective to improve the security of ID 
cards  as  travel  documents,  a  mandatory  RFID  chip  including  biometrics  (facial  image 
mandatory, fingerprints optional) is proposed.  

The  EU  data  protection  acquis  shall  apply  to  all  aspects  of  the  ID  cards  and  adequate 
safeguards  and  protections  will  be  provided  for  citizens  in  order  to  ensure  compliance  with 
fundamental rights as provided by the Charter of Fundamental Rights of the European Union 
(“the  Charter”).    The  data  contained  in  the  chip  shall  be  described  in  a  closed  list  and  be 
protected in its integrity, authenticity, and security.  A purpose limitation should be included 
for  the  use  of  the  biometric  features  in  IDs,  such  as  that  provided  in  Art.  4  Regulation 
2252/2004: "the biometric features in passports and travel documents shall only be used for 
verifying:  a)  the  authenticity  of  the  document;  b)  the  identity  of  the  holder  by  means  of 
directly  available  comparable  features  when  the  passport  or  other  travel  documents  are 
required  to  be  produced  by  law".  Exceptions  and  safeguards  must  be  provided  for  cases 
where fingerprints are required from vulnerable persons, to ensure their rights under EU law 
and  the  Charter  of  fundamental  rights  are  upheld,  particularly  regarding  children  and 
individuals who are unable to provide fingerprints. In this sense, the same rules shall apply as 
for  passports:  "children  under  the  age  of  12  years  are  exempt  from  the  requirement  to  give 
fingerprints" (Art 1(1) para 2a (a) Regulation No 444/2009 amending Council Regulation No 
2252/2004. 

Moreover,  in  order  to  ensure  the  access  and  accuracy  of  the  data  as  provided  under  Article 
8(2)  of  the  Charter,  the  proposal  would  ensure  that  data  subjects  right  under  GDPR  fully 
apply and guarantee the data subject's right to effective remedies available to  challenge any 
decisions,  which  shall  in  any  case  include  an  effective  remedy  before  a  court  or  tribunal  in 
line  with  Article  47  of  the  Charter,  without  prejudice  to  the  rights  under  the  general  data 
protection regime. 

Optional elements can be added as required in the light of the national provisions, such as the 
address  of  the  holder, the  national emblem,  etc.  Member  States  could also  enter  details,  for 
instance numbers which are used for e-government, tax identification, personal identification 
number or social security. Member States could also incorporate a dual interface or a separate 
contact chip for additional eID functionality119. Such additional storage shall comply with ISO 
standards  and  in  no  way  interfere  with  the  RFID  chip  for  biometrics.  In  parallel  but  not 
addressed  here  (as  at  this  point  in  time  it  is  considered  premature  to  completely  replace 
physical  ID  cards  by  digital  identification  in  particular  for  travelling  throughout  Europe), 
Member States may also develop fully digital mobile phone based identification solutions.120 
Member States can also look into the integration of format features that render the ID cards 

119 In order to enable eID functionalities, cards need to be compliant with the assurance levels defined in the EU 
framework  (Art  8  eIDAS  Regulation  and  Commission  Implementing  Regulation  2015/1502),  in  particular  for 
what concerns authentication to online services. Therefore, such cards shall contain a digital certificate (pair of 
private  and  public  key)  issued  under  a  public  key  infrastructure  (PKI)  scheme.  Use  of  and  access  to  the 
certificate  shall be  protected with  a  PIN  code  known  only by  the  card  holder.  Authentication  based on digital 
certificate released under a PKI and user verification through PIN can support the assurance levels. To guarantee 
the protection it is fundamental also how the  counterpart (the service requiring for authentication) implements 
the  authentication  scheme.  To  ensure  the  validation  of  the  documents  throughout  the  EU,  certificates  must  be 
exchanged. Otherwise it will not be possible to check the authenticity of the chip data. 
120 See for instance https://e-estonia.com/solutions/e-identity/mobile-id/ 

27 

 
 
                                                 
more  accessible  and  user-friendly  to  people  with  disabilities,  such  as  visually  impaired 
persons.121  

A  requirement  will  be  introduced  to  phase  out  all  documents  currently  in  circulation  and 
which do not meet the requirements suggested under this option by a fixed deadline122.  

The  deadline  should  allow  sufficient  time  for  the  authorities  and  citizens  to  cope  with  the 
transition  to  new  documents123.  This  option  would  require  that  all  previous  non-compliant 
versions of ID cards are phased out within 10 years after entry into force of the EU measure. 
Member  States  not  producing  ID  cards  with  a  properly  functional  machine  readable  zone 
(MRZ) according to ICAO shall shorten this time period to five years in order to achieve the 
desired effects more quickly.  

Option ID 2) ID SOFT) + ID 1) + Common format for ID cards 

In addition to the measures under ID SOFT and ID 1) this option represents a more ambitious 
approach with measures to harmonise all key features of national ID cards beyond ICAO 
requirements.  

The card will bear the EU emblem and the colour will be fixed. The inclusion of fingerprints 
will be mandatory. 

The  phasing  out  of  currently  circulating  old  documents  will  follow  the  same  approach  as 
under option ID 1). 

Option ID 3) ID SOFT) + EU ID cards in addition 

In addition to the non-legislative measures an alternative legislative instrument to ID 1) and 
ID 2) can provide Member States with the option to adopt an EU identity card in addition to 
their national ID cards. This EU ID card can be specifically created to serve the purposes of 
the rights as Union citizen.124  

The  format  and  security  of  these  additional  EU  ID  cards  follow  the  completely  harmonised 
features  as  laid  out  in  option  ID  2).  The  production  of  the  cards  would  still  rely  upon  the 
Member States.  

National  ID  cards  are  not  addressed  by  this  option.  None  of  the  old  currently  circulating 
national ID cards will be required to be phased out. 

121  The  features,  inter  alia,  could  include  the  title  and  the  expiry  date  in  Braille,  indentations  to  mark  the 
orientation  or  the  use  of  a  card  material  that  avoids  easy  slipping.  See  also  feedback  from  Civil  Society 
Organisations during the Open Public Consultation (September-December 2017). 
122 This is advisable, since documents in a number of Member States do not have an expiration date or they are 
valid  for  a  long  time  period.  Not  phasing  out  documents  would  lead  to  the  problem  that  even  if  new  legal 
requirements exist, older versions of some national ID cards would still be in circulation and would undermine 
the  objective  of  introducing  minimum  common  features.  Adequate  provision  should  be  made  in  the  Member 
States to ensure that citizens face being deprived of an ID of otherwise unlimited duration are not disadvantaged 
by the phasing out. 
123 Note that the average validity period of ID cards across EU Member States is 10 years.  
124 Such as the right to free movement, the right to vote in European elections, the right to launch petitions or 
other initiatives at EU level, etc. This option has been assessed in a recent European Parliament study. May 
2016: “The Legal and Political Context for setting up a European Identity Document: 
http://www.europarl.europa.eu/RegData/etudes/STUD/2016/556957/IPOL_STU(2016)556957_EN.pdf  

28 

 
 
                                                 
5.3. 

Policy Option RES – format and security of residence documents 

A potential legislative instrument can lay down requirements for only one, some or all of the 
different residence documents (see Annex 5, Table 2.3 for more details). With the exception 
of  TCN  FAM  residence  documents  which  are  used  as  a  visa  waiver,  there  is  no  evidence 
suggesting the need to distinguish the different residence documents.  

Option RES SOFT) Non-legislative measures related to residence documents 

Soft law measures related to residence documents follow a similar path to the one under ID 
SOFT)  and  would  include  similar  activities  (Your  Europe,  Single  Digital  Gateway125, 
SOLVIT, training, enhanced administrative cooperation, FADO, etc.) and actors (FRONTEX, 
FREEMO expert group and other Member State expert groups etc.).  
Regarding residence documents, awareness-raising126 will specifically focus on: (i) residence 
requirements;  (ii)  the  procedure  for  obtaining  different  forms  of  residence  documents;  (iii) 
rights and duties in regard to residence documentation. 

Option RES 1) RES SOFT) + Harmonise a limited amount of residence document data  

This option will require some mandatory features in addition to the non-legislative measures 
under RES SOFT).  

First,  the  use  of  the  document  title  as  referred  to  in  Directive  2004/38/EC  (registration 
certificate,  document  certifying  permanent  residence,  residence  and  permanent  residence 
cards to family members of a Union citizen127). The document title in the national language 
shall be repeated in at least one other (maximum two) official languages of the institutions of 
the Union, in order to facilitate the recognition of the document.  

Second, the document number, name (surname and forenames(s)) of the holder, date of issue, 
and place of issue will be required. 

There  will  be  no  other  mandatory  requirements,  such  as  regarding  the  substrate,  format, 
printing  technique,  etc.  On  an  optional  basis,  other  features  could  be  added  (e.g.  date  and 
place of birth of the holder, nationality of the holder, sex of the holder, address of the holder, 
date/signature/issuing authority, date/signature/document holder). 

The validity of documents will not be affected by this option, because the intervention is too 
minor to justify quicker replacement of non-compliant TCN FAM cards. The replacement of 
valid  residence  documents  of  EU  citizens  could  create  legal  uncertainties  in  relation  to 
Directive 2004/38/EC, and is therefore excluded (no phasing out). 

Option  RES  2)  RES  SOFT)  +  RES  1)  +  Common  format  for  TCN  FAM  residence 
documents  

125 Measures, such as the single digital gateway (see description under ID SOFT), are designed to increase the 
knowledge  of  EU  citizens  and  their  family  members  and  help  them  to  exercise  their  free  movement  rights 
without unnecessary delays due to having the wrong information. Furthermore, the measures should help citizens 
to  uphold  their  rights  and  increase  awareness  of  their  obligations  linked  to  the  position  of  the  residence 
document.  
126 For instance, it was pointed out by consulted stakeholders that family members of EU citizens are not aware 
of the consequences of not complying with the requirement of communicating any change in their situation that 
allowed them to obtain the residence document within a maximum period of one month. 
127 To save space on documents in card format, in further technical specifications adopted by Member States the 
use of standardised codes instead of the full document title could be agreed (e.g. ‘fam.res.Art.10 Dir. 2004/38’ 
for TCN FAM residence card. 

29 

 
 
                                                 
As only TCN FAM residence documents act as visa waivers, there is a substantive argument 
that  only  these  should  be  improved.  In  addition  to  soft  law  measures  (RES  SOFT)  and  a 
harmonisation of a limited amount of residence document data (RES 1) this option therefore 
suggests harmonising TCN FAM residence documents. 

TCN FAM residence cards and permanent residence cards will draw on the specifications set 
out  in  the  ICAO  document  9303  and  use  the  common  uniform  format  for  residence 
permits128, including biometrics (both mandatory facial image and fingerprints). (See Annex 7 
Table 5.2 for a list of all mandatory and optional features.)  

As for ID cards, the collection of personal data under this option should be implemented with 
strong  fundamental  rights  checks,  guarantees  and  balances  and  ensure  full  compliance  with 
the  Charter  of  Fundamental  Rights  of  the  European  Union  and  applicable  data  protection 
legislation, including the rights of the data subject and right to effective remedy. Moreover, 
insofar  as  this  option  entails  the  mandatory  collection  of  fingerprints  relating  to  minors129, 
measures  shall  provide  for  robust  fundamental  rights  safeguards  and  protection  measures  in 
light with Article 24 of the EU Charter on Fundamental Rights130.  

The card will be made entirely of a substrate compliant with ICAO Doc 9303 (lasting for at 
least 10 years), using specific printing techniques and be a specific colour. 

Documents not compliant with any of the mandatory elements based upon the uniform format 
as stipulated by the latest legislation (Regulation (EU) No 2017/1954) should be phased out 
within 10 years. However, Member States, whose current TCN FAM residence documents do 
not even comply with the older uniform format under Council Regulation (EC) No 380/2008 
will  need  to  phase  those  documents  out  within  5  years  after  the  proposed  legislation  enters 
into force. No phasing out for residence documents issued to EU citizens. 

Option RES 3) RES SOFT) + RES 1) + Common format for all residence documents  

In  addition  to  the  requirements  under  RES  SOFT)  and  RES  1)  this  option  will  involve 
establishing a harmonised common format not only for TCN FAM cards but for all types of 
residence documentation as referred to by Directive 2004/38/EC. The harmonised format will 
be again the uniform format used for residence permits (see RES 2).  

Due to their impact on border and other security, phasing out is again required for old non-
compliant  TCN  FAM  residence  documents.  The  validity  of  existing  residence  documents 
issued to EU citizens should not be touched upon for legal reasons, even if their format will 
be  harmonised  (see  RES  1).  There  will  be  no  phasing  out  under  RES  3)  for  residence 
documents issued to EU citizens.  

5.4. 

Policy  option  PROCESS  –  process  regarding  the  issuance  of  ID  cards  and 
residence  documents,  as  well  as  Member  States  sharing  information  about 
the related processes 

Option PROCESS SOFT) Promote more and better options for requesting and receiving 
documents and improving Member States sharing information about related processes 

128 As enshrined in Council Regulation 1030/2002, lately amended by Regulation (EU) No 2017/1954. 
129  For  residence  permits  the  capture  of  fingerprints  is  compulsory  as  of  six  years  of  age  (Art  4b  Council 
regulation (EC) No. 380/2008 amending Regulation (EC) No. 1030/2002. 
130 As indicated as technically feasible in the JRC study 'Fingerprint Recognition for children''; EUR 26193 EN; 

ISBN 978-92-79-33390-3Children', 2013. 

30 

 
 
                                                 
This  option  includes  the  promotion  of  online  application  tools.131  When  promoting  such 
online  tools,  security  requirements  will  be  carefully  taken  into  account,  such  as  the  need  to 
have  at  least  one  physical  contact  with  the  applicant  when  issuing  a  ID  and  residence 
document  including  biometric  data.  Moreover,  state-of-the-art  safeguards  regarding  data 
security and protection need to be respected.  

Moreover  under  this  option,  Member  States  should  step  up  the  sharing  of  information  and 
views  on  issues  they  all  face  relating  to  the  production,  issuing  and  use  of  ID  cards  and 
residence  documents.  Furthermore,  experiences  regard  the  abolition  of  certain  types  of 
documents can be exchanged (e.g. Member States stopping the production of residence cards 
for  EU  citizens  and  the  phasing  out  of  old  versions  of  ID  cards).  The  listed  EU-wide  fora, 
such  as  the  FREEMO  expert  group  (see  also  ID  SOFT  and  RES  SOFT)  will  also  be  better 
used to exchange Member States experiences in this regard.  

Option PROCESS 1) PROCESS SOFT) + Issue ID cards through consular networks of 
all Member States 

A  potentially  effective  solution  to  mobile  EU  citizens’  problem  of  renewing  ID  cards  is  to 
issue ID cards through the consular network.  

In  addition  to  the  soft  law  under  PROCESS  SOFT,  PROCESS  1)  will  thus  require  the 
Member  State  consular  networks  to  issue  ID  cards  to  their  mobile  citizens  on  a  mandatory 
basis. This will be linked to the requirement not to charge citizens more for this service than 
the  costs  in  the  home  country  for  requesting  ID  cards  (except  for  the  additional  shipping 
costs). 

6  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This  section  explains  the  impacts  of  the  given  set  of  policy  options  described  above  in 
comparison with the dynamic baseline scenario (see also section 2.2 and 5.1). Actions and 
measures  on  ID  cards  and  residence  documents  tackle  different  "instruments"  (types  of 
documents with different functions, uses and legal value) and cannot be compared with each 
other. Equally, process related issues cannot be compared with format related issues. Hence, 
impacts  of  each 
there  are  no  relevant 
"instrument/measure" for (a) ID cards, (b) residence documents and (c) process-related issues 
are therefore discussed and assessed separately. 

interdependencies  between 

them  and 

the 

The  impact  assessment  attends  particularly  to  potential  impacts  on  three  groups:  citizens, 
business including small and medium sized enterprises, and public administration.  

Member  States’  authorities  and  the  private  sector  are  reluctant  to  share  data  regarding  the 
production and issuance of national documents, as well as the costs associated with the use of 
those  documents.  As  a  result,  precise  quantification  of  impacts  (in  particular  aggregate 
impacts) of the different options is hardly possible. It is however fair to assume that the costs 
of  policy  change  and  implementation  for  most  options  would  be  set  off  by  the reduction  of 
costs  to  citizens,  business  and  public  authorities.  These  costs  are,  especially  for  citizens, 
mainly  ‘hassle’  costs132,  a  very  broad  category  of  costs  that  vary  greatly  from  individual  to 
individual and as a result are even more difficult to quantify.  

131 Examples for such tools exist in Denmark, Finland, and the UK. 
132 A non-monetary effort and inconvenience a citizen incurs in ordering, maintaining, using or disposing of an 
ID card or residence document. 

31 

 
 
                                                 
Many of the implementation and operation-related costs are based on estimates of monetary 
costs  and  possible  cost  savings  for  public  administrations  and  private  service  operators.  In 
addition there could be considerable intangible gains and benefits. 

All  options  should  have  wider  economic  and  social  impacts.  It  is  safe  to  assume  that  the 
more effectively hurdles for free movement are removed the more positive these impacts will 
be. Reduced  constraints on cross-border mobility could potentially have benefits for a  quite 
wide  range  of  economic  sectors.  Whether  SMEs  are  affected  to  the  same  extent  as  larger 
companies by facilitated freedom of movement is difficult to assess. 

Rendering documents more secure will also contribute to the level of security within the EU 
and the Member States, since it would be more difficult to falsify documents and to enter the 
EU based on falsified documents. Fraud in accessing social benefits should also be reduced. 
Moreover,  this  could  also  be  a  promoter  of  social  inclusion  with  the  affected  individuals 
feeling they are treated on an equal basis to nationals of the host country and being generally 
able to access the same public and private sector services.133 

As  regards  environmental  impact,  facilitation  of  free  movement  can  increase  air  traffic, 
which  would  however  be  impossible  to  attribute  directly  to  any  option  implemented.  The 
environmental  costs  of  a  potentially  increased  plastic  card  production  (depending  on  the 
option chosen) are rather low and negligible.134  

Fundamental  rights  are  also  affected.  There  are  three  main  rights  affected  by  the  policy 
initiatives: Article 45 of the Charter of Fundamental Rights of the EU (CFEU) on freedom of 
movement, and Article 7 CFEU on the respect of private life read and Article 8 on the right to 
the protection of personal data.  

We assume that all the policy option positively affect the right of freedom of movement and 
residence. By strengthening the security of ID and residence cards and dependent services, all 
policy options aim at facilitate free movement of persons and residence, particularly for TCN.  

Additionally,  the  policy  options,  particularly  on  the  residence  cards,  present  ancillary 
benefits/impact  for  other  fundamental  rights  such  as  Articles  39  and  40  CFEU,  since  the 
exercise of political rights  would be facilitated while residing  in a Member State other than 
their country of origin. Moreover, some of the policy options will have a positive impact in 
Article  26  CFEU  (the  right  to  integration  of  persons  with  disabilities),  as  they  will  have  a 
targeted positive impact by facilitating the reading of documents. 

The processing, including collection, access and use of personal data falls under Article 8 of 
the  Charter  of  Fundamental  Rights  of  the  European  Union  because  it  constitutes  the 
processing  of  personal  data  within  the  meaning  of  that  article.135  Accordingly,  data 

133 CSES study (feedback from stakeholder consultation). 
134 http://www.icma.com/ArticleArchives/CarbonFootprint_SE2-12.pdf : For the production of a rather complex 
ID-1 card 50g CO2 equivalent is a realistic assumption. The carbon footprint of the annual global plastic card 
production for all purposes (credit cards, ID, mobile telecommunications, etc.) is estimated to be around 200 000 
tons CO2 equivalent and compares to the carbon footprint of an average US village of 5 000 inhabitants. If 10% 
of the EU ID card holders (entire EU population except for UK and DK above the age of 15 in 2016:= 372 M 
people) renew their ID card every year (which is the typical replacement rate for cards with an average validity 
of 10 years) the annual carbon footprint of the EU ID card production is around 1 860 tons CO2 equivalent and 
would therefore amount to the annual carbon footprint of an average US village of 47 inhabitants.  
135  
See  e.g.  CJEU,  Cases  C  92/09  and  C  93/09  Volker  und  Markus  Schecke  and  Eifert  EU:C:2010:662, 
paragraph 47; see, as regards Article 8 of the ECHR, Eur. Court H.R., Leander v. Sweden, 26 March 1987, § 48, 

32 

 
 
                                                 
 
protection including data security shall be implemented in light of the relevant EU acquis136. 
Options,  which  require  the  processing  of  the  personal  data  of  citizens  including  collection, 
access and use of personal data, affect the right to the protection of personal data under the 
Charter. Interference with this fundamental right must be justified, and this will be analysed 
specifically in this section.  

The  CJEU  established  the  criteria  for  justification  of  such  interference  in  the  context  of 
Regulation 2252/2004 in Case C-291/12 Schwarz v Stadt Bochum, ECLI:EU:C:2013:670. It 
recalled that limitations to Charter rights must be ‘provided for by law, respect the essence of 
those  rights,  and,  in  accordance  with  the  principle  of  proportionality,  [be]  necessary  and 
genuinely meet objectives of general interest recognised by the Union or the need to protect 
the rights and freedoms of others’ and found that the objective ‘to prevent the falsification of 
passports and the second, to prevent fraudulent use thereof’ met those criteria. 

No  derogation  from  the  data  protection  regime  is  envisaged  and  clear  rules,  conditions  and 
safeguards shall be considered as appropriate. In particular, nothing in these initiatives shall 
provide a legal basis for the centralised storage of data collected thereunder or for the use of 
such data for purposes other than that of verifying the authenticity of the document and the 
identity  of  the  holder  by  means  of  directly  applicable  comparable  features  when  the  ID  are 
required to be produced by law.137 

6.1. 

Impacts of the options for ID cards  

General impacts  
Free  movement  of  persons:  Through  better  awareness  of  rights138  ID  SOFT)  will  have  a 
positive  impact  on  free  movement  of  persons,  including  labour  mobility.  Laying  down  a 
limited harmonisation of national ID cards (ID 1) or a completely harmonised ID card (ID 2) 
will reduce the negative effects of the diversity of documents and improve the acceptance of 
IDs because e.g. paper-based ID cards will be replaced in Member States still issuing them. 
The  effect  of  ID  3)  is  lower  because  national  ID  cards  are  not  phased  out,  and  thus  the 
problems related to national ID cards remain. 

Reduction  of  document  fraud:  By  enhancing  administrative  cooperation,  such  as 
exchanging  information  about  fraudulent  documents  through  FADO  and  more  training 
(FRONTEX),  ID  SOFT)  will  reduce  document  fraud.  ID  1)  will  require  the  addition  of 
security features and make documents even less vulnerable regarding falsification. Under ID 
2) fingerprints will be added and further reduce the likelihood of counterfeiting. In general ID 
3)  has  a less  significant positive impact than ID 1 and 2)  because  national  ID cards are  not 
phased out. 

Series  A  no  116;  Rotaru  v.  Romania  [GC],  no.  28341/95,  §  46,  ECHR  2000-V;  and  Weber  and  Saravia  v. 
Germany (dec.), no. 54934/00, § 79, ECHR 2006-XI). 
136 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection 
of natural  persons with regard  to  the processing of personal  data  and on  the  free  movement  of  such  data,  and 
repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance) and/or Directive 
(EU)  2016/680  of  the  European  Parliament  and  of  the  Council  of  27  April  2016  on  the  protection  of  natural 
persons  with  regard  to  the  processing  of  personal  data  by  competent  authorities  for  the  purposes  of  the 
prevention,  investigation,  detection  or  prosecution  of  criminal  offences  or  the  execution  of  criminal  penalties, 
and on the free movement of such data, and repealing Council Framework Decision 2008/977/JHA 
137 (see Art. 4 Regulation 2252/2004). 
138 See Art 4 and 5 Directive 2004/38/EC: right to enter and exit an EU Member State with an ID card. 

33 

 
 
                                                                                                                                                         
Reduction of identity theft: ID SOFT) will help to reduce identity theft caused by ID cards 
(also as a consequence of its effect on reducing document fraud). The impact of the options 
ID 1) and ID 2) will be even more significant because the upgraded security features will help 
to tackle a root cause of identity theft. The effect of ID 3) is less significant because the other 
national ID cards are not phased out. 
Security  (reduction  of  crime,  fraud139,  terrorism):  Soft  law  measures  will  help  to  reduce 
crime  and  improve  security  including  at  the  borders  through  enhanced  administrative 
cooperation,  such  as  optimised  information  exchange  between  police  forces.  For  combating 
all types of serious crime the availability of fingerprints on ID cards has added value because 
fingerprints  could  be  checked  against  databases  (e.g.  Prüm  checks,  Europol  Information 
System). ID 2) (where fingerprints are mandatory) has therefore a more positive impact than 
ID  1),  also  regarding  the  detection  of  criminals  and  the  reduction  of  crime  and  terrorism. 
Although ID 3) also foresees mandatory fingerprints, its impact on the reduction of crime is 
again weaker  than under ID 2)  because  national ID cards are not phased out.  Regarding the 
reduction  of  fraud  the  effects  of  ID  1)  and  2)  will  be  more  or  less  equal  because  –  on  the 
contrary to the security agencies - private and public services affected will not have access to 
fingerprints. 

Fundamental  rights: Beyond reinforcing Article 45 CFEU,  ID SOFT)  will have  a positive 
(albeit  very  limited)  effect  on  the  rights  of  persons  with  disabilities  (Art.  26  CFEU)  by 
creating a forum (e.g. drawing from the expertise of the Article 6 Committee) to discuss the 
specific  needs  of  disabled  persons  (such  as  Braille  for  visually  impaired)  in  relation  to  ID 
cards.  All  the  legislative  options  will  add  to  this  effect  by  encouraging  Member  States  to 
voluntarily  opt  for  specific  features  on  their  ID  cards  that  increase  the  accessibility  for 
disabled persons. 

The exercise of fundamental political rights (Arts. 39-40 CFEU) as well as the exercise of the 
right of petition (Art. 44 CFEU) will be positively impacted by the soft law measures because 
better  acceptance  of  ID  cards  will  facilitate  the  participation  of  mobile  EU  citizens  in 
elections or the launch of a petition through easier registration.140 All the regulatory options 
will have a positive impact in a similar extent. 

Both  soft-law  and  regulatory  options  will  improve  the  security  of  ID  cards  and  reduce 
document fraud, which reinforces the individual’s right to liberty and security (Art. 6 CFEU) 
by enabling national authorities to better prevent and detect identity theft.  

The fundamental rights to a private and family life under Article 7 CFEU, and the right to the 
protection of personal data under Article 8 CFEU are negatively impacted, particularly by the 
regulatory options ID 1-3.  

Data processing will be involved in all options. ID SOFT) will not significantly change data 
processing as compared to the baseline. ID 1) will require biographical data and an obligatory 
facial  image,  which  needs  to  be  encrypted.  For  this  purpose  cryptographic  keys  need  to  be 
exchanged with the specific services (border guards, police).  

139 Fraud here refers to acts of criminal deception intended to result in financial or personal gain with the help of 
fraudulent documents, such as unlawful claims towards social security services or insurances. 
140  Benefits  for  European  democratic  rights  and  for  the  citizens’  initiative  were  detailed  in  the  European 
Parliament’s  study  on  the  legal  and  political  context  for  setting  up  a  European  identity  document 
http://www.europarl.europa.eu/RegData/etudes/STUD/2016/556957/IPOL_STU(2016)556957_EN.pdf 

34 

 
 
                                                 
ID 2) and ID 3) will extend this requirement to fingerprints and certain biometric data will be 
collected.  As  this  is  currently  not  done  under  national  ID  schemes  (though  for  national 
passports),  more  people  will  be  affected  in  their  protected  rights.  Nevertheless,  it  is 
established  that  the  use  of  biometrics  of  the  type  proposed  and  accessible  in  the  manner 
proposed  (as  under  the  Passports  Regulation141)  are  justified  by  the  objectives  of  reducing 
travel document fraud, improving the acceptance and authentication of the ID and improving 
the  identification  of  people  based  on  them,  and  are  proportionate  to  achieving  these 
objectives,  particularly  in  terms  of  extending  their  use  to  the  entire  EU  population  who 
possess national ID cards which can be used as travel documents.  

The question of how Member States set up their national databases to store biometrics is not 
touched  upon  by  any  policy  option  in  keeping  with  the  principle  of  the  administrative 
autonomy  of  the  Member  States,  though  naturally  any  implementation  will  have  to  be 
compatible with EU law and the fundamental rights it protects.  

The  right  of  the  individuals  to  access  their  personal  data,  rectification  and  objection  is  not 
impacted by any of the options, and no derogation to the general data protection regime will 
be created.142  

There is therefore no change as compared to the baseline under any option. Data processing 
activities  by  private  services  which  might  be  accelerated  through  better  acceptance  of 
documents will only use biographical data which have been already used so far, i.e. none of 
the options will have a significant impact as compared to the baseline. 

In addition to the EU-wide mutual recognition of electronic identifications in access to public 
services143,  cross-border  data  use  deriving  from  cards  with  eID  functionality  will  require 
specific  work  on  personal  data  safeguard  mechanisms.  Data  processing  activities  by  private 
services  will  be  certainly  fostered  through  better  use  of  cross-border  eID  functionality 
(optional  under  ID  1),  ID  2)  and  ID  3)).  Should  Member  States  opt  for  such  functionalities 
this will bear additional risks which must be addressed by safeguards.144  

Table 6.1 Summary table on the general impacts under the Policy Option ID 

  Free movement of persons 

  Reduction of document fraud 
  Reduction of identity theft 
  Reduction of fraud 
  Reduction of terrorism risk 
  Criminal’s chances of detection 
  Reduction of number of criminal acts 

+/++ 

ID SOFT 

BL 
Functioning of the internal market 
0 
Security 
0 
0 
0 
0 
0 
0 

+ 
+ 
+ 
+ 
+ 
+ 

ID 1 

ID 2 

ID 3 

++/+++ 

+++ 

++ 

++ 
++/+++ 
++/+++ 
++ 
++ 
++ 

++/+++ 
++/+++ 
++/+++ 
++/+++ 
++/+++ 
++/+++ 

+/++ 
+/++ 
+/++ 
+/++ 
++ 
+/++ 

141 Regulation No 2252/2004. 
142 Specific access rights should be provided (with possibility of erasure and rectification) as is done in Art. 4 of 
the Passports Regulation. As it is already currently the case for such data, data processing activities of biometric 
data  will  only  be  carried  out  by  competent  authorities  (border  guards,  police).  Further  safeguards  could  be 
considered. 
143 eIDAS Regulation 
144  In  compliance  with  the  EU  data  protection  acquis,  in  particular  with  Regulation  (EU)  2016/679  of  the 
European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the 
processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General 
Data Protection Regulation). 

35 

 
 
 
                                                 
 

Improve security including at the borders 

++ 

++/+++ 

+/++ 

  Liberty and security (Art 6 CFEU) 
  Private and family life (Art 7 CFEU)  
  Protection of personal data (Art 8 CFEU) 
 

Integration of persons with disabilities (Art 26 
CFEU) 

0 
+ 
Fundamental rights 
+ 
0 
0/- 
0 
0/- 
0 
+ 
0 

+ 
-/-- 
-/-- 
+/++ 

+ 
--/--- 
--/--- 
+/++ 

+ 
-- 
-- 
+/++ 

+/++ 

  Political rights (Art 39-40, 44 CFEU) 
Note: 

0 
The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

+/++ 

+/++ 

+/++ 

"0" indicates no change (i.e. neutrality) 

Impacts on citizens  

Reduction  of  administrative  burden:  With  non-legislative  measures  (ID  SOFT),  citizens 
will be better informed about their rights and obligations (e.g. via the Single Digital Gateway) 
in respect to ID cards before relocating to another Member State and before engaging in intra-
EU  travel.  Through  soft  law  promoting  a  more  and  better  use  of  (cross-border)  eID 
functionality online procedures to make cross-border purchases can be further simplified. The 
additional elements under the legislative options can further reduce the administrative burden 
for citizens, (e.g. by making it possible to use e-gates at airports with an ID card). Since under 
ID 3) national ID cards are not phased out, the positive impact is not as high as for ID 1) and 
2).  

Reduction of hassle costs: Under ID SOFT) citizens will continue to experience differences 
in respect to ID cards across the EU. Nevertheless, e.g. training measures for border guards 
should already reduce the hassle costs for citizens crossing borders. The potential cost savings 
to citizens (e.g. from quicker border checks) will increase with progressive harmonisation of 
ID cards (from ID 1 to 2). The exact amount, however, cannot be quantified. The benefits and 
cost savings of ID 3) to citizens are likely to be limited, since all  Member States will likely 
still  need  also  to  accept  national  ID  cards.  Therefore,  potentially  many  citizens  would  not 
apply for an (extra) EU ID card. 

Awareness:  Citizens’  awareness  is  mainly  improved  through  non-legislative  measures  (e.g. 
Your  Europe  and  in  the  future  the  Single  Digital  Gateway).  None  of  the  legislative  options 
has a large impact on awareness. 

Access  to  services:  The  impact  of  the  different  options  is  similar  as  for  free  movement. 
Access is facilitated with a similar (ID 1) or identical layout of ID cards (ID 2 and 3). Citizens 
can  expect  to  face  fewer  problems  when  traveling  to  other  Member  States  and  in  accessing 
private  sector  services  (e.g.  opening  bank  accounts  or  making  use  of  other  private/public 
services where an ID card is required). Quantification of these effects is however not possible.  

Compliance costs: Soft law implies no compliance costs for citizens. So does ID 3), since the 
additional  EU  ID  card  is  voluntary.  Under  any  legislative  measure  the  implementation 
foresees that the production of cards with upgraded features is initiated as early as possible. 
Old not compliant cards will be in principle replaced naturally after they expire. However, to 
tackle the most imminent security features missing, a card will need to be replaced before the 
originally defined expiry date because it does not fulfil the requirements as referred to by the 
phasing out regime. This could also create some replacement costs to citizens in those cases 
when the country charges its citizens for a renewal of the card. However, a simple technical 
upgrade (such as from contact to contactless chip) should not render the production of a card 

36 

 
 
 
more expensive. Replacement costs would be equally high under option ID 1) and ID 2) as the 
phasing out regime would impact on the same countries and citizens under both options.145 

Social impacts: The impacts of the various options on employment levels and social inclusion 
generally mirror the impacts on free movement of persons. The higher the awareness about ID 
cards, the better their acceptance and the smoother their authentication, the more positive will 
be  the  effects  for  mobile  EU  citizens  and  their  family  members  when  integrating  into  the 
labour market and the social system of another Member State. 

Table 6.2 Summary table on the impacts on citizens under the Policy Option ID 

Impacts on citizens 

BL 

  Reduction of administrative burdens  
  Reduction of hassle costs 
  Awareness  
  Access to public and private services 
  Compliance costs 

0 
0 
0 
0 
0 

ID SOFT 
Economic 
+ 
+ 
+ 
+ 
0 

ID 1 

ID 2 

++/+++ 
++/+++ 
+ 
++ 
-/-- 
(15M+63M)146  

++/+++ 
+++ 
+ 
++/+++ 
-/-- 
(15M+63M)146  

Social 
+ 
+ 
The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

  Employment levels 
  Social Inclusion 
Note: 

++/+++ 
++/+++ 

++/+++ 
++/+++ 

0 
0 

ID 3 

+/++ 
+/++ 
+ 
+/++ 
0 

+/++ 
+/++ 

"0" indicates no change (i.e. neutrality) 

Impacts on businesses  

Compliance  costs:  There  are  no  compliance  costs  for  companies  under  any  option  because 
any technical upgrades to read cards will be voluntary. 

Cost  savings  at  pre-boarding  checks  and  when  opening  a  bank  account:  Private  sector 
entities  such  as  banks  or  airlines  will  continue  to  have  to  deal  with  a  large  variety  of 
documents  under  ID  SOFT)  but  awareness  raising  measures  and  training  could  speed  the 
process up when dealing with EU mobile citizens. Currently, it takes banks longer on average 
to  open  a  bank  account  for  non-national  EU  citizens  than  for  nationals  due  to  longer 
background checks. This applies also to airlines carrying out pre-boarding checks on nationals 
and  non-national  EU  citizens.  If  procedures  were  as  quick  for  non-national  EU  citizens  for 
nationals EUR 3.9M could be annually saved when opening a bank account and EUR 12.4M 
for  pre-boarding  checks.147  It  can  be  assumed  that  ID  cards  under  ID  1)  are  sufficiently 
harmonised to achieve the same impact as under full harmonisation under ID 2). 

The costs for  private sector  services of having  to deal with  an additional EU ID card under 
ID 3)  would most  likely be higher than any potential benefit  to them from it. At best  it can 
thus be assumed that ID 3) is cost neutral compared to the baseline. 

145 Around 15M citizens in BE, BG, EL, ES, HU, RO, SK need to replace their ID cards earlier because holding 
an ID card in those countries from a certain age is mandatory. Another around 63M ID cards from CZ, FR, IT, SI 
are only issued at the request of the citizens but might also be affected by quicker replacement. 
146 Around 15M citizens in BE, BG, EL, ES, HU, RO, SK need to replace their ID cards earlier because holding 
an ID card in those countries from a certain age is mandatory. Another around 63M ID cards from CZ, FR, IT, SI 
are only issued at the request of the citizens but might also be affected by quicker replacement. 
147  Calculations  in  the  CSES  study,  based  upon  feedback  from  IATA  and  Airlines  for  Europe,  as  well  as 
individual banks from the Member States.  

37 

 
 
 
                                                 
Awareness:  The  proposed  sector-oriented  training  sessions  and  the  improved  FADO 
functionalities (ID SOFT) should help raise awareness of the layout of the different types of 
documents. As they include the soft law measures the legislative options will have the same 
impact on awareness. 

Reduction of training costs: Training via associations as proposed under ID SOFT) will save 
costs  invested  in  training.  This  will  lead  to  more  efficiency  in  handling  different  types  of 
documents. The training costs of banks and airlines will be lower if ID cards comply with the 
ICAO standards as set out by policy options ID 1) and 2).  

Companies  producing  the  cards:  The  companies  will  benefit  from  activities  carried  out 
under  ID  SOFT),  e.g.  awareness  raising,  the  direct  exchange  of  Member  States  and  private 
sector association experts, as well as the information retrieved via the single digital gateway. 
ID 3) will offer an opportunity to companies to produce a limited number of fully harmonised 
EU  ID  cards  which  will  not  replace  national  ID  cards.  ID  2)  will  do  this  on  a  larger  scale. 
Under  ID  1)  each  Member  State  will  do  its  own  national  tendering  process  based  upon  ID 
card  requirements  that  will  be  Member  State  specific,  and  it  is  more  likely  that  more 
companies across the EU will benefit from this situation.  

Table 6.3 Summary table on the impacts on businesses under the Policy Option ID 

Impacts on businesses 

BL  

ID SOFT 

ID 1 

ID 2 

ID 3 

  Compliance costs 
  Cost savings pre-boarding checks - time 

Economic 
0 
0 

  Cost savings in private services (bank) - time 

0 

0 
+ 

+ 

  Awareness 
  Reduction of training costs 
  Companies producing the cards 
Note: 

0 
0 
0 
The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

+ 
+ 
+ 

"0" indicates no change (i.e. neutrality) 

Impacts on public authorities  

Costs  of  guidance,  dissemination,  awareness-raising,  training:  Soft  law  measures  will 
build on existing structures148 and activities in the Member States and at EU level. Under ID 
SOFT)  (as  well  as  included  under  all  legislative  options)  there  will  be  certain  costs  for  e.g. 
awareness  raising  and  information  campaigns,  support  for  citizens’  requests,  a  Points  of 
Contact  system  within  Member  States  to  facilitate  exchange  of  information  and  checks  on 
documents or an improved FADO (PRADO) web registry.  

Following  the  implementation  of  soft  law  measures  national  administrations  and  border 
control officials will be more aware of the layout, design, security features of documentation 
in other EU countries. Although not possible to determine exactly how this could also reduce 
cost, in particular by increasing efficiency in border and local administrations which issue and 
check  documentation.  EU-wide  training  workshops  and  capacity-building  will  be  based  on 

148 For example it is proposed that awareness-raising measures are routed via SOLVIT since it has a presence in 
all 28 Member States. EU-wide training workshops and capacity-building could be based on existing FRONTEX 
workshops. Enhanced administrative cooperation mechanisms could take place drawing on the expertise of the 
Article 6 Committee.  

38 

0 
++ 
(12.4M/yr) 
++  
(3.9M/yr)  
+ 
+/++ 
++/+++ 

0 
++ 
(12.4M/yr) 
++  
(3.9M/yr) 
+ 
++/+++ 
++ 

0 
0 

0 

+ 
0/+ 
+/++ 

 
 
                                                 
existing  FRONTEX  workshops.  Increased  training  will  have  a  positive  impact  on  the 
detection of fraudulent documents. Such activities across the EU could cost around EUR 11 
M per year.149 

Costs of enhancing regulatory and advisory bodies: Enhanced administrative cooperation 
mechanisms  will  be  via  e.g.  the  Member  States  expert  groups  on  document  security  and  its 
sub-groups and the FREEMO expert group. The additional costs for tasking these groups will 
be marginal. 

Remove regulatory complexity: ID SOFT) will not remove any regulatory complexity. ID 1) 
will  largely  harmonise  and  ID  2)  fully  harmonise  the  Member  States  rules  on  format  and 
security of ID cards, whereas ID 3) will even add further complexity by establishing another 
ID card with specific format and security features. 

Compliance  costs  –  implementation:  Under  the  legislative  options  ID  1)  to  3)  public 
administrations  will  have  to  invest  administrative  and  financial  resources,  hardware  and 
software updates in changing the format and security of ID cards. In particular the upgrade to 
chips  and  biometrics  will  add  some  costs.150  Nevertheless,  equipment  to  issue  passports  is 
already available and can also be used for the issuance of ID cards. 
Under ID 1) at least 19 Member States151 will require a certain upgrade, whereas under ID 2) 
this  is  the  case  for  all  26  Member  States  which  currently  produce  ID  cards.  Under  option 
ID 3)  all  Member  States  would  need  to  establish  a  new  card  which  –  at  the  request  of  the 
citizens - would be issued in addition to the national ID cards.152  

As  option  ID 2)  and  3)  establish  a  fully  harmonised  format  for  national  ID  cards,  the 
production costs would be marginally higher than for ID 1). Moreover, the obligatory use of 
fingerprints would also increase these options’ overall implementation costs.153  

The  same  reading  equipment  at  border  control  points  used  for  passports  could  be  used  for 
verifying  biometric  ICAO-compliant  ID  cards,  meaning  the  cost  of  additional  card  reader 
infrastructure to fully implement policy options ID 1) to 3) would be marginal.154  

Compliance costs (production) – phasing out: Member States either already fulfil the basic 
requirements  or  the  phasing  out  of  non-compliant  ID  cards  will  mostly  coincide  with  the 
natural replacement cycle of usually 10 years. ID cards from EL, IT and FR do not possess 
fully functional machine readable zones (MRZ) and would thus incur higher additional costs 
because of the quicker phasing out foreseen under options ID 1) and 2).  

Moreover,  a  number  of  other  Member  States  (BE,  BG,  CZ,  ES,  HU,  RO,  SI,  SK)  issue 
specific cards for senior citizens with longer or indefinite validity which – if replaced – would 
also bear some additional costs after the ten-year transition phase, again for both options ID 1) 

149 Cost estimate for those non-legislative measures across the policy options. See Annex 4 (section 2) and the 
CSES study for details. There is some EU funding available to cover these measures. 
150  The  additional  compliance  costs  for  adding  RFID  chips  to  already  produced  plastic  cards  are  however 
negligible. There are no data available to calculate the costs for adding biometric identifiers to ID cards. 
151 ID cards from BG, CY, HU, LV, LT, LU, and NL already comply with the requirements as proposed under 
ID 1). For DE ID cards, which have already a very high level of security, only the date field indicating the sex is 
missing and needs to be added. 
152 It seems unlikely that this function could be assumed on an EU level since it would mean that a pan-European 
database of citizen data and a EU-wide printing facility needs to be set up. This seems not to be possible both 
from a feasibility point of view and from a data protection/privacy point of view.  
153 The management of databases storing biometric identifiers is not addressed by this initiative. 
154 This has been confirmed by FRONTEX; see CSES study. 

39 

 
 
                                                 
and 2). The total cost for phasing out in all cases will amount to EUR 778.3M.155 ID 3) does 
not foresee any phasing out and is thus cost neutral. 

Time  savings  –  public  services:  Public  services,  such  as  national  social  security  providers 
will  continue  to  have  to  deal  with  a  large  variety  of  documents  under  ID  SOFT)  but  those 
non-legislative measures will speed up processes. With increasing harmonisation of ID cards 
under ID 1) and 2) procedures can be as quick for non-national EU citizens as for nationals. 
ID  3)  would  not  add  anything  here  because  another  ID  card  would  just  add  complexity.  At 
best ID 3) will be cost neutral. 

Time savings – border control: Border guards deal with diverse ID cards. Through training 
of border officials, the use of FADO/PRADO and other measures ID SOFT) could save time 
and thus costs. 

Simultaneously,  however,  border  control  authorities  will  further  benefit  from  common 
features  in  ID  cards,  such  as  under  ID  1)  and  2),  as  this  would  substantially  facilitate  the 
procedures  at  borders  and  could  again  facilitate  the  detection  of  fraudulent  cards,  thus 
increasing security. It is shown that if ID cards were more largely harmonised and checks for 
non-national  EU  citizens  would  be  as  fast  as  for  nationals156,  considerable  cost  savings  of 
around EUR 17.1M per year could be obtained throughout the EU.  

Under ID 3) none of the current ID cards will be replaced but instead another document will 
be added to the numerous documents that are already subject to border checks. 

Access  to  social  protection  systems:  The  social  protection  systems  will  benefit  from 
increased  awareness  of  document  formats  and  security  features  under  ID  SOFT),  as  this 
reduces  scope  for  abuse.  ID  1)  and  2)  will  further  reduce  document  fraud,  whereas  adding 
another document under ID 3) that will not replace other documents will not.  

Governance and good administration: Beyond removing regulatory complexity governance 
will  benefit  both  from  non-binding  soft  law,  and  from  some  harmonisation  of  ID  cards 
because  the  authentication  of  the  documents  and  the  identification  of  persons  will  be 
improved.  In  online  services  eID  functionality  on  ID  cards  could  speed  up  bureaucratic 
processes, cut paperwork and reduce administrative spending. 

E-government:  eID  functionality  will  be  optional  under  all  options.  Apart  from  general 
capacity building and contributions by research and innovation from non-legislative measures 
there is no additional effect from legislative measures.  

Table 6.4 Summary table on the impacts on public authorities under the Policy Option ID 

Impacts on public 
authorities 

  Costs of guidance, 
dissemination and 
awareness-raising, 
training 

  Costs of enhancing 
regulatory and 
advisory bodies 

BL 

ID SOFT 

ID 1 

ID 2 

ID 3 

Economic 

- 
(11M/yr)157  

- 
(11M/yr)157 

- 
(11M/yr)157 

- 
(11M/yr)157 

-/0 

-/0 

-/0 

-/0 

0 

0 

155 See Annex 3 and 4 for more precise calculation of the cost estimate. 
156 See illustrative case p. 102, CSES study. 
157 See Annex 4 - section 2 (Annual costs for non-legislative measures across the EU) 

40 

 
 
                                                 
  Remove regulatory 

complexity 

  Compliance costs – 
implementation  
  Compliance costs – 

phasing out 

  Time savings – public 

services 

  Time savings – border 

control 

  Access to social 

protection systems 
  Governance and good 

administration 
  E-government 
Note: 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

+ 

+ 

+ 

+ 

+ 

+/++ 

-- 

++ 

--- 

--/--- 
(778.3M) 
++ 

--/--- 
(778.3M) 
++ 

++ 
(17.1M/yr) 

++ 
(17.1M/yr) 

++ 

++ 

+ 

++ 

++ 

+ 

Social 

- 

--/--- 

0 

0 

0 

+/++ 

+/++ 

+ 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

6.2. 

Impacts of the options for residence documents 

General impacts  

Free  movement  persons:  Soft  law  measures,  such  as  awareness  raising  about  the  rights 
linked  to  residence  documents158,  have  a  positive  impact  on  the  free  movement  of  persons, 
including  indirectly  on  labour  mobility.  The  more  harmonised  residence  documents  across 
Member  States  are  (from  RES  1  to  3),  the  higher  is  the  positive  impact  because  the 
consequences of the diversity of documents are reduced.  

Reduction  of  document  fraud:  By  enhancing  administrative  cooperation,  such  as 
exchanging  information  about  fraudulent  documents  through  FADO/PRADO  and  more 
training,  RES  SOFT)  will  reduce  document  fraud.  The  more  security  features  are 
progressively added from RES 1) to 3) the less prone they are to counterfeiting.  

Security (reduction of crime, fraud, and terrorism): Soft law measures (e.g. training) will 
contribute to reducing crime and improving security within the EU and at its borders because 
administrations,  border  guards  and  police  will  be  more  aware  about  false  residence 
documents. Streamlining formats for and adding security features under RES 2) and 3), such 
as  mandatory  fingerprints  to  TCN  FAM  cards,  may  be  particularly  beneficial  to  internal 
security. The main effects will be on border security. 

Fundamental  rights: By creating more harmonised and robust TCN FAM cards the policy 
options  RES  2)  and  3)  have  clearly  some  impact  on  private  and  family  life  (Art  7  CFEU) 
because  unjustified  denial  of  their  holders’  entry  at  the  borders  or  their  boarding  of  planes 
entering the EU will become less likely.  

By taking up the discussion in the relevant forum, such as the Member States expert groups 
on  free  movement  and  on  document  security  RES  SOFT)  will  have  a positive  effect  on the 
rights of persons with disabilities (Art 26 CFEU). No additional effect will be achieved by the 
legislative options. 

158 See Art 8, 10, 16 and 20 of Directive 2004/38/EC. 

41 

 
 
 
                                                 
Both soft-law and regulatory options will contribute equally to preventing the current forgery 
of  documentation,  which  reinforces  the  individual’s  right  to  liberty  and  security  (Art.  6 
CFEU) by enabling national authorities to better prevent and detect identity theft. 

The obligation to collect personal data affects the protection of Articles 7 and 8 CFEU. RES 
SOFT)  will  not  significantly  change  data  processing  compared  to  the  baseline.  The 
harmonisation  of  the  very  limited  amount  of  data  for  other  residence  documents  (for  EU 
citizens) under RES 1) will not change these requirements. Apart from the name of the holder, 
which is already an indispensable feature of any document, the minimum data proposed (title 
of the document, document number, place and date of issue…) are administrative data which 
aim  to  increase  the  acceptance  of  the  documents  by  other  stakeholders.  Higher  impacts  on 
fundamental rights are anticipated by policy options RES 2) and RES 3), since they include an 
obligation to collect mandatory biometrics.  

The use of biometrics can have positive impacts on reducing the risk of mistaken identity and 
also contribute to addressing protection risks for children (such as children going missing or 
falling  victims  of  trafficking).  Because  the  collection,  storing  and  processing  of  such  data 
affects the fundamental rights of protection of private life and personal data as enshrined in 
the  CFEU,  any  measures  need  to  be  implemented,  corresponding  to  the  safeguards  already 
applied for the biometric data required under the Residence Permit Regulation with a set of 
complementary safeguards to fully comply with data protection acquis  159. This is particularly 
relevant for those cases where minors over the age of six are under options RES 2) and RES 
3)  will  be  required  to  provide  fingerprints  and  other  biometric  features.160  Article  24  of  the 
Charter emphasises that the best interests of the child must be a primary consideration in all 
actions  public  authorities  and  private  actors  take  concerning  children.  This  also  applies  to 
fingerprinting. 

The right of the individuals to access, rectification and objection is not impacted by any of the 
options.  Specific  access,  erasure  and  rectification  rights  should  be  provided,  including  an 
effective  remedy  before  a  court  or  tribunal  in  line  with  Article  47  of  the  Charter.  Data 
processing activities of biometric data for residence documents (especially TCN FAM cards) 
will only be carried out by competent authorities (border guards, police).  

Table 6.5 Summary table on the general impacts under the Policy Option RES 

BL 

RES SOFT 

RES 1  RES 2 

RES 3 

 

Free movement of persons 

Functioning of the internal market 
+ 

0 

Security 

  Reduction of document fraud 
  Reduction of fraud 
  Reduction of terrorism risk 
  Criminal’s chances of detection 
  Reduction of number of criminal acts 
 

Improve security including at the borders 

0 
0 
0 
0 
0 
0 

  Liberty and security (Art 6 CFEU) 

Fundamental rights 

0 

+ 
0/+ 
0/+ 
0/+ 
0/+ 
+ 

+ 

+/++ 

++ 

++/+++ 

+/++ 
+ 
0/+ 
0/+ 
0/+ 
+ 

++ 
+/++ 
0/+ 
0/+ 
0/+ 
++ 

++/+++ 
++ 
0/+ 
0/+ 
0/+ 
++ 

+ 

+ 

+ 

159 Regulation No 1030/2002. 
160 Art. 24 CFEU obliges the public authorities to treat a child’s best interests as a primary consideration when 
processing such data. The RES 2) and 3) requirements do not go beyond those already in place for the residence 
permit regulation and protections should therefore be aligned in this respect. 

42 

 
 
 
                                                 
  Private and family life (Art 7 CFEU) 
  Protection of personal data (Art 8 CFEU) 
 
Note: 

Integration of persons with disabilities (Art 26 CFEU) 

0 
0 
0 

+ 
0 
+ 

+/++ 
- 
+ 

++ 
-/-- 
+ 

++ 
-- 
+ 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

Impact on citizens  

Reduction of administrative burden: Non-legislative measures (RES SOFT) will reduce the 
administrative  burden  on  citizens,  because  information  about  residence  documents  and  the 
rights linked to them will be more easily available including via the promotion of the single 
digital gateway. No large effects by the other legislative options. 

Reduction  of  hassle  costs:  RES  SOFT)  will  improve  the  acceptance  of  certain  residence 
documents (through raising awareness). With progressively increasing harmonisation level of 
format and security of residence documents in all EU countries (from RES 1 to 3) it would be 
more  likely  that  problems  of  acceptance  and  authentication  of  documents  are  reduced.  This 
will reduce hassle costs. 

Awareness: RES SOFT) will have a positive impact on the awareness of mobile EU citizens 
and their family members of their residence documents via the non-legislative measures, such 
as the information citizens will retrieve via the single digital gateway.  

However,  as  under  RES  3)  all  residence  documents  –  despite  their  differences  in  document 
titles and function (see Directive 2004/38/EC) – will have the same format this could create 
also more confusion among citizens. 

Access  to  public  and  private  services:  The  impact  of  the  different  options  on  access  to 
public  and  private  services  will  mirror  the  impact  on  reduction  of  hassle  costs  and  free 
movement.  When  EU  citizens  open  a  bank  account  or  want  access  to  social  security  the 
acceptance  of  progressively  harmonised  residence  documents  will  be  improved  and 
authentication procedures will be accelerated. Particularly relevant is the improved acceptance 
of TCN FAM cards under option RES 2) and RES 3) because the use of the uniform format 
for those cards will increase the probability that TCN family members are not wrongly denied 
boarding of planes when entering the EU. 

Compliance costs: Whereas RES SOFT) will not add any compliance costs for citizens and 
RES 1) no significant costs, the phasing out regime for TCN FAM cards under RES 2) and 3) 
will  require  that  the  affected  TCN  FAM  card  holders161  in  up  to  21  countries162  to  need  to 
replace their documents before their expiry date. How much they will charge family members 
of EU citizens for this will depend on the individual Member State.  

Time savings at the border: Under RES SOFT) EU citizens and their family members will 
benefit indirectly from training of officials because they will verify TCN FAM cards163 more 
quickly at the external borders. RES 2) and 3) will further reduce waiting times at the borders 
for TCN family members due to a harmonised standard document for TCN FAM cards across 
the EU which could be easily checked by border officials.  

161 Only TCN FAM permanent residence cards are affected by the phasing out because the validity of TCN FAM 
residence cards does not exceed 5 years (see section 2.1 and CSES study). 
162 All countries except DE, LT, NL (and probably since changes recently introduced EL, IE, PT, RO) 
163 TCN FAM cards function as visa waiver. 

43 

 
 
 
                                                 
Social  impacts:  The  effects  of  the  different  options  on  employment  levels  and  social 
inclusion will mirror the effects on free movement of persons.  

Table 6.6 Summary table on the impacts on citizens under the Policy Option RES 

Impacts on citizens 

  Reduction of administrative burden 
  Reduction of hassle costs 
  Awareness  
  Access to public and private services 
  Compliance costs 
  Time savings at the border 

  Employment levels 
  Social inclusion 
Note: 

BL 
Economic 

0 
0 
0 
0 
0 
0 
Social 
0 
0 

RES SOFT 

RES 1 

RES 2 

RES 3 

+ 
+ 
+ 
+ 
0 
+ 

+ 
+ 

+ 
+/++ 
+ 
+/++ 
-/0 
+/++ 

+/++ 
+/++ 

+ 
++ 
+ 
++ 
-/-- 
++ 

++ 
++ 

+ 
++/+++ 
0/+ 
++/+++ 
-/-- 
++ 

++/+++ 
++/+++ 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

Impact on businesses  

Awareness: With soft law measures there will be more awareness and support via different 
channels about document features (FADO, single digital gateway…).  

Reduction of training costs: RES SOFT) will help to reduce costs by bundling training with 
help for private sector associations. The more harmonised the documents (from RES 1 to RES 
3), the lighter the training requirements which does again reduce costs.  

Cost savings in private services – time: The more harmonised the documents are the more 
benefits  for  businesses  (banks,  estate  agents,  insurance  companies  etc.)  which  require  a 
residence  document  together  with  an  ID  when  carrying  out  services.  The  time  for  checking 
documents  will  be  reduced.  However,  as  for  citizens,  an  identical  format  for  all  types  of 
residence documents as under RES 3) with slightly different function (registration certificate, 
TCN FAM card, etc.) might also create some confusion when these documents are used for 
private sector services.  

Cost savings at  pre-boarding checks  – time: As for private  services  cost  savings, RES 2) 
and RES 3) will have particular benefits by harmonising the security features of TCN FAM 
cards,164 to be easily accepted in all EU Member States when checked before boarding. This 
will reduce the airlines’ liability costs for wrongly denying boarding to passengers carrying a 
valid but low quality TCN FAM card. 

Companies producing the cards: RES SOFT and 1) will not change the production system 
of documents. The switch from the current format to the obligatory uniform format for TCN 
FAM cards under RES 2), and all residence documents under RES 3) will however create a 
rather small opportunity for card manufacturers, including SMEs. 

Table 6.7 Summary table on the impacts on businesses under the Policy Option RES 

Impacts on businesses 

BL 

RES SOFT 

RES 1 

RES 2 

RES 3 

164 Used as visa waiver. 

Economic 

44 

 
 
 
                                                 
  Awareness  
  Reduction of training costs 
  Cost savings in private services - time 
  Cost savings at pre-boarding checks - time 
  Companies producing the cards 
Note: 

0 
0 
0 
0 
0 

+ 
+ 
+ 
+ 
0 

+ 
+/++ 
+/++ 
+/++ 
0 

+ 
++ 
++ 
++ 
+ 

+ 
++/+++ 
++ 
++ 
+/++ 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

Impact on public authorities  

Costs  of  guidance,  dissemination  and  awareness-raising,  training:  RES  SOFT)  will 
largely rely upon the activities of public administrations. They need to adjust their activities to 
their  needs  and  possibilities.  In  particular,  enhanced  administrative  cooperation  between 
Member  States  (FREEMO  expert  group,  etc.)  to  exchange  information  about  residence 
documents  issued  will  produce  substantial  benefits  for  the  Member  States  involved.  As  in 
practice soft law measures for options ID, RES, PROCESS are bundled, the cost estimate will 
follow a similar logic as for ID cards.  

Costs of enhancing regulatory and advisory bodies: There will be only marginal costs to 
task  the  relevant  bodies  (FREEMO  expert  group,  expert  group  on  document  security)  with 
discussions about the format and security of residence documents. 

Remove regulatory complexity: The more documents’ format and security is harmonised the 
more regulatory complexity across the EU Member States is reduced. 

Time  savings  –  border  control:  There  is  some  effect  on  speedier  border  checks  through 
better  awareness and training related to  TCN FAM cards used  as  visa waiver (RES SOFT). 
The limited harmonisation of certain data (RES 1) will have no greater impact. RES 2) and 3) 
will  however  increase  time  saving  through  the  implementation  of  harmonised  TCN  FAM 
cards.  

Time savings – public services: Mirroring the general effects on free movement increasing 
harmonisation  will  have  a  positive  impact  on  quicker  procedures  for  public  services.  Under 
RES 3) the expected benefit will contribute to removing problems for the 7.2 million residents 
in other Member States. However, it is not possible to quantify what benefits can be expected, 
since it will be impossible to link any benefits directly to the policy change proposed. 

Compliance  costs  –  implementation:  By  asking  for  a  limited  amount  of  data  to  be 
harmonised, RES 1) will not place a substantial burden on public administrations but ensure 
that  residence  documents  contain  a  minimum  of  information  relevant  for  administrative 
purposes EU-wide. At least 19 Member States will have to correct or translate the title of the 
documents.165 
Under  RES  2)  at  least  21  Member  States166  will  need  to  upgrade  their  production  for  TCN 
FAM  cards.  And  as  there  is  currently  no  single  Member  State  that  issues  its  entire  set  of 
residence  documents  in  compliance  with  the  uniform  format,  under  option  RES 3)  all  28 
Member States will have to adapt their existing production for residence documents.  

165 AT, BE, BU, CZ, DE, EE, EL, ES, FR, HR, HU, IT, LU, MT, PL, PT, SK, UK; Formats for DK, FI, IE, LT 
and SE are unknown and they may also be concerned. 
166 All countries except DE, LT, NL (and probably since changes recently introduced EL, IE, PT, RO) 

45 

 
 
 
                                                 
Compliance costs– phasing out of TCN FAM cards: As regards the phasing out of old non-
compliant  documents,  at  least  14  Member  States167,  not  using  yet  the  uniform  format,  will 
need to bear some additional costs for the quicker 5-years transition period. The only cards to 
be  phased  out  prematurely  are  some  of  the  TCN  FAM  permanent  residence  documents, 
whereas TCN FAM residence cards are anyway naturally replaced within a five years cycle. 
The additional cost that Member States would have to bear under RES 2) and 3) will amount 
to EUR 3.1M168.  

Reduction of number of queries: Better acceptance and authentication of harmonised TCN 
FAM documents under RES 2) and 3) will reduce the number of queries made by the national 
authorities concerning the TCN family member’s Schengen visa exemption. 

Table 6.8 Summary table on the impacts on public authorities under the Policy Option RES 

Impacts on public authorities 

BL 

RES SOFT 

RES 1 

RES 2 

RES 3 

  Costs of guidance, 

dissemination and awareness-
raising, training 

  Costs of enhancing regulatory 

and advisory bodies 

  Remove regulatory complexity 
  Time savings – border control  
  Time savings – public services 
  Compliance costs – 
implementation  

  Compliance costs – phasing out 

of TCN FAM cards 
  Reduction of number of 

queries 

0 

0 

0 
0 
0 
0 

0 

0 

Economic 

- 
(11M/yr)157 

- 
(11M/yr)157 

- 
(11M/yr)157 

- 
(11M/yr)157 

-/0 

0 
+ 
+ 
0 

0 

0 

-/0 

+ 
+ 
+/++ 
-/0 

0 

0 

-/0 

+/++ 
++ 
++ 
- 

- 
(3.1M) 
++ 

-/0 

++ 
++ 
++/+++ 
--/--- 

- 
(3.1M) 
++ 

Note: 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

6.3. 

Impacts of the options for PROCESS 

General impacts  

Free  movement  of  persons:  PROCESS  SOFT)  will  foster  free  movement  of  persons  by 
promoting  more  citizen-friendly  administrative  procedures,  such  as  online  applications  for 
residence documents. In respect to option PROCESS 1), requiring all consulates to issue ID 
cards  to  their  citizens  in  addition,  will  clearly  facilitate  free  movement  for  citizens  of  those 
countries169  where  this  is  currently  not  possible.  This  will  also  have  a  positive  impact  on 
labour mobility and cross-border services. 

Reduction  of  document  fraud:  Promoting  robust  online  procedures,  such  as  under 
PROCESS  SOFT,  will  have  a  very  limited  impact  on  the  reduction  of  document  fraud. 
Moreover, Member States will share information about production and issuance processes, as 
well  as  whether  they  have  stopped  producing  a  certain  document.  Under  PROCESS  1)  the 

167 See FN 165 
168 See Annex 3 and 4 for more precise calculation of the cost estimate. 
169 Croatia, Czech Republic, Finland, Hungary, Malta, Romania and Spain. 

46 

 
 
 
                                                 
effect on document security is the same because issuing an ID card via the consular network 
is  not  more  secure  than  travelling  back  to  the  home  country  and  personally  applying  for  a 
document at a local authority. 

Improve security including at borders: Based upon the positive impacts on the reduction of 
document  fraud  (see  above)  soft  law  will  contribute  to  improving  the  general  security  level 
including at the external borders.  

Fundamental rights: PROCESS SOFT) will have a positive effect on the rights of persons 
with  disabilities  (Art  26  CFEU)  by  creating  online  procedures  to  receive  documents. 
Moreover, persons with disabilities accessibility will be improved via the possibility to apply 
for ID documents via the consular network (PROCESS 1). 

Because  data  processing  will  be  involved  with  both  options,  Articles  7  and  8  CFEU  are 
affected and adequate safeguards will be required, compatibly with the data protection acquis 
and in alignment with those already described for the  ID and RES options. The right of the 
individuals  to  access,  rectification  and  objection  is  not  impacted  by  any  of  the  options. 
Access,  erasure  and  rectification  rights  an  effective  remedy  would  be  ensured  in  line  with 
requirements of the data protection acquis and Article 47 of the Charter  

Table 6.9 Summary table on the general impacts under the Policy Option PROCESS 

 

Free movement of persons 

B
L 
Functioning of the internal market 
0 

Security 

  Reduction of document fraud 
 

Improve security including at the borders 

Fundamental rights 

  Private and family life (Art 7 CFEU) 
  Protection of personal data (Art 8 CFEU) 
 
Note: 

Integration of persons with disabilities (Art 26 CFEU) 

PROCESS SOFT  PROCESS 1 

+ 

+ 
+ 

-/0 
- 
+ 

+/++ 

+ 
+ 

-/0 
- 
++ 

0 
0 

0 
0 
0 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

Impact on citizens  

Reduction  of  administrative  burden:  Online  application  for  residence  documents  will 
reduce  the  administrative  burden  on  citizens  (PROCESS  SOFT).  If  consulates  provide  their 
nationals  with  the  opportunity  to  request  ID  documents  via  the  consulate  this  will  also 
substantially reduce the administrative burden on mobile EU citizens (PROCESS 1).  

Awareness:  Through  soft  law  measures  awareness  will  be  raised  about  opportunities  for 
application online, as well as via the consular network.  

Reduction  of  hassle  costs  (cost  of  the  trip):  After  soft  law  measures  under  PROCESS 
SOFT),  citizens  will  most 
likely  have  fewer  problems  e.g.  requesting  residence 
documentation  or  opening  bank  accounts  where  residence  certificates  need  to  be  presented. 
Under PROCESS 1) the benefits for expatriates can be quite substantial, as the opportunity to 
apply  for  an  ID  card  via  a  consulate  will  save  a  potentially  costly  trip  back  to  their  home 
country which would otherwise be needed to renew the ID card. 

47 

 
 
 
 
Shipping  costs:  Only  relevant  for  PROCESS  1).  The  costs  of  shipping  the  card  from  the 
Member State where the card is produced to the consulate is charged to the citizen. 

Impact on public authorities  

Costs of guidance, dissemination and awareness-raising, training: The costs for soft law 
measures are a part of the overall soft law package as discussed under the ID SOFT) and RES 
SOFT) options. Measures can be adjusted to the needs of the Member States. 

Costs of enhancing regulatory and advisory bodies: Tasking the usual groups, such as the 
FREEMO expert  group or  the expert group on document security with exchanging process-
related information will not add significant costs 

Remove  regulatory  complexity:  No  effect  under  soft  law.  PROCESS  1)  will  simplify  and 
harmonise the regulatory framework for issuing ID cards via the consular network. 

Reduction  of  administrative  costs:  Public  authorities  can  save  administrative  costs  if 
application procedures are undertaken online as proposed under PROCESS SOFT). As there 
is  little  evidence  available  on  the  administrative  costs  of  issuing  residence  documents,  it  is 
impossible  to  calculate  the  precise  gains  but  extrapolating  the  Danish  case170  argues  for 
substantial  cost  savings.  Under  PROCESS  1)  this  cost  saving  will  be  partially  offset  by  the 
administrative costs of issuing ID cards via the consular network. 

Compliance costs – implementation: No compliance costs for soft law (PROCESS SOFT), 
as  non-binding.  PROCESS  1)  will  involve  only  costs  for  those  seven  Member  States  that 
currently  do  not  issue  ID  cards  via  their  consular  network.171  There  are  two  types  of  costs. 
First, those Member States will incur costs to establish the process for issuing the ID cards. 
Second,  excluding  shipping  costs,  they  will  only  be  able  to  charge  the  same  amount  for 
issuing  the  document  via  the  consular  network  as  for  issuing  it  within  their  home 
administration. The costs cannot be calculated due to a lack of data. 

Table  6.10  Summary  table  on  the  impacts  on  citizens  and  public  authorities  under  the  Policy 
Option PROCESS 

BL 

PROCESS SOFT 

PROCESS 1 

Impacts on citizens - Economic 

  Reduction of administrative burden 
  Awareness 
  Reduction of hassle costs (cost of the trip) 
  Shipping costs 

0 
0 
0 
0 

+/++ 
+ 
+ 
n/a 

Impacts on public authorities - Economic 

  Costs of guidance, dissemination and awareness-raising, 

training 

  Costs of enhancing regulatory and advisory bodies 
  Remove regulatory complexity 
  Reduction of administrative costs 

  Compliance costs – implementation  

0 

0 
0 
0 

0 

- 
(11M/yr)157 
-/0 
0 
++/+++ 
(40-50%)172 
0 

++ 
+ 
++ 
- 

- 
(11M/yr)157 
-/0 
+ 
+/++ 

-/-- 

170 In the case of Denmark a rough estimate is that the new online system should lead to a 40% to 50% time-
saving for public authorities. 
171 Croatia, Czech Republic, Finland, Hungary, Malta, Romania and Spain 
172  If  DK  system  for  online  application  system  of  residence  cards  is  extrapolated  to  all  ID  and  residence 
documents, as well as countries. 

48 

 
 
 
 
                                                 
Note: 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

7  HOW DO THE OPTIONS COMPARE? 

Based  on  the  assessment  of  the  likely  various  impacts  (economic,  social,  security  and 
fundamental  rights  impacts)  and  their  distribution  across  stakeholders  (citizens,  businesses 
and public authorities) under section 6, this section compares the different options with regard 
to  their  effectiveness,  efficiency,  coherence  with  other  (EU)  policies  and  their  compliance 
with the proportionality principle. 

Options  are  compared  within  each  policy  instrument  and  it  is  ensured  that  the  preferred 
options for the ID cards, for the residence documents and for the process related-issues do not 
change  if  the  choice  of  options  changes  for  the  other  policy  instruments.  For  example, 
choosing a solution addressing format and security of ID cards is independent of choosing the 
format  and  security  of  residence  documents  (or  the  choice  of  a  solution  for  addressing 
process-related  issues).  Finally,  it  shall  be  clear  that  ranking  the  preferred  options  is 
independent from the choices made elsewhere. 

Multi-criteria  analysis  is  used  in  this  report  to  compare  the  different  options  within  each 
policy instrument. This methodology is chosen in particular due to the difficulty to quantify 
impacts and to take into consideration some distributional concerns. 

7.1.  Comparing the options for ID cards 

Effectiveness:  ID  SOFT  will  rather  effectively  contribute  to  tackle  some  of  the  root  causes 
(lack  of  awareness,  bureaucratic  procedures)  of  the  problems  (see  2.1)  but  not  completely 
address  the  problems  of  insufficient  acceptance  and  lacking  authentication  of  ID  cards 
because  format  and  security  of  ID  cards  will  not  be  upgraded  with  soft  law  measures. 
Promoting (optional) eID functionalities on ID cards can simplify the daily life of citizens as 
referred to by the opinion of the REFIT platform. 173 

Option ID 1) will demonstrate a high degree of effectiveness by a fair level of harmonisation 
of  format  and  security  features.  ID  1)  will  reduce  document  fraud  and  identity  theft  and 
reduce  hassle  costs  and  administrative  burden  on  citizens.  There  will  be,  for  example,  less 
uncertainty among airlines as to whether a document makes the holder eligible to travel. This 
will simplify the daily life for citizens and also effectively save time and costs (cut red tape) 
for businesses. 

Option  ID  2)  will  address  the  same  issues  as  option  ID  1)  and  even  be  more  effective  at 
achieving  the  specific  objectives  of  reducing  document  fraud  and  improving  document 
authentication.  As  a  specific  feature  substantially  contributing  to  combating  crime  and 
improving security,  fingerprints  will be obligatory  and ID cards will  be further harmonised. 
This will simplify the work of stakeholders, such as border control officials and private sector 
service providers.  

Option ID 3) will establish the same layout and same security features for ID cards as under 
ID 2),  but  will  not  address  the  specific  objectives  as  effectively  as  ID  1)  and  ID  2),  since 
national ID cards will still co-exist alongside the voluntary EU ID card.  

173 REFIT Platform Opinion on the submission by a citizen (LtL 242) on Identity and Travel Documents, 7 June 
2017. 

49 

 
 
 
                                                 
Efficiency:  Whereas  the  efficiency  of  ID  SOFT  is  variable  depending  on  the  activity 
implemented and adaptable to the specific Member State needs, ID 1) will involve some costs 
for several countries (changing substrate, printing, etc.) but also create substantial intangible 
benefits (see section 6.1).  

With  slightly  higher  benefits  than  ID 1),  ID 2)  will  bear  substantially  higher  costs  for 
implementation  and  management  (mainly  due  to  mandatory  fingerprints)  and is,  as  a  result, 
also less efficient than ID 1).  

ID 3)  will  be  less  efficient  than  ID  1)  and  2)  because  the  benefits  from  introducing  an 
additional  EU  ID  card  with  mandatory  fingerprints  but  not  harmonising  at  all  the  national 
ones will not substantially outweigh the costs. ID 3) does not bear phasing out costs like ID 1) 
and  2)  but  the  general  implementation  costs  are  almost  as  high  as  for  ID 2),  because  a 
harmonised card including the management of fingerprint data needs to be established.  

In the long run, all legislative options ID 1) to 3) might reduce some costs due to economies 
of scale within the production process. 

Coherence:  Both  non-legislative  and  legislative  ID  options  will  be  compatible  with  the 
existing  EU  framework  of  initiated  EU  policy  initiatives,  such  as  the  initiative  launched  to 
establish a European Social Security Number.  

The  coherence  of  the  proposed  soft  law  measures  is  also  ensured,  as  they  are  delivered 
through  existing  forums  to  minimise  costs  and  to  avoid  a  disproportionate  administrative 
burden.  Using  non-legislative  measures  to  promote  eID  functionality  is  coherent  with  the 
existing  framework,  such  as  eIDAS.  eIDAS  is  aligned  with  the  objectives  of  the  Digital 
Agenda for Europe, which plays a key role in achieving growth in the EU.  However, recent 
events174 have also shown that very strong safeguards are required to avoid hacking and fraud 
of national cards with eID functionality (optional feature under all legislative options). 

The coherence of option ID 1) will be high as no major amendments to the current situation 
are  foreseen.  Furthermore,  most  ID  cards  in  most  countries  already  meet  most  of  the  basic 
requirements.  For  option  ID  1)  and  ID  2)  documents  will  basically  follow  the  standards  as 
established for passports175 or residence permits176.  

ID  1)  and  ID  2)  would  be  particularly  coherent  with  the  existing  EU  Action  Plan  on  travel 
document fraud, as they would address the security gap for ID cards. The Action Plan, as well 
as the related Council Conclusions, do not specify whether fingerprints should be mandatory 
or not. Therefore both ID 1) and ID 2) can be regarded as equally coherent.  

Policy  Option  ID  3)  could  lead  to  incoherence  with  current  national  ID  cards  and  to 
duplication, as national ID cards and EU ID cards will both need to be valid in parallel.177  
Proportionality178: ID SOFT) will rely on existing frameworks for their implementation. Soft 
law does not require Member States to change existing legislation or to fundamentally change 

174  http://www.zdnet.com/article/estonias-id-card-scrisis-how-e-states-poster-child-got-into-and-out-of-trouble/ 
and http://www.zdnet.com/article/id-card-security-spain-is-facing-chaos-over-chip-crypto-flaws/  
175 Council Regulation (EC) No 2252/2004 
176 ‘Uniform format’ as prescribed by Regulation 1030/2002 
177 This would not be the case however if one document would only be used for travel purposes and the other for 
other purposes within the country that issued the document. 
178  The  proportionality  test  ensures  that  any  policy  measure  is  limited  to  what  is  necessary  to  achieve  its 
objectives.  During  the  consultation  several  Member  States  stated  that  matters  related  to  ID  cards  touch  upon 
national sovereignty and that far-reaching EU action in this field would not be proportionate to the aims being 

50 

 
 
                                                 
 
national  practices.  Simultaneously  a  positive  effect  can  be  expected  since  awareness  and 
knowledge of all involved stakeholders will be improved.  
Option  ID 1)  will  only  require  changes  to  a  relatively  small  number  of  Member  States179 
while potentially having a major positive impact in clarifying the status and functionality  of 
ID cards. It will require citizens to provide biometric data in the form of a photograph (which 
is in no case a new requirement). Nevertheless, as this will be compulsory in those states for 
which ID cards are compulsory, adequate safeguards will be required. 

Option ID 2) goes beyond ID 1) in its ambition to harmonise having a higher positive effect 
on security but also creating higher cost and requiring additional safeguards to respect certain 
fundamental  rights  (in  particular  the  right  to  the  protection  of  personal  data)  (see  above 
Effectiveness and section 6.1).  

Under options ID 2) and ID 3) citizens will be required to provide their fingerprints when ID 
cards are requested. This obligation interferes with the fundamental rights to privacy and data 
protection180.  While  in  the  Schwarz  case  the  CJEU  held  that  the  interference  with  regard  to 
passports is proportionate to the objective of maintaining security, in the context of ID cards 
the threshold for satisfying the necessity test may be higher, because ID cards are compulsory 
in some Member States in which fingerprints are not currently collected.  

In terms of document security, a completely harmonised common document, like under ID2 
or 3), could also mean that the impact of falsification will be much greater than if only one 
country’s document were falsified. An analogous issue is created through the implementation 
of a common contactless chip standard. 

Representing  an  additional  and  not  a  replacement  card  regime,  policy  option  ID  3)  also 
highlights the question of where the data contained on the ID cards will be stored.181 Given 
existing Member State practices which do not require centralisation of storage, the outcomes 
envisaged under ID 3) can clearly be achieved without them. However, ID 3) is a mere add-on 
and does not considerably change and influence the system in relation to national ID cards. It 
will  not  address  most  of  the  problems  defined  and  encountered  by  stakeholders.  ID  3)  is 
therefore the least proportionate option. 

pursued. At the same time, it should be underlined that an attempt by a Member State to save costs by reducing 
the  security  features  on  the  ID  and  residence  documents  they  produce  may  have  negative  consequences  on 
security for other Member States and of the security of the Union as a whole.  
Interference by a public authority with individuals’ right to data protection may be necessary in the interest of 
national security, public safety or the prevention of crime (See Art. 53 EU Charter on Fundamental Rights and 
Art.  8,  Convention  for  the  Protection  of  Human  Rights  and  Fundamental  Freedoms  (ETS  No  5),  Council  of 
Europe,  4.11.1950.).  The  jurisprudence  of  the  Court  of  Justice  and  of  the  European  Court  of  Human  Rights 
establishes the conditions under which such restrictions may be justified: if it is lawful, if it pursues a legitimate 
aim and if it is necessary in a democratic society. Interference with the right to privacy is considered necessary if 
it answers a pressing social need, if it is proportionate to the aim pursued and if the reasons put forward by the 
public authority to justify it are relevant and sufficient (See Marper v the United Kingdom, European Court of 
Human Rights judgment, Strasbourg, 4.12.2008.). As noted above, these principles have been interpreted in the 
context of the data requirements of the current Passports Regulation (Council Regulation (EC) No 2252/2004). 
179 Only, EL, FR and IT will need to phase out a considerable number of ID cards before their expiry date under 
ID 1) , as well as ID 2). 
180 Only, EL, FR and IT will need to phase out a considerable number of ID cards before their expiry date under 
ID 1) , as well as ID 2). 
181 Storing all data in a central database at the EU level should be discounted from the outset: currently many 
Member States do not even have central registries for their own citizens, and such a centralised store would raise 
great data protection concerns. 

51 

 
 
                                                                                                                                                         
Table 7.1 Comparison of the options within the Policy Option ID 

Criteria 

BL 

ID SOFT) 

ID 1) 

ID 2) 

ID 3) 

Effectiveness towards the objectives 

Improve authentication of documents and reduce 
document fraud 

Improve acceptance of documents 

Simplify daily life for citizens and cut red tape  

Efficiency 

Costs 

Benefits 

(COSTS VS BENEFITS) 

Coherence (with other policies

182

) 

Proportionality  

0 

0 

0 

0 

0 

0 

0 

+ 

+ 

+ 

-/0 

+ 

0/+ 

+ 

+/++ 

++/+++ 

+++ 

+/++ 

++ 

++ 

- 

++/+++ 

+/++ 

+ 

+ 

++ 

++ 

-- 

+++ 

+ 

+ 

0/+ 

+/++ 

+/++ 

- 

+/++ 

0/+ 

0 

- 

Note: 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

As  a  result  of  the  comparison  of  the  options  (see  Annex  4  for  a  detailed  assessment  on  the 
comparison of the options based on a multi-criteria analysis), there are two optimal ranking 
solutions where ID 1) always ranked first. The two optimal ranking solutions are: 

  Option  ID  1),  followed  by  ID  2),  followed  by  ID  SOFT),  followed  by  ID  3)  and 

followed by the baseline scenario; 

  Option  ID  1),  followed  by  ID  2),  followed  by  ID  3),  followed  by  ID  SOFT)  and 

followed by the baseline scenario. 

Therefore, ID 1) is identified as the preferred option in both optimal solutions. Although less 
effective  than  ID  2),  it  is  more  efficient  and  proportional.  ID  1)  also  address  all  specific 
objectives satisfactorily and leaves the Member States as much scope as possible for national 
decisions about a document that they regard as an “expression of the identity of their country” 
(see Annex 2 – section 3 stakeholder views).  

7.2.  Comparing the options for residence documents 

Effectiveness:  Soft  law  measures  under  RES  SOFT  will  contribute  to  addressing  the 
problems.  Nevertheless  the  root  causes  of  the  problems  (differences  and  inconsistency  of 
documents, missing security features in particular for TCN FAM cards) will not be effectively 
targeted (see section 6.2).  

Progressive  legislative  harmonisation  of  format  and  security  of  residence  documents  (from 
RES  1)  to  3)  will  mean  increasing  effectiveness,  as  this  will  also  increasingly  reduce 
document fraud and  acceptance and authentication of documents by facilitating the work of 
national authorities.  

182 In particular Fundamental rights, data protection and digital policies 

52 

 
 
 
 
 
                                                 
This will mean that – given the order of magnitude of residence documents for EU citizens in 
circulation – options RES 1) and RES 2) will solve the same share of the problems identified 
in  2.1  for  residence  documents  of  EU  mobile  citizens.  However,  RES  2)  will  also  target 
security  gaps  in  TCN  FAM  cards,  which  have  an  important  function  as  visa  waivers  at  the 
external borders. RES 2) is thus more effective than RES 1).  

RES 3) will address format and security features of all documents and will thus address all the 
root causes of the problems of all the residence documents. The increased streamlining of all 
documentation will mean that authorities will be more familiar with all documents regardless 
where they are issued.  

Under RES 3) the initiative’s specific objectives (reduce document fraud, improve acceptance 
and authentication of documents, raise awareness and simplify the lives of all target groups) 
will  be  addressed.  There  will  therefore  be  greater  effectiveness  in  carrying  out  authenticity 
checks, which might be quicker. The overall harmonisation under RES 3) will also potentially 
further simplify the daily life for citizens. However, at the same time harmonising residence 
documents  with  different  function  and  use  can  also  cause  some  confusion  which  would 
outweigh some of the additional positive effects by RES 3). This means that overall RES 2) 
and  RES  3)  are  equally  effective  as  regards  their  potential  to  simplify  the  daily  life  for 
citizens.   

Efficiency:  RES  SOFT)  is  adjustable  to  the  needs  of  a  Member  State  and  is  therefore 
relatively  cost  neutral.  RES  1)  will  not  create  any  significant  compliance  costs,  since 
production standards will not need to be changed.  

Some  Member  States  already  use  the  uniform  format  for  TCN  FAM  cards,  which  will 
therefore trigger some but not substantial compliance costs under RES 2). If only one type of 
document needs to be printed and only adapted to the specific residence status, the authorities 
will  only  need  one  type  of  machinery,  one  procedure  and  one  type  of  material  to  issue 
different  documents.  In  practice,  the  uniform  format  for  residence  documentation  should 
contain  all  the  necessary  information  and  meet  very  high  technical  standards,  in  particular 
regarding safeguards against counterfeiting and falsification. The format will also be suited to 
use by all the Member States and bear universally recognisable harmonised security features, 
visible to the naked eye.183  

If this is extended to the other types of documents related to residence status (RES 3) there 
will be even greater economies of scale. However there will also be very substantial and much 
bigger investment (costs) in changing printing techniques, etc. for all other documents. This 
will  by  far  outweigh  the  additional  benefits  of  RES  3)  and  thus  make  this  option  less  cost-
efficient than all the others. 

Coherence and proportionality: The remarks made with respect to ID cards about the issue 
of  proportionality  in  the  context  of  interference  with  fundamental  rights  as  enshrined  in  the 
Charter, and in particular the fundamental rights to private and family life and the protection 
of personal data, apply mutatis mutandis to this section. 

The more the residence documents across Member States are harmonised (in ascending order 
from  RES 1)  to  3)  the  more  likely  it  is  that  the  problems  described  in  section  6.2  will  be 
addressed  (see  effectiveness  above).  Improved  security  of  the  TCN  FAM  cards  (with  their 
specific  function)  will  be  achieved  by  RES  2)  and  RES  3)  by  mandatorily  adopting  the 

183 Recital 5 of Council Regulation 1030/2002. 

53 

 
 
                                                 
uniform format. This will be particularly coherent with the treatment of other TCNs receiving 
a  residence  permit.  Simultaneously  RES  2)  and  RES  3)  will  guarantee  that  the  TCN  FAM 
cards are properly marked, so that the specific rights of TCN family members under Directive 
2004/38/EC are properly flagged.  

As noted in section 6, creating a level playing field in the treatment of TCNs with respect to 
the  application  of  the  residence  permit  format  does  mean  that  in  some  Member  States 
biometric data will have to be collected and stored, and in some cases this will be for minors 
aged over 6 years. While this does mean that particular case would have to be taken to ensure 
that adequate safeguards are in place if these options are implemented, the requirements for 
biometric  data  would  not  go  beyond  those  already  in  place  under  the  residence  permit 
regulation, and are necessary in that context. 

Directive  2004/38/EC  puts  each  specific  residence  document  type  (e.g.  registration 
certificates, TCN FAM residence  cards)  in the specific context of the provisions of the free 
movement acquis. A complete harmonisation of all residence documents will therefore  only 
make sense if the objectives and provisions related to those residence documents, as referred 
to in Directive 2004/38/EC, are the same. This is not the case and reduces the coherence and 
proportionality of a solution like under RES 3) requiring harmonisation of all documents, no 
matter what their use is. 

Table 7.2 Comparison of the options within the Policy Option RES 

Criteria 

BL 

RES SOFT) 

RES 1) 

RES 2) 

RES 3) 

Effectiveness towards specific objectives 

Improve authentication of documents and reduce 
document fraud 

Improve acceptance of documents 

Simplify daily life for citizens and cut red tape  

Efficiency 

Costs 

Benefits 

(COSTS VS BENEFITS) 

Coherence (with other policies) 

Proportionality  

0 

0 

0 

0 

0 

0 

0 

0 

0/+ 

0/+ 

0/+ 

0 

+ 

+ 

0/+ 

0/+ 

+/++ 

+/++ 

+/++ 

++ 

++ 

++ 

++/+++ 

++/+++ 

++ 

-/0 

- 

--/--- 

+/++ 

++/+++ 

+ 

+ 

+ 

+/++ 

+ 

+ 

+++ 

0/+ 

0/+ 

0/+ 

Note: 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

Based on the multi-criteria analysis methodology for comparing the different options, in the 
two  optimal  ranking  solutions  RES  2)  always  ranked  first  (for  more  details  on  the 
methodology  see  Annex  4).  Therefore,  despite  option  RES  3)  being  slightly  stronger  in 
effectiveness,  option  RES  2)  is  selected  as  preferred  option  due  to  its  better  scores  on 
efficiency, coherence and proportionality. 

7.3.  Comparing the options for PROCESS 

Effectiveness; PROCESS SOFT) will simplify the life of citizens by promoting more speedy 
and comfortable ways for requesting ID and residence documents, Adding the possibility to 
request  ID  cards  via  the  consular  network  in  PROCESS  1),  will  be  even  slightly  more 

54 

 
 
 
effective  and  promote  the  general  policy  objectives  of  facilitating  free  movement.  Both 
options  will  –  to  a  lesser  extent  –  also  contribute  to  improving  security  via  a  very  limited 
impact on document fraud (see also section 6.3).  

Efficiency:  Overall,  the  costs  related  to  both  PROCESS  options  are  considered  minimal. 
Promoting the use of an online tool for requesting ID and residence cards can be adapted to 
each  Member  State’s  needs.  The  costs  to  the  countries  currently  not  providing  ID  card 
renewal via consular networks can be regarded as higher but still limited. The benefits should 
outweigh the costs for both options, in particular for citizens living abroad. As a result both 
options under PROCESS can be regarded as equally efficient. 

Coherence:  Option  PROCESS  SOFT)  will  be  coherent  with  the  EU  e-Government  Action 
Plan  2016-2020.  PROCESS  SOFT)  is  also  compatible  with  the  possibility  to  request 
information  about  the  rights  and  obligations  linked  to  ID  and  residence  documents,  as 
proposed through the single digital gateway (SDG).  
The original proposal to the Single Digital Gateway184 envisaged that citizens will be able to 
request and renew inter alia ID cards via the single digital gateway. However, this possibility 
was deleted during negotiations because Member States were concerned about abuse/fraud if 
these  procedures  were  fully  online and  also  because  some  Member  States  require biometric 
checks  etc.185  The  feature  to  require  all  Member  States  to  issue  ID  cards  through  consular 
networks set out in PROCESS 1) is thus not entirely coherent with the current framework in 
this respect.  

Proportionality: under PROCESS SOFT) the intensity of action will be adjusted to the needs 
of each Member State. PROCESS 1) will require a legal intervention into the Member States 
administrative procedures related to document issuance. This is hardly acceptable to Member 
States (see also coherence above). 

Table 7.3 Comparison of the options within the Policy Option PROCESS  

Criteria 

BL 

PROCESS SOFT) 

PROCESS 1) 

Effectiveness (towards objectives) 

Reduce document fraud 

Simplify daily life for citizens and cut red tape  

Efficiency 

Costs 

Benefits 

(COSTS VS BENEFITS) 

Coherence (with other policies) 

Proportionality  

0 

0 

0 

0 

0 

0 

0 

+ 

+ 

0 

+ 

+ 

+ 

+ 

+ 

++ 

-/0 

+/++ 

+ 

-/0 

- 

Note: 

The evaluation is based on a scale of 10 steps from very negative impact (---) to very positive impact (+++) 

"0" indicates no change (i.e. neutrality) 

184 COM 2017) 256 final: Proposal for a Regulation of the European Parliament and the Council on establishing 
a  single  digital  gateway  to  provide  information,  procedures,  assistance  and  problem  solving  services  and 
amending Regulation (EU) No 1024/2012 
185 Council document 8838/17 + ADD 1 

55 

 
 
 
 
 
 
                                                 
As a result of the comparison of options using the multi-criteria analysis (for more details see 
Annex  4)  option  PROCESS  SOFT)  ranks  first  in  the  unique  optional  ranking  solution,  in 
particular because of its higher scores in coherence and proportionality. 

7.4.  How  sensitive  are  the  preferred  options  to  using  different  weights  for  the 

criteria? 

The multi-criteria analysis presented uses equal weights between the individual criteria. When 
equal  weights  are  used  between  the  individual  criteria,  effectiveness  (adding  the  three  sub-
criteria)  gets  the  highest  weight  (50%  for  ID  and  RES  options  and  40%  for  PROCESS 
option). A sensitivity test was carried out to see if the conclusions of the multi criteria analysis 
are stable when applying different weights (see Annex 4). 

The preferred options are kept, even if 

Equal weights are used between the categories of criteria (25% each for effectiveness, 

(i) 
efficiency, coherence and proportionality) 

(ii) 

Efficiency gets the highest weight (50% weight used for efficiency) 

(iii)  Coherence gets highest weight (50% weight used for coherence) 

In case the proportionality criterion gets the highest weight, only the preferred option for ID 
policy area changes (ID SOFT instead of ID 1). For the other policy areas (RES and SOFT) 
the previous results of the preferred option are kept. 

A further test is to look at the specific objectives of this initiative and increase the weight of 
the individual effectiveness sub-criteria. We can focus on the options presented towards the: 

(i) 

Security specific objective:  

Option ID 1) and Option RES 2) are the preferred options. This outcome changes if a weight 
around  1/3  is  given  to  the  criterion  ‘Improve  authentication  of  documents  and  reduce 
document  fraud’  (and  all  the  other  criteria  with  equal  weight).  In  this  case,  Option  ID  2) 
(including mandatory fingerprints) and Option RES 3) (harmonising all residence documents) 
are  the  preferred  options.  PROCESS  SOFT  is  still  the  preferred  option  under  these 
circumstances. 

(ii) 

Free movement objective:  

Option  ID  1)  is  the  preferred  option  unless  the  weight  attributed  to  the  criterion  ‘Improve 
acceptance of documents’ is very close to 1. Option ID 2) would be in this case the preferred 
option.  Regarding  RES  option,  RES  1  is  the  preferred  option  unless  a  weight  around  1/3  is 
given to the criterion. RES 3 would be the preferred option in this case. 

8 

PREFERRED OPTION 

8.1.  The preferred options 

Following the comparison of policy options in section 7, Table 8.1 shows the options found 
most suitable to promote the objectives of improving security at borders and internally within 
Member States, and freedom of movement.  

Table 8.1: Overview about the preferred option(s) and the measures included 

Policy options 

Non-legislative measures  Legislative measures 

ID cards (p.25) 

ID SOFT)  

ID 1) 

56 

 
 
Residence documents (p.29) 

RES SOFT) 

RES 2) (includes RES 1) 

Process (p.30) 

PROCESS SOFT) 

- 

The  selected  policy  options  follow  a  set  of  minimum  standards  for  document  format  and 
security  and  thus  make  border  control  more  effective  and  more  secure.  Regarding  free 
movement, the preferred policy options diminish ‘hassle costs’ to EU citizens when crossing 
the border and when accessing private and public sector services.  

Non-legislative  measures  will  allow  for  adaptable  tailor-made  support  for  the  work  on 
documents, but also on the administrative processes regarding issuance, renewal and handling 
of  documents.  Soft  law  support  will  also  connect  the  discussion  about  documents  in  the 
context of security and free movement to other identity management, sectoral debates such as 
in taxation, social security or student mobility.  

The  issuance  of  ID  and  residence  documents  is  a  national  prerogative  and  this  will  remain 
unchanged. As shown above, the selected options respect the principles of proportionality and 
subsidiarity,  as  they  do  not  disproportionately  intrude  on  national  policy,  requiring  more 
modest harmonisation than, e.g., the uniform EU driving licence.  

In the long run a potentially large number of ID card holders (more than 300 M) will profit 
from a more secure ID card format but only a very limited number of people (around 15 M) 
will be required to quickly renew their cards and the respective Member States' obligation to 
hold an ID card from a certain age (see Annex 8 Figure 8.1). 

8.2.  Combined impact of the preferred options 

The principal impact analysis of the preferred options is described in the previous sections 6 
and 7. Here only the aggregate impacts of the preferred options compared with the baseline 
scenarios (no EU intervention) are presented. 

Phasing in 

After entry into force of legislation all new ID cards and residence documents will need to be 
produced  based  on  the  requirements  in  line  with  the  preferred  option and  the  more  detailed 
technical specifications to be laid down by a Technical Committee186.  
A  few  countries187  produce  documents  which  already  fully  comply  with  those  proposed 
requirements.  All  the  other  Member  States  will  need  to  upgrade  their  new  ID  cards,  TCN 
FAM documents, and residence documents to mobile EU citizens.  

This  may  have  a  financial  impact,  although  compared  to  the  baseline,  the  additional  costs 
related to a simple upgrade might not be substantial. For example, the upgrade of biographical 
data, such as in the case of the German ID card, or the title, such as in the case of IE, should 
have no significant cost impact. Similarly, the material cost of an ID card with a contactless 
chip  will  not  be  significantly  higher  than  for  a  card  with  a  contact  chip  (such  as  in  FI). 
However, the shift from a paper ID card without biometrics to a plastic card with biometrics, 
such  as  in  EL,  will  obviously  mean  higher  cost.  The  costs  related  to  new  card  reader 
infrastructure  and  an  additional  handling  of  biometric  data  could  be  even  more  expensive. 

186  See  in  a  similar  way  Art  2  and  5  of  the  Council  Regulation  (EC)  No  2252/2004  (security  features  and 
biometrics in passports). 
187  BG,  CY,  HU,  LV,  LT,  LU,  and  NL  for  ID  cards,  DE,  LT,  NL  (and  probably  EL,  IE,  PT,  RO  which  have 
recently introduced changes that need to be monitored) for TCN FAM cards; CY, NL, RO, and SI for residence 
documents issued to EU citizens. 

57 

 
 
                                                 
However,  since  all  Member  States  already  handle  their  passports  under  the  technical 
conditions set under the preferred option for ID cards, any additional costs in this regard will 
be very limited. 

For TCN FAM cards the upgrade for at least 21 countries will be to meet the requirements of 
the 'uniform format' as introduced by the respective legislation on residence permits.188 This 
will range from simply adding the title in another EU language (e.g. SK) which will have no 
relevant  cost  impact  to  switching  from  an  ordinary  paper  card  to  the  fully  fledged  card 
respecting the 'uniform format' (e.g. AT). 

The simple upgrade of the residence documents for mobile EU citizens, i.e. adding either the 
document  number,  the  correct  title  of  the  document  and  its  translation,  or  the  date/place  of 
issue, in 24 Member States will not have any relevant financial impact. There will be no other 
changes in format and production required from Member States. 

See  Annex  8,  Figures  8.2-3  and  Tables  8.2-4  for  a  more  detailed  analysis  of  the  preferred 
option's impact for each document type and Member State. A more detailed presentation per 
Member State ("country fiches") is included in Annex 10.189  

Phasing out 

A phasing out is foreseen for ID cards and TCN FAM cards but not for residence documents 
issued  to  EU  citizens  (e.g.  registration  certificates),  as  this  would  create  legal  uncertainties 
regarding  the  free  movement  acquis.  The  phasing  out  regime  simply  serves  the  purpose  of 
accelerating  the  upgrade.  Hence,  a  quicker  phasing  out  of  old  documents  is  foreseen  where 
the requirements regarding security are more urgent. Should it be decided to further accelerate 
the phasing out, this would imply higher and increasing costs (see also Annex 4 section 1).  

For ID cards phasing out within 10 years will be required for AT, BE, CZ, EE, FI, DE, ES, 
HR, IE, MT, PL, PT, RO, SK, SI, SE. For most ID cards the validity of cards is already up to 
10  years.  This  means  the  phasing  out  will  not  create  additional  costs  because  they  will  be 
naturally replaced within 10 years.  

BE, CZ, ES, RO, SK, SI however have produced cards with longer validity for senior citizens 
(see Annex 5, Table 2.2). The same applies to BG and HU whose new ID cards are compliant 
with the preferred option but nevertheless some old cards issued to senior citizens will need to 
be replaced. These cards will therefore need to be phased out earlier than foreseen which will 
have a financial impact. However, this will concern a very limited part of the population, as, if 
we count the deadline for adoption of the Regulation (2 years), finalisation of the standards by 
a committee (1 year) and the 10 years phasing out, only seniors above 68 (RO), 71 (for BG), 
73  (SK),  78  (HU),  83  (CZ,  ES  and  SI)  and  88  (BE)  will  be  concerned  in  the  respective 
Member States. 

Phasing  out  within  five  years  will  be  required  for  ID  cards  which  do  not  have  a  fully 
functional  machine  readable  zone  (MRZ)  allowing  for  basic  interoperability  and  a  form  of 
automated checks of EU citizens’ identification. This will impact on EL, FR and IT, since ID 
cards will need to be renewed considerably faster than the 15 years foreseen in EL and FR and 
the 10 years foreseen in IT. 

188  Regulation  (EU)  2017/1954  of  the  European  Parliament  and  of  the  Council  of  25  October  2017  amending 
Council  Regulation (EC)  No 1030/2002 laying down  a uniform  format  for residence permits  for  third-country 
nationals (amended in 2017) 
189  The  impact  of  the  non-legislative  measures  is  not  included,  since  these  measures  are  non-binding  and 
adjustable to each Member State’s needs. 

58 

 
 
                                                 
For  TCN  FAM  cards  phasing  out  within  five  years  will  be  required  when  the  TCN  FAM 
cards are not currently based on the uniform format for residence permits. This will create no 
additional  financial  impact  for  the  phasing  out  of  TCN  family  member  residence  cards 
because their validity is always five years and they will be therefore naturally replaced in this 
time frame.  

However, phasing out TCN FAM permanent residence cards (which are usually valid for 10+ 
years) within five years will bring additional costs in at least 14 states (AT, BG, CY, CZ, DK, 
ES, FI, HR, HU, IT, LU, PL, SI and UK). EL, IE, PT, and RO have announced that they are 
currently implementing the uniform format but if they do not manage in time, this will also 
affect their phasing out of TCN FAM permanent residence cards. 

Tables 8.5-7 in Annex 8 give an overview about any compliance cost for phasing in and out 
regimes  for  each  document  type  and  Member  State,  including  quantification  if  possible.  A 
broad  analysis  of  cost  savings  is  provided  in  section  8.3  (REFIT).  An  overview  of  cost  and 
benefits (quantified as far as possible) is presented in Annex 3. For a cost estimate of a range 
of freely adjustable soft law activities see Annex 3 and 4. 

The wider economic and social impacts of the preferred option have been discussed in the 
previous sections 6 and 7.  

The legislative proposal affects fundamental rights in five main areas: 

i. 

to citizens liberty and security (Article 6 Charter FEU),  

to their private and family lives (Article 7), and the protection of their personal data 

ii. 
(Article 8), 

iii. 

iv. 

v. 

to the integration of persons with disabilities (Article 26 CFEU), 

to their political rights (Articles 39-40 and 44 CFEU), 

to their freedom of movement and residence (Article 45 CFEU). 

The elimination of the problems identified in the exercise of free movement and to security 
through  the  non-legislative  and  legislative  measures  proposed  naturally  yield  a  positive 
impact  on  liberty  and  security  and  free  movement  rights.  The  protection  of  disability  rights 
and political rights can be improved in principle under the non-legislative measures if they are 
included as an objective of the enhanced coordination and dialogue pursued. 

The provisions on ID cards and on uniform format residence cards including biometrics affect 
the protection of private life and personal data (Article 7 and 8 CFEU), because they involve 
the collection, storage and processing of personal data, including biometric data (facial image 
and potentially fingerprints) about the bearer of the card. 
EU  law  on  data  protection190  applies  to  personal  data  processed  in  application  of  any 
regulation related to ID and residence documents including the right of data subjects to have 
access to personal data processed in their documents and have them corrected. The protection 
of  fundamental  rights  is  ensured  principally  by  safeguards  which  are  based  on  or  directly 
reference  to  existing  provisions  of  identical  or  parallel  legal  frameworks  for  achieving  the 
same  results,  either  in  national  ID  card  schemes,  or  through  alignment  to  other  EU 
instruments including the Passport Regulation framework. 

190 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection 
of natural  persons with regard  to  the processing of personal  data  and on  the  free  movement  of  such  data,  and 
repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance). 

59 

 
 
                                                 
The question of data protection is much more acute in how and the extent to which Member 
States will store biometrics in national databases of identities and issued cards. The preferred 
option  does  not  tackle  this,  and  the  civil  registry  databases  are  not  within  the  scope  of  any 
future  proposal.  In  any  case  the  initiative  shall  not  provide  a  legal  basis  for  the  centralised 
storage of data collected thereunder or for the use of such data for purposes other than that of 
the  identity  of  the  holder  by  means  of  directly  available  comparable  features  when  the 
passport or other travel documents are required to be produced by law (as set out e.g. in Art. 4 
Regulation 2252/2004). 

As regards the inclusion of fingerprints, account has to be taken of the case law of the Court 
of  Justice.  The  Court  concluded  in  C-291/12  ('Michael  Schwarz  v  Stadt  Bochum')  that 
although the taking and storing of fingerprints in passports constitutes an infringement of the 
rights  to  respect  for  private  life  and  the  protection  of  personal  data,  the  inclusion  of 
fingerprints in passports is lawful given the general objective of preventing illegal entry into 
the  EU  and  the  protection  of  fraudulent  use  of  passports.  However,  given  that  the  ID  cards 
serve  more  purposes  than  crossing  the  border  and  given  the  different  traditions  in  Member 
States for the use of ID cards, it is not self-evident that the same conclusion could be drawn.  

The  collection  of  personal  data  under  this  option  should  be  implemented  with  strong 
fundamental rights checks, guarantees and balances and ensure compliance with the Charter 
of  Fundamental  Rights  of  the  European  Union  and  EU  data  protection  legislation. 
Particularly, insofar as this option entails the mandatory collection of fingerprints relating to 
minors,  measures  shall  provide  for  robust  fundamental  rights  safeguards  and  protection 
measures  in  light  with  Article  24  of  the  EU  Charter.  The  preferred  option  would  ensure 
safeguards and guarantee the data subject's right applicable under GDPR including the right to 
effective remedy. 

For TCN FAM residence documents, the preferred option is precisely aligned to the existing 
arrangements for the issuance of residence permits for TCN, where data on the cards issued, 
including fingerprints, are specifically encrypted and secured. This means that some Member 
States will begin collecting biometric data for the TCN family member of EU citizens if their 
existing procedures did not provide for this, including for minors aged over 6 years 

The general safeguards to be provided for biometrics are: 

  For chip verification the chip shall contain a digital certificate, exchange of 

certificate (PKI); 

  Adequate state-of the art encryption level to protect data on the chip (Basic 

Access Control for alphanumeric data and facial image; Extended Access Control 
for fingerprints if included); 

  The data contained in the chip must be described in a closed list; 

  A purpose limitation should be included, such as “biometric features in passports 
and travel documents shall only be used for verifying: a) the authenticity of the 
document; b) the identity of the holder by means of directly available comparable 
features when the passport or other travel documents are required to be produced 
by law; 

  Exceptions and safeguards must be provided for cases where fingerprints are 

taken (age limitation as referred to by the Passport Regulation); 

60 

 
 
  Furthermore,  Member  States  could  decide  to  exclude  central  storage  of  the 

fingerprints of their citizens and only store them on the chip.191 

  Ensure that the right to access, rectification and erasure of the data stored is fully 

applied.  

The potential of the ID card provisions to facilitate EU-wide mutual recognition of electronic 
identification in access to public and private services is an additional consideration which was 
taken into account when preparing these safeguards. When used to accessing digital services 
and to secure information stored on the card the following requirements shall apply: 

  To enable eID functionalities, cards need to be compliant with the assurance levels 

defined in the EU framework (Art 8 eIDAS Regulation and Commission 
Implementing Regulation 2015/1502)192; 

  Data used via such eID functionalities must be clearly separated from the 

biometric data;  

  Such cards shall contain a digital certificate; 

  Certificates must be exchanged; 

The  cost  of  the  safeguards  for  biometrics  should  be  comparable  to  the  passport  and  the 
residence permit framework. Moreover, basic infrastructure and knowledge can be re-applied 
to  ID  cards  and  TCN  FAM  residence  cards.  Nevertheless  the  exact  costs  for  biometrics,  as 
well  as  for  the  eID  management  cannot  be  quantified,  as  Member  States  did  not  share  any 
basic data that could be used to model the cost.  

The harmonisation of the very limited amount of data for other residence documents (for EU 
citizens)  under  the  preferred  option  will  not  change  the  requirements  for  data  protection. 
Apart  from  the  name  of  the  holder,  which  is  already  an  indispensable  feature  of  any 
document,  the  required  minimum  data  proposed  (title  of  the  document,  document  number, 
place and date of issue…) are administrative data which aim to increase the acceptance of the 
documents by other stakeholders. Other optional personal data of the document holder will be 
processed according to usual data protection requirements.  

8.3.  REFIT (simplification and improved efficiency) 

REFIT Cost Savings – Preferred Option(s) 
Description 

Amount 

Annual cost savings for 
accelerated border checks 
across EU-28 (recurrent)* 

Annual cost savings for 
accelerated pre-boarding 
checks across EU-28 

EUR 17.1M 

EUR 12.4M 

Comments 

Figures drawn from CSES study 
estimates 
Beneficiaries: Public administration 
(border guards) 

Figures drawn from CSES study 
estimates 
Beneficiaries: Businesses (airlines) 

191 Some national implementations of biometrics in ID already provide safeguards as we suggest, and indeed take 
further steps, such as in Germany, where fingerprints are only stored and processed for the purposes of ID card 
production, and subsequently only stored on the ID card itself, with all other copies of this biometric information 
being destroyed (no central database). 
192 See FN 119. 

61 

 
 
                                                 
(recurrent)* 

Annual cost savings for 
accelerated document 
checks across EU-28 
when opening a bank 
account (recurrent)* 

Cost savings through 
improved document 
quality of TCN FAM 
cards (recurrent) 

Reduced hassle costs 
through improved 
acceptance of more secure 
documents (recurrent) 

Reduced hassle costs 
through swifter and more 
efficient processes for 
requesting and renewing 
ID and residence 
documents (recurrent) 

Reduced hassle costs 
through better awareness 
of document formats and 
the rights linked to the 
documents (recurrent) 
* See CSES study 

EUR 3.9M 

Figures drawn from CSES study 
estimates 
Beneficiaries: Businesses (banks) 

Fewer rejections of TCN family 
members at EU borders resulting in 
reduced costs to travellers; reduced 
handling and compensation payments 
for authorities and airlines; reduced 
denial-of-boarding costs (lost sale) for 
airlines. 

Quicker, more reliable access to 
relevant public and private services, 
reduced administration, staff training 
and business risk costs, reduced costs 
of fraud, increased opportunities to 
provide services to non-nationals 

Not quantifiable – border authorities 
and airlines do not collect such data 
Beneficiaries: citizens, businesses 
(especially airlines through liability 
for unjustified denial of boarding) 

Not quantifiable – while some 
indications of costs were obtained for 
certain elements, most was either 
commercially sensitive or not 
provided by national authorities. 
Beneficiaries: citizens, business, 
public administration 

Streamlined online processing reduces 
staff and administration costs, reduces 
costs of providing services abroad 
(where done), reduces need for 
journeys 

Not quantifiable – data on such 
document applications is not 
collected. 
Beneficiaries: citizens, public 
administration 

Reduced administrative and training 
costs, reduced costs of rectifying errors 
and compensating for rights wrongly 
denied, reduced loss of time and denial 
of service to citizens. 

Not quantifiable – data on such issues 
is not collected by national 
administrations or business. 
Beneficiaries: Citizens, businesses, 
public administration 

9  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

Implementation will be monitored in terms of the measures adopted at the EU and Member 
State  level  to  implement  the  legislative  and  non-legislative  measures  deriving  from  the 
preferred  option.  The  Commission  should  also  submit  an  implementation  report  to  the 
European  Parliament  and  the  Council  three  years  after  the  entry  into  application  of  the 
legislative measures.  

The  assessment  of  impacts  will  probably  have  to  rely  on  an  essentially  qualitative 
methodology  (e.g.  an  analysis  of  feedback  from  national  authorities  and  other  key 
stakeholders  such  as  citizens  groups  and  business  representatives)  on  the  extent  to  which 
implementation of the preferred policy option achieves the desired impacts and contributes to 
the achievement of the general aims of EU intervention. It is unlikely that it will be possible 
to establish a causal link between any quantitative data, for example, trends in the number of 
citizens  exercising  their  free  movement  rights,  and  the  measures  envisaged  in  the  preferred 
policy option on a specific document. 

It  is  envisaged  that  some  contextual  information  will  be  collected  on  a  periodic  basis,  i.e. 
developments  not  intentionally  related  to  the  policy  intervention,  although  they  may  be 
influenced by it. The key developments in this context relate to free movement, namely trends 

62 

 
 
with regard to cross-border mobility (for ID cards) and trends with regard to the number of 
non-nationals residing in different Member States (for residence documents).  

It  is  envisaged  that  national  authorities  will  introduce  monitoring  systems  so  that  the  data 
needed  for  the  key  performance  indicators  can  be  collected193.  Nevertheless,  it  will  be 
important  to  adopt  a  realistic  approach  to  monitoring  the  implementation  of  the  preferred 
policy option and not to over-burden national authorities. Consultations with Member States 
will be needed to determine the most appropriate frequency of data collection and reporting 
but  an  annual cycle could  be suggested. The data collected at Member  State level will then 
have to be analysed on the EU level.  

Apart  from  the  national  activities,  monitoring  at  the  EU  level  could  complement  this,  for 
example,  through  FRONTEX  or  Member  States  expert  groups.  Similarly,  some  EU-level 
coordination  of  national  monitoring  activities  will  be  needed  (e.g.  to  define  a  common 
template for data collection) as well as the collation and analysis of information provided by 
national authorities.  

It  should  be  noted  that  some  relevant  information  is  already  shared  at  the  EU  level.  In 
particular,  information  can  be  retrieved  to  a  certain  extent  from  the  FADO/PRADO  web 
registry. This provides an overview of documents in circulation at Member State level and it 
explains  the  features  included  in  these  documents.  However,  the  web  registry  is  not  always 
updated  for  all  Member  States  and  thus  the  system  needs  to  be  improved  to  serve  as  data 
source for the preferred option monitoring purposes.  

See Annex 9, Table 9.1 for a more detailed summary table. 

193 National authorities already gather some of the data needed to feed in the indicators system (e.g. number of 
residence documents issued per year, number of non-national EU citizens residing in a country, costs in relation 
to producing documentation (in some cases). However, more comprehensive data on for example border control 
checks  (e.g.  numbers  of  documents  that  were  not  valid,  statistics  on  e-gates,  etc.),  costs  of  digital  application 
systems,  costs  of  documents  in  circulation,  will  be  needed  with  approaches  being  harmonised  across  the  EU 
Member States.  

63 

 
 
 
                                                 
Annex 1: Procedural information 

1. Lead DG, Decide Planning/CWP references 

DG JUSTICE AND CONSUMER AFFAIRS 

DECIDE PLANNING: 2016/JUST/050 

CWP  2018:  REFIT  initiatives:  An  Area  of  Justice  and  Fundamental  Rights  Based  on 
Mutual  Trust  (9.ID  cards  and  Residence  Documents):  Legislative  Initiative  to  improve 
the  security  of  ID  cards  and  residence  documents  of  EU  citizens  and  of  their  non-EU 
family  members.  This  initiative  responds  to  an  opinion  of  the  REFIT  Platform. 
(legislative, incl. impact assessment, Art. 21 and/or 77(3) TFEU, Q2 2018) 

2. Organisation and timing 

Commission responds to an opinion of the REFIT platform in April and June 2017 and to 
the developments at Council level. 

A  Commission  inter-services  steering  group  (ISG)  was  established  in  September  2014 
for  preparing  this  initiative.  The  following  DGs  and  services  were  invited  to  the  inter-
services  group  included:  General  Secretariat  (SG),  Legal  Service  (SJ),  Migration  and 
Home  Affairs  (HOME),  Internal  Market,  Industry,  Entrepreneurship  and  SMEs 
(GROW), Education, Youth, Sport and Culture (EAC), Employment, Social Affairs and 
Inclusion (EMPL), Communications Networks, Content and Technology (CNECT), Joint 
Research  Centre  (JRC),  Mobility  and  Transport  (MOVE),  Human  Resources  and 
Security  (HR),  Taxation  and  Customs  Union  (TAXUD).  The  ISG  met  7  times  in  the 
period  from  September  2014  to  January  2018  and  an  additional  written  consultation 
before the submission to the RSB was held in January 2018. 

3. Consultation of the RSB 

The  Regulatory  Scrutiny  Board  (RSB)  received  the  draft  version  of  the  present  impact 
assessment report on 24 January 2018, as well as upon request a shortened version on 31 
January 2018.  

The  RSB  meeting  was  held  on  21  February  2018,  and  the  RSB  delivered  a  positive 
opinion on 23 February 2018. The table below shows how this report takes into account 
the RSB comments.  

RSB comment 

How it was incorporated in the IA 

(1) The report should present a more complete 
discussion  of  fundamental  rights  implications 
of  the  proposed  initiative.  In  view  of  the 
sensitive  nature  of  the  (biometric)  information 
that  would  be  stored  on  the  ID  and  residence 
documents, 
to  be  more 
the  report  needs 
specific  on  how  data  protection  would  be 
ensured.  It  should  describe  the  measures  and 
techniques  used  to  restrict  access  to  personal 
data.  Bearing  in  mind  the  differences  between 
Member States, it should also identify the costs 
for implementing safeguards, such as setting up 

of 

complete 

discussion 

the 
A  more 
fundamental  rights  implications  (in  particular 
on  data  protection)  has  been  incorporated  in 
section  8.2.  Safeguards 
and  mitigation 
measures,  as  well  as  techniques  to  restrict 
access to personal data are better described and 
explained.  

The  cost  related  to  these  measures  cannot  be 
quantified, as Member States do not share any 
such data with the Commission.  

64 

 
 
access  control  systems  with 
technical measures. 

the  relevant 

(2)  The  comparison  of  the  options  should 
reflect  in  how  far  the  choice  of  the  preferred 
option  changes  if  objectives  are  weighted 
the  multi-criteria  analysis. 
differently 
Reflecting  possibly  differing  outcomes  of  the 
analysis,  depending  on  political  preference, 
would  make  the  report  better  at  informing  the 
decision-making process. 

in 

The  report  could  better  motivate  the  scores  of 
the  options  in  Tables  7.1,  7.2  and  7.3.  Some 
options might have received the same score for 
different  reasons,  without  the  reasons  for  this 
having been spelled out.  

(3) The context  description  could elaborate on 
the  arguments  of  opposing  stakeholders,  and 
explain to what extent they contrast with strong 
political  support  expressed  in  other  instances, 
i.e.  through  Council  Conclusions.  The  report 
could  better  reflect  the  views  of  the  Member 
States, 
including  potential  disagreements 
within national administrations. 

Furthermore,  the  report  could  improve  the 
presentation  of  Member  States'  intentions  and 
national  plans  for  upgrading  ID  and  residence 
documents.  The  report  should  make  it  clearer 
to  what  extent  unilateral  Member  State  action 
is  insufficient  to  address  security  concerns,  in 
particular  given  that  the  problems  of  fraud 
seem to be circumscribed to a small number of 
countries.  In  this  regard,  it  should  better 
demonstrate 
introducing 
the  necessity  of 
binding legislation at EU level, as compared to 
a recommendation or soft law measures. 

Also,  the  report  could  also  better  explore  the 
synergies 
other 
initiatives,  as  regards  facilitating  access  to 
services. 

connections  with 

and 

(4)  The  report  could  provide  further  evidence 
to  illustrate  the  magnitude  of  the  problem  and 
its  expected  future  evolution.  It  could  better 
substantiate  the  links  between  weak  document 
security  for  ID  and  residence  documents  and 
fraud.  The  report  could  present  in  a  more 
prominent way the available data on the use of 
fraudulent  documents  or  misuse  of  genuine 
cards.  Contributing  to  the  need  for  secure 
documents is the increasing number of security 
controls  in  conjunction  with  the  increased 

The results of a sensitivity test of the preferred 
option are inserted in section 7.4 and Annex 4. 

Better motivations of the scores of the options 
in Tables 7.1, 7.2 and 7.3 have been integrated 
in section 7. 

The views of stakeholders were elaborated and 
summarised in the context description (section 
1.2).  

How the problem would further evolve and the 
Member States' intentions and plans have been 
better explained in section 2.3.  

The  necessity  to  introduce  binding  legislation 
instead  of  establishing  another  set  of  non-
binding 
and 
recommendations  was  sketched  out  in  section 
3.2 Subsidiarity: Necessity of EU action. 

guidelines 

political 

A description of initiatives, such as the eIDAS 
Regulation, has been included in section 1.2. 

The  magnitude  of  the  problem  was  better 
elaborated in section 2.1. More details recently 
reported  by  FRONTEX  regarding  fraudulent 
documents were added. 

The problems of citizens to access services are 
laid out in Annex 6 section 2 and 3. 

65 

 
 
 
number  of  travellers.  Additionally,  the  report 
could  give  more 
information  on  citizens' 
problems  to  access  services  with  their  ID  and 
residence cards.  

The  Board  takes  note  of  the  quantification  of 
the various costs and benefits associated to the 
preferred option of this initiative, as assessed in 
the  report  considered  by 
the  Board  and 
summarised 
the  attached  quantification 
in 
tables.  The  Board  considers  that  costs  related 
to  the  introduction  of  new  ID  and  residence 
cards could be quantified more extensively. 

Some  more  technical  comments  have  been 
transmitted directly to the author DG. 

More  extensive  quantification  is  not  possible 
because there is a lack of reliable data. This did 
not  allow  for  far-reaching  extrapolations  or 
modelling.  

A regards the technical comments received the 
following  changes  were  implemented  in  the 
final IA report: 

- Main text and Annexes were merged into one 
document.  

- The summary tables on the individual impacts 
by  policy  option  were  incorporated  in  section 
6. 

- Complementary initiatives on border security 
and  management  were  integrated  in  section 
1.2. 

4. Evidence, sources and quality 

The  Commission  awarded  a  contract  to  the  Centre  for  Strategy  &  Evaluation  Services 
(CSES)  to  carry  out  a  study  on  ‘EU  policy  initiatives  on  residence  and  identity 
documents to facilitate the exercise of the right of free movement’, August 2017. 

The Commission additionally drew on other sources to gather evidence that was used to 
support this impact assessment. This included for example: 

-  A  review  of  the  concepts  of  the  initiative  was  carried  out  by  the  Commission’s 

Joint Research Centre. 

-  A  study  established  by  Milieu  for  the  European  Parliament  “The  Legal  and 
Political Context for setting up a European Identity Document, May 2016.194  

-  A consultation of Member States within the FREEMO expert group 
-  A public consultation from September to December 2017 

194 http://www.europarl.europa.eu/RegData/etudes/STUD/2016/556957/IPOL_STU(2016)556957_EN.pdf  

66 

 
 
 
 
 
                                                 
Annex 2: Stakeholder consultation  

1. Stakeholders mapping 

The main stakeholders categories identified overall are: 

• 

• 

• 

Citizens/individuals – EU citizens living and/or traveling in an EU Member State 
other  than  their  Member  State  of  nationality.  EU  citizens  living  in  an  EU 
Member  State  other  than  their  Member  State  of  nationality,  travelling  to  and 
returning  from  a  third  country,  particularly  to  and  from  third  countries  which 
permit entry and exit using an EU national ID card. Non-EU family members of 
the former and the latter.  
Public  authorities  –  National  authorities  of  the  Member  States  which  issue  ID 
cards  to  their  own  nationals  and  residence  documents  to  EU  citizens  and  their 
third country family members. National authorities which deal directly with and 
in  particular  provide  services  (such  as  schooling,  housing,  healthcare)  to  non-
national EU citizens and their third-country family members. National authorities 
which control the external EU border.  
Industry/business/workers’ organisations – Businesses which provide services to 
EU  citizens  from  other  Member  States,  particularly  businesses  which  are 
required  by  law  or  policy  to  establish  the  identity  and/or  residence  of  such  EU 
citizens  when  providing  services,  such  as  banks,  airlines,  insurance  companies, 
other transport carriers and their organisations.  

EU citizens from Member State which issue ID cards (all Member States except for UK, 
DK  and  IE)  are  the  main  stakeholders  with  respect  to  the  aspect  of  this  consultation 
which  considers  ID  cards,  as  these  are  the  most  commonly  used  proofs  of  identity  in 
these Member States, and are also very commonly used as travel documents within the 
EU, and outside the EU where relevant (EU Member States have bilateral arrangements 
with  many  third  countries  to  allow  entry  and  exit  of  Member  State  nationals  to  those 
third countries using ID cards).  

All EU citizens living in a Member State other than their own are the main stakeholders 
with  respect  to  the  aspect  of  this  consultation  which  considers  residence  documents, 
because they are the citizens who must rely on these documents to prove their residence 
status, and who have direct experience of the status quo in this respect. The third country 
family  members  of  EU  citizens  living  in  a  Member  State  other  than  their  state  of 
nationality  also  have  a  strong  interest  in  this  consultation  because  their  residence 
document exempt them from visa when they travel in the EU.  

2. Consultation methods 

The  consultation  process  combined  tools  of  a  more  general  reach  such  as  a  public 
consultation  with  more  targeted  consultations  of  stakeholder  groups.  Part  of  the 
consultation  process,  especially  regarding  technical  information  requiring  analysis  of 
data, was carried out by an external contractor.  

The following types of consultation activities have been carried out: 

67 

 
 
 
• 

• 

• 

• 

• 

• 

Online  open  public  consultation  of  12  weeks  (12  September  to  5  December 
2017)  in  three  parts,  one  each  targeting  EU  citizens,  the  third  country  family 
members  of  EU  citizens  living  in  a  Member  State  other  than  their  state  of 
nationality, and Industry/business/workers’ organizations, respectively. The open 
public  consultation  did  not  contain  questions  specifically  addressed  to  the 
Member States and public authorities, due to the excessively technical nature of 
the information which needs to be gathered. They were approached by means of 
a  questionnaire/survey  and  interviews  instead.  However,  the  consultation 
remained open to the Member States and Public Authorities, should they wish to 
participate. The open public consultation questionnaire was made available in 23 
official languages with possibility to respond in any of them. 
Targeted  interviews  were  used  to  gather  information  from  specific  groups  of 
stakeholders  (e.g.  collection  of  information  on  current  costs  and  impacts  of 
potential  options)  by  the  external  contractor  who  conducted  69  interviews  with 
NGOs,  companies  producing  cards  and  documents  and  businesses  requiring 
proof  of  identity  to  conclude  services,  academics  experts195.  A  specific 
questionnaire targeted businesses during the public consultation with 15 replies. 
A first questionnaire/survey for the Member States was carried out by an external 
contractor,  followed  by  53  interviews  of  national  authorities196  .  This  tool  was 
used due to the need of collecting technical information (legislation, specimen of 
documents etc.).  
A questionnaire to Member States was sent through the FREEMO expert group, 
on security features of ID and residence documents, costs and possibilities of EU 
harmonisation,  with  an answer  from  24  Member  States  197.  15  Member  States 
agreed that common security features and a certain or partial harmonisation are 
required  for  ID  cards,  and  the  same  number  supported  this  for  residence 
documents, and in particular for TCN FAM residence cards.198 
Structured  and  semi-structured  interviews  were  carried  out  by  an  external 
contractor with the authorities of all the Member states, as mentioned above (53 
individual interviews in all Member States except the United-Kingdom). 
Semi-structured discussion was conducted at two meetings of the Expert Group 
on Free Movement on 4 May and 16 November 2017, discussing the result of the 
questionnaire sent to the group and the support for a harmonisation at EU level. 

3. Results from the consultation in the context of the external study 

All document types 

Soft  law  measures  (ID  SOFT,  RES  SOFT)  with  regard  to  all  types  of  documents  are 
favoured by many stakeholders that have been consulted (e.g. national authorities in HU, 
SK, FI and HR and civil rights organisations in BE, ES and SE).  

195 CSES study: list of interviewees per Member States in Annexe A. 
196 CSES study; list of interviews in the annexe A. The interviewees were representatives of the national 
authorities  competent  for  ID  and/or  residence  documents,  in  most  cases  Ministries  of  Interior,  Home 
Affairs or Migration. 
197 Spain, Croatia, Italy and the United-kingdom did not send any answer. 
198 For ID cards: CY, CZ, EE, EL, FI, IE, LT, LU, LV, NL, PT, RO, SI, SE, SK; For residence documents: 
For residence documents:  EL, IE, LU, BU, CY, CZ, EE, FI, HU, LT, LV, NL, PL, SI, SK. 

68 

 
 
 
                                                 
A widely supported proposal of a quite specific nature is for more regular updates of the 
FADO/PRADO database with document specimen.199  

The Council stressed the importance of security of ID cards and residence documents in 
two Council conclusions adopted in 2017.200 
ID cards201:  
The DE Ministry of Interior asked  that the Council  Resolution202 on minimum security 
standards  of  identity  cards  from  2006  should  be  “extended  to  include  the  minimum 
security  guarantees  for  electronic  identifications  (elDs),  since  the  elDAS  Regulation 
provides for the mutual recognition of national elD solutions.” 

Within the free movement expert community, introducing security features (ID 1 or ID 2) 
is favoured by many national authorities (such as those in BG, CY, DE, EL, FI, IE, PT, 
RO, SI, and SK). However, it has also been argued that in particular harmonisation for ID 
cards should not go beyond minimum features, since documentation ‘is an expression of 
the  identity  of  each  country’  (e.g.  SK),  and  since  it  could  facilitate  falsification  of 
documents as  counterfeiters would need  to deal with  fewer versions of ID cards across 
Europe (e.g. BG). Amongst those who favour (limited) action at the EU level, the starting 
point  is  a  willingness  to  accept  a  certain  degree  of  diversity  as  long  as  ID  cards  are 
machine-readable (functional MRZ) and contain a microchip with biometric data. Linked 
to  this,  phasing  out  paper-based  and  old  plastic  ID  documents  which  are  not  machine-
readable and can be easily forged is seen as highly desirable. 

There  are  very  mixed  views  on  the  scope  for  action  at  the  EU  level  to  promote 
harmonisation  of  ID  cards.  For  instance,  some  of  the  national  authorities  (primarily 
Ministries of Interior in AT, CZ, HR, DK, NL, MT and PL) explicitly stated they did not 
see the necessity of a legislative measure on ID cards. In contrast, national authorities in 
some  other  countries  (e.g.  CY  and  EE)  advocated  EU  measures  to  lay  down  minimum 
requirements with regard to key security features and the inclusion of biometrics to help 
prevent fraud.  

Amongst  the  private  sector  and  the  NGO  stakeholders  opinions  were  very  mixed  with 
around  half  of  those  consulted  indicated  that  no  legislative  action  is  necessary  or  that 
they  are  not  really  concerned  by  the  issue,  while  the  others  argued  that  harmonisation 
could be beneficial.  
An EP study203 assessed the added value of introducing an additional European identity 
card in order to facilitate political participation at the EU level. The study argues that an 
EU  ID  card  (ID  3)  would  enhance  democratic  participation  rights  at  the  EU  level  and 

fraud 

199 CSES study 
200  Council  Conclusions  on  the  Commission  Action  plan  to  strengthen  the  European  response  to  travel 
document 
adopted  on  27  March  2017  http://www.consilium.europa.eu/en/press/press-
releases/2017/03/27/jha-travel-document-fraud and Council Conclusion on the EU Citizenship Report 2017 
adopted on 11 May 2017 http://data.consilium.europa.eu/doc/document/ST-9080-2017-INIT/en/pdf  
201 Mostly based upon CSES study and the DG JUST consultation of Member States in 2017 
202  Resolution  of  the  Representatives  of  the  Governments  of  the  Member  States,  meeting  within  the 
Council on 4-5 December 2006, on minimum security standards of identity cards valid for travel issued by 
Member States. 
203  May  2016:  “The  Legal  and  Political  Context  for  setting  up  a  European  Identity  Document: 
http://www.europarl.europa.eu/RegData/etudes/STUD/2016/556957/IPOL_STU(2016)556957_EN.pdf  

69 

 
 
                                                 
facilitate  free  movement.  However,  the  report  also  referred  to  the  limited  legal  and 
political  feasibility  of  and  challenges  for  setting  up  an  interoperable  European  identity 
card given the current legislative and political context. 

Residence documents:  

In order to increase clarity of the legal status and the functionality of residence cards it 
was  mentioned  explicitly  by  authorities  in  several  Member  States  (e.g.  Austria  and 
Lithuania)  that  it  will  be  helpful  to  require  Member  States  to  print  the  title  of  the 
document in both the original and the English language on the document and when not 
equivalent also mention the terminology used in Directive 2004/38/EC on the document 
(RES 1).  

Some national authorities in LU, FR and EL suggested that, as already implemented by a 
number  of  Member  States,  TCN  family  members  of  EU  citizens  should  hold  residence 
cards in the uniform format of residence permits for TCNs (RES 2). FRONTEX suggests 
that  further  harmonisation  of  TCN  FAM  residence  documents  may  further  improve 
security204. 

Others (e.g. national authorities in CY, DK, EE, FR, EL, LU and MT) favoured a greater 
degree  of  harmonisation  of  all  residence  documents  (RES  3),  possibly  following  the 
uniform  format  as  well,  or  pleaded  at  least  for  adding  a  facial  image  on  registration 
certificates for EU citizens. 

4. Results from the open public consultation 

Three questionnaires were used in the consultation, a) one questionnaire for EU citizens 
(398  replies),  b)  one  questionnaire  for  non-EU  citizens  (34  replies)  and  c)  one 
questionnaire for businesses (15 replies). Member States authorities were not specifically 
consulted again, since they were addressed and consulted in the context of the external 
study before.205 As a result no national authorities replied to  the questionnaires used  in 
this open public consultation. 

a) The 398 replies from EU citizens are further analysed below in the  sections on ID 
cards, residence documents, and processes. 

Of the total of 398 individual  EU citizens responding,  375 (95%) were of working  age 
(18 to 65). Only 15 respondents were above, and 8 under 18. 

The 398 answers were received from all Member States with a high level of answers 
from Italy (68) and a cluster of Member States with an answer rate of around 30: Spain, 
the  United-Kingdom,  Germany,  France,  Bulgaria  and  Belgium.  Then  follow  the 
Netherlands, Greece and Finland with around 20 respondents each. Only Malta, Cyprus 
and Luxemburg have only one respondent. 

Table 1 

Austria 

Nationality 
(398 
replies) 
15 

Country 
residence 
replies) 

13 

204 CSES study 
205 See above and CSES study 

of 
(398 

In which other EU country do you live or have lived 
in the last five years?’ (208 replies) 

3 

70 

 
 
 
                                                 
Belgium 
Bulgaria 
Cyprus 
Croatia 
Czech Republic 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Liechtenstein 
Lithuania 
Luxembourg 
Malta 
More 
countries 
Netherlands 
Norway 
Other 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
UK 

18 
22 
1 
7 
5 
1 
5 
19 
27 
28 
20 
5 
3 
64 
0 
6 
1 
0 
23 

17 
5 
3 
7 
11 
14 
3 
4 
32 
4 
28 

55 
14 
3 
5 
4 
2 
5 
20 
20 
33 
7 
4 
7 
32 
0 
1 
9 
2 
8 

17 
2 
14 
2 
13 
5 
1 
3 
31 
11 
46 

34 
1 
2 
1 
3 
1 
0 
1 
11 
17 
1 
0 
3 
8 
1 
0 
7 
0 
54 

12 
0 
0 
1 
2 
0 
0 
0 
12 
6 
27 

b)  34  non-EU  citizens  replied  to  the  specific  questionnaire  for  non-EU  citizens.  The 
results  are  mainly  relevant  to  residence  documents  for  third  country  national  family 
members of EU citizens (see section on TCN FAM cards). 

c)  Moreover,  15  ‘businesses’  (including  7  civil  society  organisations)  from  across  the 
EU replied to a specific business questionnaire, and of those five uploaded more specific 
content. The results are integrated in all the following sections. 

1. ID cards 

Of  the  398  respondents  to  the  EU  citizen  questionnaire,  318  (almost  80%)  hold  a 
national ID card and 289 use their ID to travel in the EU. However, a quarter (72) of 
them reported difficulties:  

-  36  mention  problems  at  airport  to  get  their  ID  accepted  as  a  travel  document, 
principally in the United-Kingdom for two-thirds; 18 reported longer queues than for 
passport holders; 

- Several problems with paper ID cards were reported by Italian and Greek citizens: 
deterioration or no expiry date (for Greek ID cards); lack of Latin alphabet in Greek 

71 

 
 
 
cards, specific kinds of ID cards (e.g. specific colour of German-speaking Italians’ ID 
cards); 

- The differences in cards were also reported as causing problems: unusual format of 
the Czech (booklet) and of Romanian cards, or the use of several surnames on Spanish 
ID cards; 2 French citizens mentioned problems with ID card with prolonged validity 
not indicated on the cards themselves; 

-  3  cases  reported  non-European  or  low  cost airlines  refusing  to  accept  ID  cards  for 
intra-EU flights; 

‘Have you ever used your identity card as identification in an EU country 
outside the one that issued the card?’ ‘Where?’  

150
100
50
0

250 respondents (79%) used their ID cards in other Member States, in most cases for 
contacts with administrations, local authorities, at banks and post offices. In more than 
one  third  of  the  cases  (91),  proof  of  identity  was  problematic,  for  example  when  no 
address was mentioned on the card or it used non-Latin alphabet, or the age or the date of 
issue was missing. 

Problems  regarding  acceptance  and  authentication  of  ID  cards,  as  well  as  problems  of 
citizens identifying themselves at borders and with private sector service providers, such 
as airlines, were also reported by civil society organisations.206 

As  regards  strong  security  features  to  reduce  the  risk  of  document  and  identity 
fraud,  a  large  majority  wants  strong  (155  respondents)  or  even  the  strongest  possible 
(141  respondents)  security  features  to  reduce  the  risk  of  fraud.  Only  22  believe  that 
strong security features are not essential to reduce the risk (see below).  
Civil  society  organisations206  support  Member  States  phasing  out  paper-based  identity 
cards  as  soon  as  possible  and  argue  for  minimum  harmonisation  as  regards  security 
features  and  format  but  without  the  need  ‘that  the  ID  cards  should  necessarily  look 
exactly the same’. 

206 EU Rights Clinic (University of Kent; ecas/ European Citizen Action Service) 

72 

 
 
 
                                                 
‘An  identity  card  can  be  used  for  travel  and  identification  purposes 
throughout the EU. Which of the following statements do you agree most 
with?’  

Strong security features are unnecessary. I’m not 
worried about document fraud or identity theft. 

The strongest possible security features are
needed to reduce the risk of document fraud and
identity

Strong security features are essential to reduce
the risk of document fraud and identity theft.

0

20

40

60

80

100 120 140 160

On  the  increased  costs  of  ID  cards  with  increased  security  features,  respondents 
answered that this should be borne by the national budget (51%) or shared between the 
national  budget  and  applicants  (45%).  161  (41%)  EU  citizen  respondents 
recommended  a  price  less  than  EUR  15,  and  142  (36%)  a  price  between  EUR  15 
and EUR 50. 

On the appearance of ID cards, 278 (70%) respondents are in favour of a European 
format for national ID cards, with a slightly lower percentage for respondents who hold 
currently no ID cards (67.5%). 

272 (68.3%) EU citizen respondents believe that ID cards should have special identity 
features  for  people  who  are  visually  impaired  (e.g.  braille)  for  easy  recognition  by 
them.  
This  is  also  supported  by  civil  society  organisations207  responding  to  the  ‘business’ 
questionnaire.  In  addition  to  Braille,  those  organisations  want  ID  cards  (and  where 
relevant residence document) to meet additional criteria to address the needs of persons 
with disabilities: 

  Maximise readability; 
  Mark orientation; 
  Use of Braille (see above); 
  Low-slip cards (easy to handle); 
  Easy to understand; 
  Provide the card information in other formats (see section on e-ID). 

207 European Blind Union, European Disability Forum 

73 

 
 
 
 
                                                 
‘Do you think identity cards should look exactly the same throughout the 
EU?’ 

250

200

150

100

50

0

YES

NO

NO opinion

Holding ID card

Not Holding ID card

2.  Residence  documents  (Registration  certificates,  Residence  cards  and 

Permanent residence cards for EU citizens) 

Of the 398 EU citizens responding to the public consultation, 211 have lived in another 
EU  country  in  the  past  5  years.  55  of  these  EU  citizens  have  held  a  registration 
certificate, 39 a residence card and 26 a permanent residence card.  

Registration certificates 

Most of the registration certificates of those surveyed are paper documents (31), with the 
remaining  22  respondents  possessing  a  registration  certificate  in  card  form.  The  main 
advantage of a registration certificate according to the respondents is that it enables them 
to prove to the authorities of their host Member State that they are a legal resident (37).  

A  second  use  for  registration  certificates  is  to  be  able  to  prove  residence  to  national 
authorities (34).  

Others also mentioned that it is considered an added value when applying for permanent 
residence after 5 years of residence (12), and that they use it to prove their residence in 
another  Member  State  in  their  Member  State  of  origin  after  they  have  returned  (11). 
Regarding difficulties encountered  when using the registration certificate, only 7 of the 
55 respondents noted experiencing difficulties. The majority of these difficulties relate to 
the paper format of the registration certificate, which is deemed not to be robust enough 
for  such  an  important  document.  Others  note  the  requirement  of  an  additional  apostille 
when using the document outside of their host Member State, and the embassies of their 
Member State of origin requiring them to be translated into their native language.  

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regarding  the  advantages  of  EU  harmonization  of  registration  certificates,  most 
respondents considered that it would make it easier for the national authorities to accept 
the registration certificate (45), as well as making this easier for private companies (33). 
Others noted that it would make it easier to carry the document due to a better size and 
shape  (30),  as  well  that  registration  certificates  could  benefit  from  higher  production 
standards (especially those from IT and EL).  

Residence cards for EU citizens 

36 respondents possessed residence cards in the EU country where they lived or continue 
to  live.  The  main  reason  for  the  respondents  applying  for  residence  cards  was  because 
they were obliged to apply for one (23)(BE, NL, ES, DK), wanted to have a document to 
prove their legal residence in the host Member State (17) and to have a useful document 
when  contacting  public  authorities  or  private  companies  (16).  A  residence  card  is 
required  for  essential services such  as  entering into  a  contract,  opening a  bank  account 
and paying taxes or receiving wages, with some citizens considering it an unwanted but 
necessary formality. Other reasons include proving one’s identity (33), proving residence 
status  when  applying  for  a  permanent  residence  card  (17)  and  proving  residence  status 
when returning to the EU country of origin (16). 

Most  residence  cards  look  similar  to  ID  cards  or  TCN  FAM  residence  cards,  making 
them easy to confuse (30). Others are distinct documents which are not easily mixed up 
with other EU documents (7), or cards which are not comparable to other documents (6). 
As opposed to registration certificates, only 4 respondents had residence cards made of 
paper,  in  Italy.  At  the  other  end  of  the  spectrum,  Swedish  residence  cards  include  a 
picture, signature and biometrics.  

Regarding views on the advantages of EU harmonization, the main improvement was felt 
to  be  making  it  easier  for  national  authorities  to  accept  the  residence  card  (32),  to 
improve  the  size  and  shape  of  the  document  (21)  and  to  enable  private  companies  to 
more  easily  accept  the  document  (21).  Comments  also  noted  that  EU  harmonization 
would  create  a  stronger  sense  of  ‘Europeaness’,  and  two  respondents  called  for 
integrating the residence card function into their national ID cards.  

Permanent residence cards for EU citizens 

26  respondents  indicated  having  permanent  residence  cards.  23  of  these  respondents 
indicated  that  they  did  so  because  they  considered  it  useful  to  prove  their  residence 
status,  especially  in  the  light  of  Brexit.  Other  respondents  thought  that  it  would  prove 
useful  in  case  they  needed  to  identify  themselves  (8).  3  respondents  noted  that  a 
permanent residence card is also a prerequisite for applying for UK nationality.  

Other  comments  suggested  incorporating  the  permanent  residence  card  into  documents 
already  available  such  as  national  ID  cards  or  driver  licences  (2),  to  permit  all  MS 
authorities to access the information found on the these identification documents.  

3. Residence documents for third country nationals who are family members 

of EU citizens (TCN FAM cards) 

Thirty-four  non  EU  citizens  responded  to  the  specific  questionnaire,  of  diverse 
nationalities  and  residing  in  various  EU  Member  States,  with  the  highest  numbers  of 

75 

 
 
 
residents  in  Belgium  (5),  Germany  (5),  Italy  (4),  Spain  (4)  and  the  UK  (4).  Most 
respondents are young, 26 below the age of 45. The majority are spouses of EU citizens, 
with  only  4  being  their  registered  partners  and  3  dependent  direct  relatives.  Almost  a 
third of respondents claimed they travel within the EU several times a year.  

18 

respondents  hold  or  held  EU  residence  card  as  family  members  of  EU  citizens,  8  a 
permanent residence card of family members of EU citizens, and 7 a residence permit.  

 

TCN FAM residence cards 

A majority of respondents claimed their residence card is useful for proving their status 
as a legal resident (16), for travelling in the EU without a visa (14), and for being able to 
apply for a permanent residence card after 5 years (13). Moreover, respondents stated it 
is useful for online signature and access to online services, for applying for jobs, working 
and paying taxes in another country, and for proving the relationship with an EU citizen. 
As  a  respondent  from  Spain  stated,  ‘aside  from  the  above  benefits  mentioned,  the  EU 
residence  card  improves  my  sense  of  independence  and  confidence  when  establishing 
credibility, and  most  importantly  [provides  for  an]  access to  standard  social  integration 
that may require the specific document. For example, [it is useful] when opening a bank 
account, when trying to rent an accommodation, employment, health and safety.’ 

A  similar  number  of  respondents  stated  that  they  should  be  able  to  use  their  residence 
card  to  prove  their  identity  (16),  to  prove  their  residence  status  to  national  authorities 
(16),  to  prove  their  residence  status  when  going  back  to  the  home  EU  country  of  the 
mobile  EU  citizen  (14),  to  prove  their  residence  status  when  applying  for  a  permanent 
residence  card  (14),  and  to  apply  for  jobs  (1).  One  of  the  respondents,  resident  in 
Germany, suggested that residence card should have the same status as an ID card for EU 
citizens, which would in particular eliminate the obligation to hold a passport.  

15  respondents  consider  the  main  advantage  of  all  residence  cards  looking  exactly  the 
same  in  all  EU  countries  that  it  would  be  easier  for  national  authorities  to  accept  the 
documents  (15),  easier  to  carry  due  to  better  size  and  shape  (11),  and  easier  for 
shops/private  companies  to  accept  (8).  One  of  the  respondents,  resident  in  Belgium, 

76 

 
 
 
 
 
 
 
 
 
 
 
 
 
wrote: ‘the residence card of a family member of an EU citizen has to be uniformed so 
the  rights  of  the  card  holder  can  be  recognised  more  easily  in  another  country.  In 
Belgium  the  F  card  looks  like  Belgian  national  ID  card  which  is  very  misleading  for 
many people and even could be misused. To give another example, Portugal still issues 
paper  version  of  the  card  which  is  very  unpractical  and  unsecure.’  Furthermore,  as 
another respondent described, such a uniform card would ‘improve communication and 
neutralise the tension that bureaucracy usually creates.’  

 

TCN FAM permanent residence cards 

Permanent  residence  cards  in  the  EU  Member  States  in  which  the  respondents  reside 
either look like a regular residence card for non-EU nationals (4), are formal documents 
which are not like a residence card or identity card (2), or are paper documents (1). For 
instance, a respondent from Slovenia described that their permanent residence card is just 
an  ID-sized  paper  with  their  picture  and  identification  number,  without  any  biometric 
features. 

6 respondents found their permanent residence card useful in proving that they are legally 
resident, 3 for travelling in the EU without a visa, and 1 did not find the card useful. The 
respondent  dissatisfied  with  the  usefulness  of  their  permanent  residence  card  was 
requested to present their passport to board a plane to Venice since, they were told, the 
Belgian  F+  permanent  residence  card  was  not  a  proof  of  identity.  This  sentiment  was 
repeated by another respondent who raised the issue with Belgian residence card, which 
involved a lengthy procedure and did not facilitate cross-border work in Germany. 

Residents  think  they  should  be  able  to  use  their  permanent  residence  card  to  prove 
identity (7), to prove residence status to national authorities (5), to prove residence status 
when  going  back  to  the  home  EU  country  of  the  mobile  EU  citizen  (5),  and  to  prove 
residence status when re-applying for a permanent residence card (5). A respondent from 
Belgium  added  that  ‘the  permanent  residence  card  should  grant  access  to  the  labour 
market without need of a work permit.’ 

Respondents stated that if permanent residence cards looked exactly the same in all EU 
countries, it would be easier to carry due to better size and shape (6), easier for national 
authorities to accept (5), and easier for shops/private companies to accept (3). 
Civil society206 feedback  pleads for harmonisation of TCN FAM cards on the basis of 
the uniform format for residence permits.208 

4. e-ID for EU citizens 

Electronic  ID  cards  and  the  possibility  to  pass  through  electronic  border  control  gates 
were noted as additional functions that just over 30 respondents would be willing to pay 
more  for.  Such  technical  features, in  the  view  of  some  citizens,  would  facilitate  border 
control,  voting,  or  access  to  many  online  services  or  even  contactless  payments. 
Moreover, technical features including personal digital signature, biometric information, 
chip,  secure  encryption  key  or  centralised  data  storage  also  recurred  throughout  the 
responses. Several citizens suggested ‘e-government functions’ that e-IDs could be useful 

208  To  distinguish  the  TCN  FAM  cards  from  other  documents  such  as  residence  permits  Member  States 
should  use  a  standardised  code,  such  as  ‘fam.res.Art.10  Dir.  2004/38’  or  ‘fam.  perm.res.Art.20  Dir. 
2004/38’ 

77 

 
 
                                                 
for  and  with  which  they  could  be  integrated  (i.e.  through  creation  of  an  ‘electronic 
personal file’),  in aspects such  as social security, healthcare, driving  license,  insurance. 
One respondent expressed willingness to ‘pay for the possibility to have a virtual version 
of  my  ID  Card/e-Passport  securely  stored  and  accessible  on  my  mobile  to  authenticate 
with higher assurance and trust to online services.’  

Nevertheless,  some  respondents  admitted  they  considered citizens  should  not  pay more 
for such technical features, as they ‘allow the authorities to save money.’  

While e-ID and the possibility to cross electronic border control gates would generally be 
welcomed by many respondents, some concerns about data protection and privacy were 
also raised. For  instance,  one  of  the  respondents  emphasised  the  necessity to  ensure  an 
opt-out possibility with regard to biometric data. Another citizen stated that ‘standardized 
procedures at European level should be enforced to ensure cards security mechanisms do 
pass checks according to stringent security certifications to avoid, e.g. ‘vulnerabilities in 
digital  certificates  present  in  large  number  of  issued  e-ID  cards  in  a  number  of  EU 
countries.’ 

5. Processes (applying, issuing etc.) 

161  respondents  felt  that  the  price  of  issuing  ID  cards  with  additional  security  features 
should be borne by the national budget. 142 respondents indicated that these costs could 
be  shared  by  the  national  budget  and  applicants,  and  only  15  respondents  felt  that  all 
costs should be paid by the applicant.  

78 

 
 
129  respondents  felt  that  ID  card  should  cost  citizens  less  than  EUR  15,  whereas  116 
respondents felt that EUR 15-EUR 50 was fair. 74 respondents felt that an ID card should 
be free.  

No  further  specific  questions  regarding  the  application  and  issuance  procedures  for  ID 
cards or residence were asked in the public consultation.  

A  comment  from  a  German  citizen  suggested  an  opt-out  of  the  biometric  chips,  so 
citizens may choose themselves to keep the price of their ID card down. Other comments 
suggested  to  in  the  situation  where  a  citizen  loses  his  or  hers  ID  card  before  the 
expiration date, he or she should borne the full costs of the replacing ID card. 

79 

 
 
 
 
Annex 3: Who is affected and how? 

1. Practical implications of the initiative 

The  following  stakeholders  would  be  mainly  affected  by  the  initiative  as  set  out  in  the 
preferred option (see section 8): 

National administrations 

Public  administrations  will  have  to  administrate  ID  cards  and  residence  documents 
according to the minimum format and security standards defined at EU level.209 

Adjustments to new production processes and staff training regarding ID and residence 
documents  can  build  on  existing  regimes  for  passports  and  residence  permits  which 
already  need  to  take  into  account  of  ICAO  standards.  In  the  long  run,  this  could  yield 
economies  of  scale  in  the  production,  issuance  and  handling  of  all  these  documents,  if 
efforts to coordinate and collaborate to make savings are successful. 

Phasing out ID cards and residence cards for the family members of EU citizens will be 
in line with the natural replacement rate of the documents in most  Member States. The 
shorter  five-years  phasing-out  regime  for  ID  cards  will  impact  only  3  Member  States. 
Fourteen countries are affected by the quicker phasing out of non-compliant TCN FAM 
permanent residence cards.210 This does not affect very many citizens because only few 
such documents are issued.211 

Public administrations, in particular border guards, will benefit from the harmonisation of 
ID  and  residence  cards,  because  verification  of  cards  and  documents  issued  by  other 
Member  States  will  be  facilitated.  It  will  reduce  the  need  for  training  of  the  officials 
involved,  reduce  the  staff  resource  needed  to  handle  the  same  number  of  IDs  by 
permitting  authentication  to  be  performed  more  quickly  and  reliably,  and  also  increase 
the trust in those documents, which will be more difficult to misuse. 

EU citizens and their family members 

EU  citizens  and  their  family  members  will  have  to  obtain  new  ID  and  residence 
documents.  For  most,  the  issuance  of  a  new  document  will  be  according  to  the  usual 
renewal period and will not require early or additional action. 

Some  EU  citizens  may  have  to  request  new  ID  cards  before  their  normal  expiry  date, 
namely in FR, IT and EL. This will also apply to a number of senior citizens in a limited 
number  of  Member  States212  whose  ID  cards  have  currently  very  long  validity  or  no 
expiry date at all.  

In  return,  all  EU  citizens  will  benefit  from  having  their  ID  cards  accepted  more  easily 
throughout the EU by public administration and business, as those cards will be easier to 

209 See the Member States concerned in section 8.2 of the impact assessment report 
210 TCN FAM residence cards are not affected because their validity of 5 years coincides with the phasing 
out regime. 
211 See Table 2.5 of the CSES study, page 20: Among the countries concerned Belgium appears to deliver 
the largest number with 6194 permanent residence cards delivered in 2015 
212 BE, BG, CZ, ES, HU, SI, SK. 

80 

 
 
                                                 
verify  and  more  trusted  because  of  their  increased  security  features.  They  will  also 
benefit from more robust residence documents, whose acceptance will also be improved. 

As  for  third  country  family  members  of  EU  citizens,  only  those  already  holding 
permanent residence cards  in  18 Member States would have to  renew their card before 
the  normal validity  period  of  ten  years  expires. In  return  they  will  benefit  from  greater 
certainty in the use of their cards, notably when travelling and benefitting from using this 
documents as visa waivers. 

2. Summary of costs and benefits 

I. Overview of Benefits (total for all provisions) – Preferred Option 

Description 

Amount (qualified where unquantified)  Comments 

Direct benefits 

Annual cost savings for 
accelerated border checks 
across EU-28* 

Annual cost savings for 
accelerated pre-boarding 
checks across EU-28* 

Annual cost savings for 
accelerated document checks 
across EU-28 when opening 
a bank account* 

Cost savings through 
improved document quality 
of TCN FAM cards 

EUR 17.1M 

Figures drawn from CSES study estimates 

Beneficiaries: Public administration (border 
guards) 

EUR 12.4M 

Figures drawn from CSES study estimates 

Beneficiaries: Businesses (airlines) 

EUR 3.9M 

Figures drawn from CSES study estimates 

Beneficiaries: Businesses (banks) 

Fewer rejections of TCN family members at EU 
borders resulting in reduced costs to travellers; 
reduced handling and compensation payments for 
authorities and airlines; reduced denial-of-
boarding costs (lost sale) for airlines. 

Not quantifiable – border authorities and 
airlines do not collect such data 

Beneficiaries: citizens, businesses 
(especially airlines through liability for 
unjustified denial of boarding) 

Reduced hassle costs 
through improved 
acceptance of more secure 
documents (recurrent) 

Quicker, more reliable access to relevant public 
and private services, reduced administration, staff 
training and business risk costs, reduced costs of 
fraud, increased opportunities to provide services 
to non-nationals 

Not quantifiable – while some indications of 
costs were obtained for certain elements, 
most was either commercially sensitive or 
not provided by national authorities. 

Beneficiaries: citizens, business, public 
administration 

Reduced hassle costs 
through swifter and more 
efficient processes for 
requesting and renewing ID 
and residence documents 

Streamlined online processing reduces staff and 
administration costs, reduces costs of providing 
services abroad (where done), reduces need for 
journeys  

Not quantifiable – data on such document 
applications is not collected. 

Beneficiaries: citizens, public administration 

Reduced hassle costs 
through better awareness of 
document formats and the 

Reduced administrative and training costs, 
reduced costs of rectifying errors and 
compensating for rights wrongly denied, reduced 

Not quantifiable – data on such issues is not 
collected by national administrations or 
business. 

81 

 
 
 
rights linked to the 
documents 

Indirect benefits 

Improved security within the 
EU and at its borders 

loss of time and denial of service to citizens. 

Beneficiaries: Citizens, businesses, public 
administration 

Reduction in document fraud related to poor 
document types (forgery, tampering, impostor, 
reused document blanks). Reduction in poor 
document types being used as precursor 
documents.  

Not quantifiable – the precise increase in the 
level of security within the EU cannot be 
quantified. 

Beneficiaries: Citizens, businesses, public 
administrations 

Facilitated freedom of 
movement for EU citizens 
and their family members 

Improved documents permit quicker, easier and 
more secure use of documents, which in turn 
limits or reduces need for certain current 
restrictive measures. 

Not quantifiable – the precise increase in the 
level of security within the EU cannot be 
quantified, and nor can the resultant 
decrease in current restrictive practices.  

Citizens, (businesses, public 
administrations) 

* See CSES study 

II. Overview of costs – Preferred option 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent  One-off 

Recurrent  One-off 

Recurrent 

Direct costs 
(Compliance) 

Indirect costs 

- 

- 

Not 
quantifiable* 

Not 
quantifiable* 

of 

Phasing 
in 
costs:  General 
improvement 
ID 
costs 
cards, 
TCN 
FAM  residence 
documents, 
other  residence 
docs 

Phasing out 
costs ID cards 
EL, FR, IT X 

Direct costs 
(Compliance) 

Not 
quantifiable* 

Indirect costs 

Not 
quantifiable* 

Phasing out 
costs senior 
citizen ID cards 
X 

Direct costs 
(Compliance) 

Not 
quantifiable* 

Indirect costs 

Not 
quantifiable* 

Phasing out 
costs TCN 
FAM 
permanent 
residence 

Direct costs 
(Compliance)  

Not 
quantifiable* 

Indirect costs 

Not 
quantifiable* 

- 

- 

- 

- 

- 

- 

82 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Not 
quantifiable#+  

Not 
quantifiable+ 

666.4M 

Not 
quantifiable+ 

111.9M 

Not 
quantifiable+ 

3.1M 

Not 
quantifiable+ 

- 

- 

- 

- 

- 

- 

- 

- 

 
 
 
 
cards X 

Annual costs 
for non-
legislative 
measures across 
the EU 

Direct costs 

(Compliance) 

Indirect costs 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

11MXX 

- 

* Whether the quantified cost to the administrations will be passed to individuals and the 
levels  of  potential  additional  support  to  implementation  provided  is  not  known  at  this 
stage. 
# 7 Member States produce ID cards that do not require any changes regarding format and 
features. The other 19 MS that issue ID cards will need to upgrade their cards (depending 
on  the  MS  from  adding  biographical  data  to  switching  to  plastic  cards  or  adding  chips 
and biometric data). The costs of each of these upgrade steps are unknown, as MS do not 
share these data.  
+ Insufficient data was provided by national authorities to permit assessment of costs of 
this element. 
X Calculation method of phasing out costs presented in Annex 4. 
XX Figures drawn from estimates in CSES study. More details presented in Annex 4. 

83 

 
 
 
 
 
Annex 4: Analytical methods 

1.  Calculation  of  phasing  out  costs  for  ID  cards  and  TCN  FAM  residence 

documents 

Phasing out costs for ID cards in France, Greece and Italy 

The phasing out regime for EL, FR and IT will require that their ID cards are phased out 
within  five years.  Since  it  can  be  assumed  that  half  of  the  IT  population  holds  modern 
ICAO  compliant  ID  cards,  only  the  other  50%  of  the  IT  ID  card  holders  would  be 
affected by the phasing out.213 

It  is  assumed  that  the  population  to  which  the  phasing  out  regime  in  EL,  FR  and  IT  is 
mostly relevant is the group of persons above the age of 15. This is under the assumption 
that  this  is  the  usual  part  of  the  population  carrying  an  ID  card  for  travel  and  other 
purposes. Moreover, ID cards in EL are mandatory from the age of 12. In FR and IT ID 
cards are not mandatory at all. 

Due to the different validity regimes the phasing out has a different impact. In EL and FR 
two thirds of the ID cards would need to be phased out prematurely, in IT 50% of them. 
The few figures received through the external study214 indicate that the production cost of 
plastic cards in the individual countries may range from EUR 5 in Slovakia to EUR 23 in 
Germany. The average costs of a new plastic ID card is therefore estimated EUR 12. The 
compliance  cost  of  a  premature  upgrade  of  French,  Greek  and  Italian  ID  cards  is 
therefore estimated to be at most EUR 666 million (one-off over five years). 

Table 1: Calculation of phasing out costs for EL, FR, IT 

Country 

Population above 
age of 15 
(EUROSTAT 2016) 

EL 
FR 
IT 

9 226 985 
54 431 181 
52 383 692 

Affected 
population of 
possible ID card 
holders 
9 226 985 
54 431 181 
52 383 692 

Validity 
of ID 
card in 
years 
15 
15 
10 

Affected 
number of 
ID cards  

Phasing out 
cost in EUR 

73 815 880 
6 151 323 
36 287 454  435 449 448 
13 095 923  157 151 076 

Phasing out costs for senior citizen ID cards  

BE, BG, CZ, ES, HU, RO, SK, SI must phase out cards that are non-compliant with the 
preferred option within 10 years. Since they produce cards with longer validity for senior 
citizens  (see  Annex  5  Table  2.2),  these  cards  will  need  to  be  phased  out  earlier  than 
foreseen which will have a financial impact.  

This  will concern a very limited part  of the population, as if we count the deadline for 
adoption of the Regulation (2 years), finalisation of the standards by a committee (1 year) 

213 See also FN 41 
214 See CSES study, Table 2.15, page 45. 

84 

 
 
 
                                                 
and  the  10  years  phasing  out,  only  seniors  above  68  (RO),  71  (for  BG),  73  (SK),  78 
(HU), 83 (CZ, ES and SI) and 88 (BE) will be affected in the respective Member States.  

Assuming  that  all  persons  above  the  indicated  ages  held  cards  needing  renewal,  again 
using the average cost of EUR 12 per plastic card produced (see above), the compliance 
costs to phase out senior citizens' cards would thus be at most EUR 111.9 million (one-
off over 10 years). 

Table 2: Calculation of phasing out costs for senior citizen ID cards 

Country 

BE 

BG 

CZ 

ES 

HU 

RO 

SI 

SK 

Population 
affected above 
age of: 
88 

71 

83 

83 

78 

68 

83 

73 

"*": based upon EUROSTAT 2016 figures 

Affected population of potential card holders 
above indicated age * 

285 057 

1 450 715 

416 949 

2 726 152 

418 645 

3 429 379 

101 745 

500 526 

Phasing 
out cost in 
EUR 
3 420 684 

17 408 580 

5 003 388 

32 713 824 

5 023 740 

41 152 548 

1 220 940 

6 006 312 

Phasing out costs for TCN FAM permanent residence cards  

For  TCN  FAM  cards  under  the  preferred  option,  phasing  out  within  five  years  will  be 
required when the TCN FAM cards are currently not based upon the uniform format for 
residence permits. This phasing out within five years will create no additional financial 
impacts for the phasing out of TCN family member residence cards because their validity 
is always five years and they will be therefore naturally be replaced in five years.  

Phasing out TCN FAM permanent residence cards within five years requires additional 
costs in at least 14 countries (AT, BG, CY, CZ, DK, ES, FI, HR, HU, IT, LU, PL, SI and 
UK). If they are valid for 10 years, we assume that half will need to be phased out early. 
If their validity is unlimited we can assume that they all need to be replaced.  

Very few countries delivered figures about production cost of such cards (from EUR 5.63 
in CZ to EUR 15.40 in BE). 215 It is therefore assumed that a state-of-the-art plastic card 
with security features will cost as much as for ID cards (average EUR 12). The overall 
phasing  out  costs  for  TCN  FAM  cards  are  therefore  estimated  to  be  at  most  EUR  3.1 
million over five years (one-off). 

Table 3: Calculation of phasing out costs for TCN FAM permanent residence cards 

Country 

AT 

BG 

Number of cards 
produced in 10 years 216 
8 730 

Validity of TCN FAM 
perm res card in years 
10 

Phasing out cost taking into 
account validity in EUR 
52 380 

2 710 

10 

16 260 

215 See CSES study, Table 2.16, page 47. 
216 Based on figures in CSES study Table 2.5, page 20. 

85 

 
 
                                                 
CY 

CZ 

DK 

ES 

FI 

HR 

HU 

IT 

LU 

PL 

SI 

UK 

1 330 

13 810 

45 000 

361 370 

1 070 

110 

8 410 

10 000 

9 270 

No figures 

1 000 

10 000 

10 

10 

unlimited 

10 

unlimited 

10 

10 

unlimited 

10 

10 

unlimited 

10 

7 980 

82 860 

540 000 

2 168 220 

12 840 

660 

50 460 

60 000 

55 620 

- 

12 000 

60 000 

Cost implications if the phasing out is accelerated 

To  speed  up  the  security  gains  to  be  provided  by  the  improved  documents  the  phasing 
out of documents that are non-compliant with the preferred option can be accelerated.  

If  the  phasing  out  period  was  for  instance  cut  in  half  (2-3  years  for  the  least  secure 
documents  and  5  years  for  the  other  non-compliant  documents)  the  (one-off)  phasing 
out cost would not only double but almost triple both for ID cards and TCN FAM 
cards. 

For ID cards more countries would be affected by the phasing out regime. In addition to 
the ID cards in EL, FR and IT, and the senior citizen ID cards in BE, BG, CZ, ES, HU, 
RO, SI and SK, a substantial number of ID cards would need to be phased out in AT, BE, 
BG, CZ, DE, ES, HU, LU, MT, PL, RO, SI, SK.   

Regarding  TCN  FAM  cards,  under  a  similarly  accelerated  phasing  out  regime,  the 
phasing  out  would  also  create  additional  financial  impacts  for  more  countries. 
Furthermore  it  would  also  affect  TCN  FAM  residence  cards  and  not  only  TCN  FAM 
permanent  residence  cards  because  non-compliant  TCN  FAM  residence  cards  would 
usually not be naturally replaced within the requested phasing out period.  

2. Annual costs for non-legislative measures across the EU  

As  set  out  in  section  5  the  soft  law  measures  under  ID  SOFT),  RES  SOFT)  and 
PROCESS  SOFT)  are  non-binding  and  can  be  adapted  to  the  needs  of  the  individual 
Member State.  
We therefore only provide examples of how much such activities will cost.217 

Soft law measures 

Annual costs (EUR) 

a) Awareness raising  

EUR 2.4 million 

b) Reinforce SOLVIT  

EU28 x 1 x EUR 134 000 = EUR 3.75 million 

217 See CSES study, page 142. 

86 

 
 
 
 
                                                 
Soft law measures 
c) Enhanced administrative 
cooperation  
d) EU wide training 

e) Points of Contact 

Annual costs (EUR) 
EU28 x 2 (participants) x 1 (meeting) x EUR 500 (per person) = EUR 
28 000 
Training of public authorities: EUR 387 332; Training of private 
sector: 750 500 EUR 1.1 million 
EU28 x 1 x EUR 134 000 = EUR 3.75 

Total  

Around EUR 11 million 

a) Awareness raising 

Each Member State could invest in awareness-raising activities at the national and local 
level (EUR 80-90 000). EU funding could be used for this.  

b) Reinforce SOLVIT  

SOLVIT  could  be  used  to  coordinate  the  awareness-raising  campaign:  one  additional 
FTE might be needed to coordinate the action in each country. The costs would be lower 
in some Member States and higher in others. The average salary for the additional FTE is 
based upon a grade 5 Commission official’s cost of employment.  

c) Enhanced administrative cooperation 

This would be best achieved through a dedicated group on document security (drawing 
on the expertise of the 'Article 6' Committee).  

It  is  assumed  that  there  would  be  one  or  two  officials  fulfilling  this  role  per  Member 
State and that issues would be discussed by experts of the Article 6 Committee. In this 
way no additional costs would arise apart from the expenses for the participation of two 
more experts. It should be noted that additional activities might need to be undertaken by 
officials apart from simply attending the meetings (e.g. preparation for the meeting and 
follow-up  actions  after the  meeting).  However,  these  costs are  not  accounted  for in  the 
following  estimate  as  they  would  not  necessarily  lead  to  specific  additional  costs  since 
they would form part of the routine function of the official.  

d) EU wide training 

The  key  target  group  would  be  national  authorities,  especially  border  control  officials. 
FRONTEX  could  be  responsible  for  coordinating  this  measure.  FRONTEX  already 
provides  training  for  border  control  officials  on  document  security.  More  training 
sessions than currently are provided would take place. It should be noted that the costs 
for a training courses and road shows have been based on information from FRONTEX 
based  on  its  experience  in  carrying  out  such  workshops.  Furthermore,  the  e-learning 
course does not involve any extra-costs as it has already been developed by FRONTEX.  

Measures 

Two-week training course at FRONTEX with 
one  subject  matter  expert 
from  each 
Member State  

Price per 
Unit 
130 666218 

Amount of training 
p.a. 
2 training sessions at 

FRONTEX 

Total EUR 

EUR 261 332 

218 Based on the figure provided from FRONTEX: 70 000€ for 15 participants, the costs for a workshop 
with 28 participants should be EUR 1 050 000. 

87 

 
 
 
                                                 
Road  shows  at  major  airports,  ports  and 
external land borders 

E-learning Course 

Total  

4 500 

28 training sessions, 

EUR 126 000 

one in each 
Member State 

Unknown 

All border guards 

0219 
EUR 387 332 

A  series  of  training  sessions  would  also  be  organised  for  the  private  sector.  The 
associations would then be responsible for disseminating the findings of the  workshops 
to  their  members.  There  would  obviously  be  additional  costs  related  to  associations 
engaging in training sessions with their respective industry. However, this cost would not 
be that significant given that these training sessions probably already take place or could 
be  linked  to  other  events/training  sessions.  The  high-level  training  would  however 
contribute to increased effectiveness of those training sessions.  

Summary - Cost of training sessions for private stakeholders 

Total (EUR) 

Number of training sessions per year 

Average number of participants per session 

Cost of paying for trainer(s) (per session) 

Average cost of hiring a meeting room for three days with catering 

Average cost of travel and subsistence per meeting per expert 

Cost of materials/handouts per participant  

E-learning Course for all employees  

Total  

56 (2 per MS) 

35 

EUR 1 500 

EUR 2 250 

EUR 300 

EUR 25 
EUR 0220 
EUR 752 350 

e) Points of Contact 

A Points of Contact system would need to be established by the national authorities and 
could be hosted by one of the Ministries, SOLVIT, etc. This would require one member 
of  staff  being  designate  as  the  contact  in  each  EU  Member  State.  It  can  therefore  be 
assumed that the costs of this measure are equal to the cost estimated under a) Awareness 
raising.  

3. Multi-criteria Analysis – methodology applied 

Multi-criteria  analysis  is  one  of  the  tools  presented  in  the  Better  Regulation  "Toolbox" 
(Tool #63) to compare the different policy options. It is a non-monetary approach and its 
main  advantage  is  that  it  allows  considering  simultaneously  a  significant  number  of 
objectives, criteria and relations. 

Let’s  look  at  the  example  of  the  policy  instrument  ID  cards  presented  in  this  report. 
There are five different options (including the baseline scenario) which are assessed and 
compared against 6 different criteria. One of the ID option might be better than another 

219 As mentioned, the e-learning tool is already developed by FRONTEX. Therefore, there might be some 
further  costs  involved  in  extending  the  elements  of  the  e-learning  tool  related  to  ID  and  residence 
documents. However, once developed the e-learning tool could be distributed for free to all border guards.  
220 Same Frontex tool as the one developed for border guards could be used.  

88 

 
 
 
 
 
 
                                                 
option  according  to  one  criterion  (e.g.  efficiency)  but  worse  according  to  another  (e.g. 
reduction  of  document  fraud).  Thus,  there  is  no  solution  optimising  all  criteria 
simultaneously  and  therefore a compromise solution  has  to be found (Giuseppe, 2003). 
Multi-criteria  analysis  gives  the  opportunity  to  deal  with  policy  issues  characterised  by 
various  conflicting  assessments,  thus  allowing  for  an  integrated  assessment  of  the 
problem at hand. 

The  multi-criteria  problem  is  described  the  following  way  (Giuseppe,  2003;  Giuseppe, 
2017): 

Step 1 – Impact matrix 

  A is a finite set of N feasible options, 𝐴 = {𝑎, 𝑏, … , 𝑁} 
  M is the number of different evaluation criteria 𝐺 = {𝑔𝑀}, 𝑚 = 1,2, … , 𝑀 

considered relevant in a policy problem. 

Taking as an example the case of ID cards, table 1 presents the impact matrix where all 
the  possible  options  (N=5)  are  assessed  against  the  criteria  (M=6).  The  impact  matrix 
shows i) the number of criteria in favour of a given option; ii) the weight attached to each 
single criterion; and iii) the relationship of each single option with all the other options. 

Regarding the weights, let's assume the existence of a set of individual criterion weights 
W = {𝑤𝑀}, m=1,2,...,M, with ∑
= 1. In this case, we assume equal weights then 
wm=1/6.  Despite  of  equal  weights, please  be  aware  that  three  of  the  criteria  considered 
are under the umbrella of a broader criterion – effectiveness, therefore a higher weight is 
given this criterion. 

𝑀
𝑚=1

𝑤𝑚

Table.1 Comparison of the options within the Policy Option ID 

# 

Criteria 

𝒘𝒎  BL 

ID SOFT) 

ID 1) 

ID 2) 

ID 3) 

Effectiveness towards the objectives 

1 

2 

3 

Improvement of authentication of documents 
and reduction of document fraud 

Improvement of acceptance of documents 

Simplification of daily life for citizens and to 
cut red tape 

1/6 

1/6 

1/6 

Efficiency 

Costs 

Benefits 

4 

5 

6 

(COSTS VS BENEFITS)  1/6 

Coherence (with other policies221) 

Proportionality 

1/6 

1/6 

0 

0 

0 

0 

0 

0 

0 

0 

+ 

+ 

+ 

-/0 

+ 

0/+ 

+ 

+/++ 

++/+++ 

+++ 

+/++ 

++ 

++ 

++ 

++ 

+/++ 

+/++ 

- 

-- 

- 

++/+++ 

+++ 

+/++ 

+/++ 

+ 

+ 

+ 

+ 

0/+ 

0/+ 

0 

- 

Note: 

The evaluation is based on a scale of 10 steps from very limited impact (--) to very high impact (+++) 
"0" indicates no change (i.e. neutrality) 

221 In particular Fundamental rights, data protection and digital policies 

89 

 
 
 
 
                                                 
𝑤𝑚 weight of each criterion 

The next steps shall allow to use the information available above to rank in a complete 
pre-order (I.e. without any incomparability relation) all the options from the best one to 
the worst one. In order to do so, the mathematical aggregation convention can be divided 
in two main steps: 

1.  Pair-wise comparison of options according to the whole set of individual criteria 

used (step 2) 

2.  Ranking of options in a complete pre-order (step 3) 

Step 2 - Pair-wise comparison of options 

Where the option a is evaluated to be better than option b (both belonging to the set A) 
according to the mth criteria, then 𝑔𝑚(a) > 𝑔𝑚(b). In this way a decision problem may be 
represented in a N x M matrix, E, called outranking matrix (Arrow and Raynaud, 1986; 
Roy, 1996). Any generic element of E: 𝑒𝑗𝑘, j ≠ k is the result of the pair-wise comparison, 
according  to  all  the  M  individual  criteria,  between  options  j  and  k.  Such  a  global  pair-
wise comparison is obtained by means of equation: 

𝑒𝑗𝑘 = ∑

𝑀
𝑚=1

(𝑤𝑚(𝑃𝑗𝑘) +

1

2

𝑤𝑚(𝐼𝑗𝑘))

,  

Where  𝑤𝑚(𝑃𝑗𝑘)  and  𝑤𝑚(𝐼𝑗𝑘)  are  the  weights  of  individual  criteria  presenting  a 
preference a ≻ b and an indifference relation (a ~ b), respectively. It clearly holds 

𝑒𝑗𝑘 +   𝑒𝑘𝑗   = 1  

In another words and coming back to our ID cards case, options are compared pairwise. 
For  each  comparison  (e.g.  ID  1  versus  ID  2  –  hereafter,  abbreviated  as  "12")  all  the 
weights are summed for the criteria where Option ID 1 is preferred over Options ID 2 (in 
case of option ID 1 being indifferent of ID 2 half of the weight is given). In this case, ID1 
vs ID2 receives the weights of criteria 4 and 6 and half of the weights of criteria 2, 3 and 
1
1
5m i.e., (2 ×
). For comparison ID 2 vs ID 1 receives the weights of the 
) + (3 ×
6
6
other criteria.  

  ×

1

2

Table.2 Pair-wise comparison of options [Policy Options (N) = 5; Criteria (M) = 6] 

B 

0 

1 

1 

1 

S 

0 

0 

3/4 

3/4 

1 

0 

1/4 

0 

5/12 

3/4 

7/12 

0 

2 

0 

1/4 

7/12 

0 

0 

3 

1/4 

5/12 

1 

1 

0 

B 
S 
1 
2 
3 

Step 3 - Ranking of options 

90 

 
 
 
  
 
Call R the set of all N! possible complete rankings of alternatives, R={𝑟𝑠}, s = 1 ,2, ..., 
N!. For each 𝑟𝑠, the corresponding score 𝜑𝑠 are computed as the summation of 𝑒𝑗𝑘 over 
all the (𝑁

2) pairs 𝑗, 𝑘 of alternatives, i.e., 

𝜑𝑠 =   ∑ 𝑒𝑗𝑘 , 

where 𝑗 ≠ 𝑘, 𝑠 = 1,2, … , 𝑁! and 𝑒𝑗𝑘 ∈ 𝑅. 

The final ranking (𝐫∗) is the one which maximises the following equation: 

𝒓∗ ⇔ 𝜑∗ = 𝑚𝑎𝑥 ∑ 𝑒𝑗𝑘  𝑤ℎ𝑒𝑟𝑒 𝑒𝑗𝑘 ∈ 𝑅. 

In the case of the ID cards, policy options can be ranked in 5! (=120) ways (see table 3). 
For example, the score for the ranking "BS123" is the score of BS plus those of B1, B2, 
B3, S1, S2, S3, 12, 13 and 23 (all ordered pairs from left to right). The optimal ranking is 
the  one  with  the  maximum  likelihood  score,  i.e.,  "123SB"  (ID  1,  followed  by  ID  2, 
followed  by  ID  3,  followed  by  ID  SOFT  and  followed  by  the  baseline  scenario). 
Therefore the preferred option is ID 1. 

Table.3 Ranking of Policy Options ID cards 

 Ranking 

 POLICY PAIRINGS  

BS123 
BS132 
BS213 
BS231 
BS312 
BS321 
B1S23 
B1S32 
B12S3 
B123S 
B13S2 
B132S 
B2S13 
B2S31 
B21S3 
B213S 
B23S1 
B231S 
B3S12 
B3S21 
B31S2 
B312S 
B32S1 
B321S 
SB123 

BS 
BS 
BS 
BS 
BS 
BS 
B1 
B1 
B1 
B1 
B1 
B1 
B2 
B2 
B2 
B2 
B2 
B2 
B3 
B3 
B3 
B3 
B3 
B3 
SB 

B1 
B1 
B2 
B2 
B3 
B3 
BS 
BS 
B2 
B2 
B3 
B3 
BS 
BS 
B1 
B1 
B3 
B3 
BS 
BS 
B1 
B1 
B2 
B2 
S1 

B2 
B3 
B1 
B3 
B1 
B2 
B2 
B3 
BS 
B3 
BS 
B2 
B1 
B3 
BS 
B3 
BS 
B1 
B1 
B2 
BS 
B2 
BS 
B1 
S2 

B3 
B2 
B3 
B1 
B2 
B1 
B3 
B2 
B3 
BS 
B2 
BS 
B3 
B1 
B3 
BS 
B1 
BS 
B2 
B1 
B2 
BS 
B1 
BS 
S3 

S3 
S2 
S3 
S1 
S2 
S1 
13 
12 
13 
1S 
12 
1S 
23 
21 
23 
2S 
21 
2S 
32 
31 
32 
3S 
31 
3S 
B3 

12 
13 
21 
23 
31 
32 
S2 
S3 
2S 
23 
3S 
32 
S1 
S3 
1S 
13 
3S 
31 
S1 
S2 
1S 
12 
2S 
21 
12 

13 
12 
23 
21 
32 
31 
S3 
S2 
23 
2S 
32 
3S 
S3 
S1 
13 
1S 
31 
3S 
S2 
S1 
12 
1S 
21 
2S 
13 

S2 
S3 
S1 
S3 
S1 
S2 
12 
13 
1S 
13 
1S 
12 
21 
23 
2S 
23 
2S 
21 
31 
32 
3S 
32 
3S 
31 
B2 

S1 
S1 
S2 
S2 
S3 
S3 
1S 
1S 
12 
12 
13 
13 
2S 
2S 
21 
21 
23 
23 
3S 
3S 
31 
31 
32 
32 
B1 

91 

Final 
Score 

3.75 
2.75 
3.58 
2.58 
1.75 
1.58 
4.25 
3.25 
4.75 
4.92 
3.42 
3.92 
4.08 
3.08 
4.58 
4.75 
3.25 
3.75 
1.92 
1.75 
2.42 
2.92 
2.25 
2.75 
4.75 

23 
32 
13 
31 
12 
21 
23 
32 
S3 
3S 
S2 
2S 
13 
31 
S3 
3S 
S1 
1S 
12 
21 
S2 
2S 
S1 
1S 
23 

 
 
 Ranking 

 POLICY PAIRINGS  

SB132 
SB213 
SB231 
SB312 
SB321 
S1B23 
S1B32 
S12B3 
S123B 
S13B2 
S132B 
S2B13 
S2B31 
S21B3 
S213B 
S23B1 
S231B 
S3B12 
S3B21 
S31B2 
S312B 
S32B1 
S321B 
1BS23 
1BS32 
1B2S3 
1B23S 
1B3S2 
1B32S 
1SB23 
1SB32 
1S2B3 
1S23B 
1S3B2 
1S32B 
12BS3 
12B3S 
12SB3 
12S3B 
123BS 
123SB 
13BS2 

SB 
SB 
SB 
SB 
SB 
S1 
S1 
S1 
S1 
S1 
S1 
S2 
S2 
S2 
S2 
S2 
S2 
S3 
S3 
S3 
S3 
S3 
S3 
1B 
1B 
1B 
1B 
1B 
1B 
1S 
1S 
1S 
1S 
1S 
1S 
12 
12 
12 
12 
12 
12 
13 

S1 
S2 
S2 
S3 
S3 
SB 
SB 
S2 
S2 
S3 
S3 
SB 
SB 
S1 
S1 
S3 
S3 
SB 
SB 
S1 
S1 
S2 
S2 
1S 
1S 
12 
12 
13 
13 
1B 
1B 
12 
12 
13 
13 
1B 
1B 
1S 
1S 
13 
13 
1B 

S3 
S1 
S3 
S1 
S2 
S2 
S3 
SB 
S3 
SB 
S2 
S1 
S3 
SB 
S3 
SB 
S1 
S1 
S2 
SB 
S2 
SB 
S1 
12 
13 
1S 
13 
1S 
12 
12 
13 
1B 
13 
1B 
12 
1S 
13 
1B 
13 
1B 
1S 
1S 

B2 
B3 
B1 
B2 
B1 
13 
12 
13 
1B 
12 
1B 
23 
21 
23 
2B 
21 
2B 
32 
31 
32 
3B 
31 
3B 
B3 
B2 
B3 
BS 
B2 
BS 
S3 
S2 
S3 
SB 
S2 
SB 
23 
2S 
23 
2B 
2S 
2B 
32 

13 
21 
23 
31 
32 
B2 
B3 
2B 
23 
3B 
32 
B1 
B3 
1B 
13 
3B 
31 
B1 
B2 
1B 
12 
2B 
21 
S2 
S3 
2S 
23 
3S 
32 
B2 
B3 
2B 
23 
3B 
32 
BS 
B3 
SB 
S3 
3B 
3S 
BS 

12 
23 
21 
32 
31 
B3 
B2 
23 
2B 
32 
3B 
B3 
B1 
13 
1B 
31 
3B 
B2 
B1 
12 
1B 
21 
2B 
S3 
S2 
23 
2S 
32 
3S 
B3 
B2 
23 
2B 
32 
3B 
B3 
BS 
S3 
SB 
3S 
3B 
B2 

S2 
S3 
S1 
S2 
S1 
S3 
S2 
S3 
SB 
S2 
SB 
S3 
S1 
S3 
SB 
S1 
SB 
S2 
S1 
S2 
SB 
S1 
SB 
13 
12 
13 
1S 
12 
1S 
13 
12 
13 
1B 
12 
1B 
13 
1S 
13 
1B 
1S 
1B 
12 

B3 
B1 
B3 
B1 
B2 
12 
13 
1B 
13 
1B 
12 
21 
23 
2B 
23 
2B 
21 
31 
32 
3B 
32 
3B 
31 
B2 
B3 
BS 
B3 
BS 
B2 
S2 
S3 
SB 
S3 
SB 
S2 
2S 
23 
2B 
23 
2B 
2S 
3S 

B1 
B2 
B2 
B3 
B3 
1B 
1B 
12 
12 
13 
13 
2B 
2B 
21 
21 
23 
23 
3B 
3B 
31 
31 
32 
32 
BS 
BS 
B2 
B2 
B3 
B3 
SB 
SB 
S2 
S2 
S3 
S3 
2B 
2B 
2S 
2S 
23 
23 
3B 

92 

Final 
Score 

3.75 
4.58 
3.58 
2.75 
2.58 
5.75 
4.75 
6.75 
7.25 
5.25 
6.25 
5.58 
4.58 
6.58 
7.08 
5.08 
6.08 
3.25 
3.08 
4.25 
5.25 
4.08 
5.08 
5.25 
4.25 
5.75 
5.92 
4.42 
4.92 
6.25 
5.25 
7.25 
7.75 
5.75 
6.75 
6.75 
6.92 
7.75 
8.25 
7.42 
8.42 
4.92 

32 
13 
31 
12 
21 
23 
32 
B3 
3B 
B2 
2B 
13 
31 
B3 
3B 
B1 
1B 
12 
21 
B2 
2B 
B1 
1B 
23 
32 
S3 
3S 
S2 
2S 
23 
32 
B3 
3B 
B2 
2B 
S3 
3S 
B3 
3B 
BS 
SB 
S2 

 
 
 Ranking 

 POLICY PAIRINGS  

13B2S 
13SB2 
13S2B 
132BS 
132SB 
2BS13 
2BS31 
2B1S3 
2B13S 
2B3S1 
2B31S 
2SB13 
2SB31 
2S1B3 
2S13B 
2S3B1 
2S31B 
21BS3 
21B3S 
21SB3 
21S3B 
213BS 
213SB 
23BS1 
23B1S 
23SB1 
23S1B 
231BS 
231SB 
3BS12 
3BS21 
3B1S2 
3B12S 
3B2S1 
3B21S 
3SB12 
3SB21 
3S1B2 
3S12B 
3S2B1 
3S21B 
31BS2 

13 
13 
13 
13 
13 
2B 
2B 
2B 
2B 
2B 
2B 
2S 
2S 
2S 
2S 
2S 
2S 
21 
21 
21 
21 
21 
21 
23 
23 
23 
23 
23 
23 
3B 
3B 
3B 
3B 
3B 
3B 
3S 
3S 
3S 
3S 
3S 
3S 
31 

1B 
1S 
1S 
12 
12 
2S 
2S 
21 
21 
23 
23 
2B 
2B 
21 
21 
23 
23 
2B 
2B 
2S 
2S 
23 
23 
2B 
2B 
2S 
2S 
21 
21 
3S 
3S 
31 
31 
32 
32 
3B 
3B 
31 
31 
32 
32 
3B 

12 
1B 
12 
1B 
1S 
21 
23 
2S 
23 
2S 
21 
21 
23 
2B 
23 
2B 
21 
2S 
23 
2B 
23 
2B 
2S 
2S 
21 
2B 
21 
2B 
2S 
31 
32 
3S 
32 
3S 
31 
31 
32 
3B 
32 
3B 
31 
3S 

3S 
32 
3B 
3S 
3B 
B3 
B1 
B3 
BS 
B1 
BS 
S3 
S1 
S3 
SB 
S1 
SB 
13 
1S 
13 
1B 
1S 
1B 
31 
3S 
31 
3B 
3S 
3B 
B2 
B1 
B2 
BS 
B1 
BS 
S2 
S1 
S2 
SB 
S1 
SB 
12 

B2 
SB 
S2 
2B 
2S 
S1 
S3 
1S 
13 
3S 
31 
B1 
B3 
1B 
13 
3B 
31 
BS 
B3 
SB 
S3 
3B 
3S 
BS 
B1 
SB 
S1 
1B 
1S 
S1 
S2 
1S 
12 
2S 
21 
B1 
B2 
1B 
12 
2B 
21 
BS 

BS 
S2 
SB 
2S 
2B 
S3 
S1 
13 
1S 
31 
3S 
B3 
B1 
13 
1B 
31 
3B 
B3 
BS 
S3 
SB 
3S 
3B 
B1 
BS 
S1 
SB 
1S 
1B 
S2 
S1 
12 
1S 
21 
2S 
B2 
B1 
12 
1B 
21 
2B 
B2 

1S 
12 
1B 
1S 
1B 
23 
21 
23 
2S 
21 
2S 
23 
21 
23 
2B 
21 
2B 
23 
2S 
23 
2B 
2S 
2B 
21 
2S 
21 
2B 
2S 
2B 
32 
31 
32 
3S 
31 
3S 
32 
31 
32 
3B 
31 
3B 
32 

32 
3B 
32 
3B 
3S 
B1 
B3 
BS 
B3 
BS 
B1 
S1 
S3 
SB 
S3 
SB 
S1 
1S 
13 
1B 
13 
1B 
1S 
3S 
31 
3B 
31 
3B 
3S 
B1 
B2 
BS 
B2 
BS 
B1 
S1 
S2 
SB 
S2 
SB 
S1 
1S 

3B 
3S 
3S 
32 
32 
BS 
BS 
B1 
B1 
B3 
B3 
SB 
SB 
S1 
S1 
S3 
S3 
1B 
1B 
1S 
1S 
13 
13 
3B 
3B 
3S 
3S 
31 
31 
BS 
BS 
B1 
B1 
B2 
B2 
SB 
SB 
S1 
S1 
S2 
S2 
1B 

93 

Final 
Score 

5.42 
5.92 
6.92 
6.42 
7.42 
5.08 
4.08 
5.58 
5.75 
4.25 
4.75 
6.08 
5.08 
7.08 
7.58 
5.58 
6.58 
6.58 
6.75 
7.58 
8.08 
7.25 
8.25 
4.75 
5.25 
5.75 
6.75 
6.25 
7.25 
2.42 
2.25 
2.92 
3.42 
2.75 
3.25 
3.42 
3.25 
4.42 
5.42 
4.25 
5.25 
3.92 

2S 
B2 
2B 
BS 
SB 
13 
31 
S3 
3S 
S1 
1S 
13 
31 
B3 
3B 
B1 
1B 
S3 
3S 
B3 
3B 
BS 
SB 
S1 
1S 
B1 
1B 
BS 
SB 
12 
21 
S2 
2S 
S1 
1S 
12 
21 
B2 
2B 
B1 
1B 
S2 

 
 
 Ranking 

 POLICY PAIRINGS  

31B2S 
31SB2 
31S2B 
312BS 
312SB 
32BS1 
32B1S 
32SB1 
32S1B 
321BS 
321SB 

31 
31 
31 
31 
31 
32 
32 
32 
32 
32 

32 

3B 
3S 
3S 
32 
32 
3B 
3B 
3S 
3S 
31 

31 

32 
3B 
32 
3B 
3S 
3S 
31 
3B 
31 
3B 

3S 

3S 
32 
3B 
3S 
3B 
31 
3S 
31 
3B 
3S 

3B 

1B 
1S 
1S 
12 
12 
2B 
2B 
2S 
2S 
21 

21 

12 
1B 
12 
1B 
1S 
2S 
21 
2B 
21 
2B 

2S 

1S 
12 
1B 
1S 
1B 
21 
2S 
21 
2B 
2S 

2B 

B2 
SB 
S2 
2B 
2S 
BS 
B1 
SB 
S1 
1B 

1S 

BS 
S2 
SB 
2S 
2B 
B1 
BS 
S1 
SB 
1S 

1B 

2S 
B2 
2B 
BS 
SB 
S1 
1S 
B1 
1B 
BS 

SB 

Final 
Score 

4.42 
4.92 
5.92 
5.42 
6.42 
3.75 
4.25 
4.75 
5.75 
5.25 
6.25 

The same applies to the other policy instruments RES and Process. 

Policy Instrument RES 

Step 1 – Impact matrix 

Table.4 Comparison of the options within the Policy Option RES 

# 

Criteria 

𝒘𝒎  BL  RES SOFT)  RES 1)  RES 2)  RES 3) 

Effectiveness towards the objectives 

1 

2 

3 

Improvement of authentication of 
documents and reduction of document fraud 

1/6 

Improvement of acceptance of documents 

1/6 

Simplification of daily life for citizens and to 
cut red tape 

1/6 

Efficiency 

Costs 

Benefits 

4 

5 

6 

(COSTS VS BENEFITS)  1/6 

Coherence (with other policies222) 

Proportionality 

1/6 

1/6 

0 

0 

0 

0 

0 

0 

0 

0 

0/+ 

0/+ 

0/+ 

0 

+ 

+ 

0/+ 

0/+ 

+/++ 

++ 

++/+++ 

+/++ 

++ 

++/+++ 

+/++ 

++ 

++ 

-/0 

- 

--/--- 

+/++ 

++/+++ 

+++ 

+ 

+ 

+ 

+/++ 

+ 

+ 

0/+ 

0/+ 

0/+ 

Note: 

The evaluation is based on a scale of 10 steps from very limited impact (--) to very high impact (+++) 
"0" indicates no change (i.e. neutrality) 
𝑤𝑚 weight of each criterion 

222 In particular Fundamental rights, data protection and digital policies 

94 

 
 
 
 
 
 
                                                 
Step 2 - Pair-wise comparison of options 

Table.5 Pair-wise comparison of options [Policy Options (N) = 5; Criteria (M) = 6] 

B 

0    

1    

1    

1    

1    

S 

0    

0    

 11/12 

1    

1    

1 

0    

 1/12 

0    

 5/6  

 1/2  

2 

0    

0    

3 

0    

0    

 1/6  

 1/2  

0    

 7/12 

 5/12 

0    

B 
S 
1 
2 
3 

Step 3 - Ranking of options (R=5!) 

Table.6 Ranking of Policy Options RES 

 Ranking 

POLICY PAIRINGS  

BS123 
BS132 
BS213 
BS231 
BS312 
BS321 
B1S23 
B1S32 
B12S3 
B123S 
B13S2 
B132S 
B2S13 
B2S31 
B21S3 
B213S 
B23S1 
B231S 
B3S12 
B3S21 
B31S2 
B312S 
B32S1 
B321S 
SB123 
SB132 
SB213 
SB231 

BS 
BS 
BS 
BS 
BS 
BS 
B1 
B1 
B1 
B1 
B1 
B1 
B2 
B2 
B2 
B2 
B2 
B2 
B3 
B3 
B3 
B3 
B3 
B3 
SB 
SB 
SB 
SB 

B1 
B1 
B2 
B2 
B3 
B3 
BS 
BS 
B2 
B2 
B3 
B3 
BS 
BS 
B1 
B1 
B3 
B3 
BS 
BS 
B1 
B1 
B2 
B2 
S1 
S1 
S2 
S2 

B2 
B3 
B1 
B3 
B1 
B2 
B2 
B3 
BS 
B3 
BS 
B2 
B1 
B3 
BS 
B3 
BS 
B1 
B1 
B2 
BS 
B2 
BS 
B1 
S2 
S3 
S1 
S3 

B3 
B2 
B3 
B1 
B2 
B1 
B3 
B2 
B3 
BS 
B2 
BS 
B3 
B1 
B3 
BS 
B1 
BS 
B2 
B1 
B2 
BS 
B1 
BS 
S3 
S2 
S3 
S1 

S2 
S3 
S1 
S3 
S1 
S2 
12 
13 
1S 
13 
1S 
12 
21 
23 
2S 
23 
2S 
21 
31 
32 
3S 
32 
3S 
31 
B2 
B3 
B1 
B3 

S1 
S1 
S2 
S2 
S3 
S3 
1S 
1S 
12 
12 
13 
13 
2S 
2S 
21 
21 
23 
23 
3S 
3S 
31 
31 
32 
32 
B1 
B1 
B2 
B2 

95 

S3 
S2 
S3 
S1 
S2 
S1 
13 
12 
13 
1S 
12 
1S 
23 
21 
23 
2S 
21 
2S 
32 
31 
32 
3S 
31 
3S 
B3 
B2 
B3 
B1 

12 
13 
21 
23 
31 
32 
S2 
S3 
2S 
23 
3S 
32 
S1 
S3 
1S 
13 
3S 
31 
S1 
S2 
1S 
12 
2S 
21 
12 
13 
21 
23 

13 
12 
23 
21 
32 
31 
S3 
S2 
23 
2S 
32 
3S 
S3 
S1 
13 
1S 
31 
3S 
S2 
S1 
12 
1S 
21 
2S 
13 
12 
23 
21 

Final 
Score 

1.33 
1.17 
2.00 
2.00 
1.17 
1.83 
2.17 
2.00 
3.17 
4.17 
3.00 
4.00 
3.00 
3.00 
3.83 
4.83 
4.00 
4.83 
2.17 
2.83 
3.00 
4.00 
3.83 
4.67 
2.33 
2.17 
3.00 
3.00 

23 
32 
13 
31 
12 
21 
23 
32 
S3 
3S 
S2 
2S 
13 
31 
S3 
3S 
S1 
1S 
12 
21 
S2 
2S 
S1 
1S 
23 
32 
13 
31 

 
 
  
 
 Ranking 

POLICY PAIRINGS  

SB312 
SB321 
S1B23 
S1B32 
S12B3 
S123B 
S13B2 
S132B 
S2B13 
S2B31 
S21B3 
S213B 
S23B1 
S231B 
S3B12 
S3B21 
S31B2 
S312B 
S32B1 
S321B 
1BS23 
1BS32 
1B2S3 
1B23S 
1B3S2 
1B32S 
1SB23 
1SB32 
1S2B3 
1S23B 
1S3B2 
1S32B 
12BS3 
12B3S 
12SB3 
12S3B 
123BS 
123SB 
13BS2 
13B2S 
13SB2 
13S2B 

SB 
SB 
S1 
S1 
S1 
S1 
S1 
S1 
S2 
S2 
S2 
S2 
S2 
S2 
S3 
S3 
S3 
S3 
S3 
S3 
1B 
1B 
1B 
1B 
1B 
1B 
1S 
1S 
1S 
1S 
1S 
1S 
12 
12 
12 
12 
12 
12 
13 
13 
13 
13 

S3 
S3 
SB 
SB 
S2 
S2 
S3 
S3 
SB 
SB 
S1 
S1 
S3 
S3 
SB 
SB 
S1 
S1 
S2 
S2 
1S 
1S 
12 
12 
13 
13 
1B 
1B 
12 
12 
13 
13 
1B 
1B 
1S 
1S 
13 
13 
1B 
1B 
1S 
1S 

S1 
S2 
S2 
S3 
SB 
S3 
SB 
S2 
S1 
S3 
SB 
S3 
SB 
S1 
S1 
S2 
SB 
S2 
SB 
S1 
12 
13 
1S 
13 
1S 
12 
12 
13 
1B 
13 
1B 
12 
1S 
13 
1B 
13 
1B 
1S 
1S 
12 
1B 
12 

S2 
S1 
S3 
S2 
S3 
SB 
S2 
SB 
S3 
S1 
S3 
SB 
S1 
SB 
S2 
S1 
S2 
SB 
S1 
SB 
13 
12 
13 
1S 
12 
1S 
13 
12 
13 
1B 
12 
1B 
13 
1S 
13 
1B 
1S 
1B 
12 
1S 
12 
1B 

B1 
B2 
12 
13 
1B 
13 
1B 
12 
21 
23 
2B 
23 
2B 
21 
31 
32 
3B 
32 
3B 
31 
B2 
B3 
BS 
B3 
BS 
B2 
S2 
S3 
SB 
S3 
SB 
S2 
2S 
23 
2B 
23 
2B 
2S 
3S 
32 
3B 
32 

B3 
B3 
1B 
1B 
12 
12 
13 
13 
2B 
2B 
21 
21 
23 
23 
3B 
3B 
31 
31 
32 
32 
BS 
BS 
B2 
B2 
B3 
B3 
SB 
SB 
S2 
S2 
S3 
S3 
2B 
2B 
2S 
2S 
23 
23 
3B 
3B 
3S 
3S 

96 

B2 
B1 
13 
12 
13 
1B 
12 
1B 
23 
21 
23 
2B 
21 
2B 
32 
31 
32 
3B 
31 
3B 
B3 
B2 
B3 
BS 
B2 
BS 
S3 
S2 
S3 
SB 
S2 
SB 
23 
2S 
23 
2B 
2S 
2B 
32 
3S 
32 
3B 

31 
32 
B2 
B3 
2B 
23 
3B 
32 
B1 
B3 
1B 
13 
3B 
31 
B1 
B2 
1B 
12 
2B 
21 
S2 
S3 
2S 
23 
3S 
32 
B2 
B3 
2B 
23 
3B 
32 
BS 
B3 
SB 
S3 
3B 
3S 
BS 
B2 
SB 
S2 

32 
31 
B3 
B2 
23 
2B 
32 
3B 
B3 
B1 
13 
1B 
31 
3B 
B2 
B1 
12 
1B 
21 
2B 
S3 
S2 
23 
2S 
32 
3S 
B3 
B2 
23 
2B 
32 
3B 
B3 
BS 
S3 
SB 
3S 
3B 
B2 
BS 
S2 
SB 

Final 
Score 

2.17 
2.83 
3.33 
3.17 
4.33 
5.33 
4.17 
5.17 
4.00 
4.00 
5.00 
6.00 
5.00 
6.00 
3.17 
3.83 
4.17 
5.17 
4.83 
5.83 
3.17 
3.00 
4.17 
5.17 
4.00 
5.00 
4.17 
4.00 
5.17 
6.17 
5.00 
6.00 
5.17 
6.17 
6.17 
7.17 
7.17 
8.17 
5.00 
6.00 
6.00 
7.00 

12 
21 
23 
32 
B3 
3B 
B2 
2B 
13 
31 
B3 
3B 
B1 
1B 
12 
21 
B2 
2B 
B1 
1B 
23 
32 
S3 
3S 
S2 
2S 
23 
32 
B3 
3B 
B2 
2B 
S3 
3S 
B3 
3B 
BS 
SB 
S2 
2S 
B2 
2B 

 
 
 Ranking 

POLICY PAIRINGS  

132BS 
132SB 
2BS13 
2BS31 
2B1S3 
2B13S 
2B3S1 
2B31S 
2SB13 
2SB31 
2S1B3 
2S13B 
2S3B1 
2S31B 
21BS3 
21B3S 
21SB3 
21S3B 
213BS 
213SB 
23BS1 
23B1S 
23SB1 
23S1B 
231BS 
231SB 
3BS12 
3BS21 
3B1S2 
3B12S 
3B2S1 
3B21S 
3SB12 
3SB21 
3S1B2 
3S12B 
3S2B1 
3S21B 
31BS2 
31B2S 
31SB2 
31S2B 

13 
13 
2B 
2B 
2B 
2B 
2B 
2B 
2S 
2S 
2S 
2S 
2S 
2S 
21 
21 
21 
21 
21 
21 
23 
23 
23 
23 
23 
23 
3B 
3B 
3B 
3B 
3B 
3B 
3S 
3S 
3S 
3S 
3S 
3S 
31 
31 
31 
31 

12 
12 
2S 
2S 
21 
21 
23 
23 
2B 
2B 
21 
21 
23 
23 
2B 
2B 
2S 
2S 
23 
23 
2B 
2B 
2S 
2S 
21 
21 
3S 
3S 
31 
31 
32 
32 
3B 
3B 
31 
31 
32 
32 
3B 
3B 
3S 
3S 

1B 
1S 
21 
23 
2S 
23 
2S 
21 
21 
23 
2B 
23 
2B 
21 
2S 
23 
2B 
23 
2B 
2S 
2S 
21 
2B 
21 
2B 
2S 
31 
32 
3S 
32 
3S 
31 
31 
32 
3B 
32 
3B 
31 
3S 
32 
3B 
32 

1S 
1B 
23 
21 
23 
2S 
21 
2S 
23 
21 
23 
2B 
21 
2B 
23 
2S 
23 
2B 
2S 
2B 
21 
2S 
21 
2B 
2S 
2B 
32 
31 
32 
3S 
31 
3S 
32 
31 
32 
3B 
31 
3B 
32 
3S 
32 
3B 

3B 
3S 
B1 
B3 
BS 
B3 
BS 
B1 
S1 
S3 
SB 
S3 
SB 
S1 
1S 
13 
1B 
13 
1B 
1S 
3S 
31 
3B 
31 
3B 
3S 
B1 
B2 
BS 
B2 
BS 
B1 
S1 
S2 
SB 
S2 
SB 
S1 
1S 
12 
1B 
12 

32 
32 
BS 
BS 
B1 
B1 
B3 
B3 
SB 
SB 
S1 
S1 
S3 
S3 
1B 
1B 
1S 
1S 
13 
13 
3B 
3B 
3S 
3S 
31 
31 
BS 
BS 
B1 
B1 
B2 
B2 
SB 
SB 
S1 
S1 
S2 
S2 
1B 
1B 
1S 
1S 

97 

3S 
3B 
B3 
B1 
B3 
BS 
B1 
BS 
S3 
S1 
S3 
SB 
S1 
SB 
13 
1S 
13 
1B 
1S 
1B 
31 
3S 
31 
3B 
3S 
3B 
B2 
B1 
B2 
BS 
B1 
BS 
S2 
S1 
S2 
SB 
S1 
SB 
12 
1S 
12 
1B 

2B 
2S 
S1 
S3 
1S 
13 
3S 
31 
B1 
B3 
1B 
13 
3B 
31 
BS 
B3 
SB 
S3 
3B 
3S 
BS 
B1 
SB 
S1 
1B 
1S 
S1 
S2 
1S 
12 
2S 
21 
B1 
B2 
1B 
12 
2B 
21 
BS 
B2 
SB 
S2 

2S 
2B 
S3 
S1 
13 
1S 
31 
3S 
B3 
B1 
13 
1B 
31 
3B 
B3 
BS 
S3 
SB 
3S 
3B 
B1 
BS 
S1 
SB 
1S 
1B 
S2 
S1 
12 
1S 
21 
2S 
B2 
B1 
12 
1B 
21 
2B 
B2 
BS 
S2 
SB 

Final 
Score 

7.00 
8.00 
4.00 
4.00 
4.83 
5.83 
5.00 
5.83 
5.00 
5.00 
6.00 
7.00 
6.00 
7.00 
5.83 
6.83 
6.83 
7.83 
7.83 
8.83 
6.00 
6.83 
7.00 
8.00 
7.83 
8.83 
3.17 
3.83 
4.00 
5.00 
4.83 
5.67 
4.17 
4.83 
5.17 
6.17 
5.83 
6.83 
5.00 
6.00 
6.00 
7.00 

BS 
SB 
13 
31 
S3 
3S 
S1 
1S 
13 
31 
B3 
3B 
B1 
1B 
S3 
3S 
B3 
3B 
BS 
SB 
S1 
1S 
B1 
1B 
BS 
SB 
12 
21 
S2 
2S 
S1 
1S 
12 
21 
B2 
2B 
B1 
1B 
S2 
2S 
B2 
2B 

 
 
 Ranking 

POLICY PAIRINGS  

312BS 
312SB 
32BS1 
32B1S 
32SB1 
32S1B 
321BS 
321SB 

31 
31 
32 
32 
32 
32 
32 

32 

32 
32 
3B 
3B 
3S 
3S 
31 

31 

3B 
3S 
3S 
31 
3B 
31 
3B 

3S 

3S 
3B 
31 
3S 
31 
3B 
3S 

3B 

12 
12 
2B 
2B 
2S 
2S 
21 

21 

1B 
1S 
2S 
21 
2B 
21 
2B 

2S 

1S 
1B 
21 
2S 
21 
2B 
2S 

2B 

2B 
2S 
BS 
B1 
SB 
S1 
1B 

1S 

2S 
2B 
B1 
BS 
S1 
SB 
1S 

1B 

BS 
SB 
S1 
1S 
B1 
1B 
BS 

SB 

Final 
Score 

7.00 
8.00 
5.83 
6.67 
6.83 
7.83 
7.67 
8.67 

The  optimal  rankings  are  the  ones  with  the  maximum  likelihood  score,  i.e.,  "213SB" 
(RES 2, followed by RES 1, followed by RES 3, followed by RES SOFT and followed 
by the baseline scenario) and "231SB" (RES 2, followed by RES 3, followed by RES 1, 
followed by RES SOFT and followed by the baseline scenario). In both of the optional 
rankings RES 2 ranks first and therefore the preferred option is RES 2. 

Policy Instrument PROCESS 

Step 1 – Impact matrix 

Table.7 Comparison of the options within the Policy Option PROCESS 

# 

Criteria 

𝒘𝒎  BL 

PROCESS SOFT) 

PROCESS 1) 

Effectiveness towards the objectives 

1 

2 

Reduction of document fraud 

Simplification of daily life for citizens and to 
cut red tape 

1/5 

1/5 

Efficiency 

Costs 

Benefits 

(COSTS VS BENEFITS) 

1/5 

Coherence (with other policies223) 

Proportionality 

1/5 

1/5 

3 

4 

5 

Note: 

0 

0 

0 

0 

+ 

+ 

+ 

+ 

+ 

0 

+ 

+ 

-/0 

- 

+ 

++ 

-/0 

+/++ 

+/++ 

+ 

+ 

The evaluation is based on a scale of 10 steps from very limited impact (--) to very high impact (+++) 
"0" indicates no change (i.e. neutrality) 
𝑤𝑚 weight of each criterion 

223 In particular Fundamental rights, data protection and digital policies 

98 

 
 
 
 
 
 
 
 
                                                 
Step 2 - Pair-wise comparison of options 

Table.8 Pair-wise comparison of options [Policy Options (N) = 3; Criteria (M) = 5] 

B 

0    

1    

S 

0    

0    

 3/5  

 2/5  

1 

 2/5  

 3/5  

0    

B 
S 
1 

Step 3 - Ranking of options (R=3!) 

Table.9 Ranking of Policy Options PROCESS 

Policy Parings 

Final Score 

BS1 
B1S 
SB1 
S1B 
1BS 
1SB 

BS 
B1 
SB 
S1 
1B 

1S 

B1 
BS 
S1 
SB 
1S 

1B 

S1 
1S 
B1 
1B 
BS 

SB 

1 
0.8 
2 
2.2 
1 
2 

The  optimal  ranking  is  the  one  with  the  maximum  likelihood  score,  i.e.,  "S1B" 
(PROCESS  SOFT,  followed  by  PROCESS  1  and  followed  by  the  baseline  scenario). 
Therefore the preferred option is PROCESS SOFT. 

4. Sensitivity test 

  4 categories of criteria (effectiveness, 

efficiency, coherence and proportionality) 
  Under effectiveness there are 3 individual 

criteria (ID and RES option) and 2 
individual criteria (PROCESS option) 
showing the effectiveness of the options 
towards the objectives of the initiative.  

  Thus, there are in total 6 individual 

criteria 

  When equal weights are used between the 
individual criteria, effectiveness gets the 
highest weight (50% for ID and RES 
options and 40% for PROCESS option). For 
the purpose of the sensitivity analysis, 50% 
is the weight used when you say that a 
category of criteria has the highest weight  

ID Option 

RES OPTION 

PROCESS OPTION 

Weights 
ID and RES 
option 

Weights 
PROCESS 
option 

Ranking 
of 
Options 

Preferred 
Option(s) 

Ranking 
of 
Options 

Preferred 
Option(s) 

Ranking 
of 
Options 

Preferred 
Option(s) 

Equal weights 
between the 
categories of 
criteria 

Effectiveness                          
1/4   
Efficiency                                 
1/4   

Effectiveness                     
1/4   
12S3B 
Efficiency                            
1/4   

Option ID 
1 

213SB 

Option 
RES 2 

SB1 
S1B 

PROCESS 
SOFT 

99 

 
 
  
 
  
 
 
Coherence                               
1/4   
Proportionality                      
1/4   
Effectiveness                          
1/2   
Efficiency                                
1/6  
Coherence                              
1/6 
Proportionality                      
1/6 
Effectiveness                         
1/6 
Efficiency                                
1/2 
Coherence                              
1/6 
Proportionality                     
1/6 
Effectiveness                         
1/6 
Efficiency                                
1/6 
Coherence                              
1/2 
Proportionality                     
1/6 
Effectiveness                         
1/6 
Efficiency                                
1/6 
Coherence                              
1/6 
Proportionality                     
1/2 
Effectiveness         
above around 
1/3 
Efficiency                                
1/7 
Coherence                             
1/7 
Proportionality                    
1/7 

Coherence                          
1/4   
Proportionality                 
1/4   
Effectiveness                     
2/5  
Efficiency                           
1/5 
123SB 
Coherence                         
1/5 
Proportionality                
1/5 
Effectiveness                     
1/6 
Efficiency                            
1/2 
12S3B 
Coherence                          
1/6 
Proportionality                 
1/6 
Effectiveness                      
1/6 
Efficiency                             
1/6 
12S3B 
Coherence                           
1/2 
Proportionality                   
1/6 
Effectiveness                       
1/6 
Efficiency                              
1/6 
S12B3 
Coherence                            
1/6 
Proportionality                    
1/2 
Effectiveness   
above around 
1/3 
Efficiency                             
1/6 
213SB 
Coherence                           
1/6 
Proportionality                   
1/6 

Option ID 
1 

213SB 
231SB 

Option 
RES 2 

S1B 

PROCESS 
SOFT 

Option ID 
1 

213SB 

Option 
RES 2 

S1B 

PROCESS 
SOFT 

Option ID 
1 

213SB 

Option 
RES 2 

SB1 

PROCESS 
SOFT 

Option 
SOFT 

213SB 

Option 
RES 2 

SB1 

PROCESS 
SOFT 

Option ID 
2 

321SB 

Option 
RES 3 

S1B 

PROCESS 
SOFT 

Option 1 is the 
preferred option. 
Option 2 is the 

Option RES 2 
If weight above 1/3, 
option RES 3 is 

N/A as free movement 
is not a SO under this 
option 

Effectiveness 
highest weight 

Efficiency 
highest weigh 

Coherence 
highest weight 

Proportionality 
highest weight 

Effectiveness 
towards 
‘security’ 
objective224 

Effectiveness 
towards ‘free 

224 Increase only the weight of the criteria “Improve authentication of documents and reduce document 
fraud” and all the others have equal weights 

100 

 
 
 
 
                                                 
movement’ 
objective225 

preferred 

preferred option iff If 
the weight given to 
the criterion is very 
close to 1 

225  Increase  only  the  weight  of  the  criteria  “Improve  acceptance  of  documents”  and  all  the  others  have 
equal weights 

101 

 
 
 
 
                                                 
Annex 5: Scope of initiative (ID cards and residence documents)  

ID cards 

According  to  the  Free  Movement  Directive  2004/38/EC,  Member  States  shall  issue  to  their 
own nationals, and renew, an identity card or passport stating their nationality, in accordance 
with their national laws. All national ID cards may be used as travel documents within the EU 
and  when  entering  the  EU  via  its  external  borders.  Under  bilateral  agreements,  many  third 
countries permit EU nationals to enter their territories using their ID cards226. 

Figure 2.1: General types of national ID cards being issued in the European Union 

As  ID  cards  are  less  bulky  and  usually  cheaper  than  passports,  ID  card  ownership  is  much 
more widespread than passport ownership227 and tens of millions of journeys involving entry 
to the EU territory are made every year using ID cards.228 While ID cards are mandatory in 

226 For instance, DE nationals may travel to all of the rest of Europe (except Belarus, Russia and Ukraine) Egypt, 
Georgia, Turkey, Morocco and Tunisia; FR nationals may travel to Europe (except Belarus, Kosovo, Russia and 
Ukraine)  French  overseas  territories,  Egypt,  Turkey,  Georgia,  Dominica,  Montserrat,  Saint,  Saint  Vincent  and 
the Grenadines, and to Jordan and Tunisia. 
227 In countries where ID cards are issued, ID cards are used as the primary form of personal identification and 
for  most  inter-Schengen  journeys.  Passport  ownership  is  therefore  thought  to  be  low,  as  comparatively  fewer 
persons travel outside of EU borders. Even in a country which does not issue ID cards and is not in the Schengen 
area, such as the UK, passport ownership is not universal – there are an estimated 50 million valid UK passports 
in circulation in 2012 for a population of 64 million at that time, or 78%: 
https://www.gov.uk/government/publications/passports-issued-under-the-6-british-citizenship-categories-2007-
to-2012. 
228 FRONTEX data shows that in 2013, there were 548 556 638 arrivals on intra-EU/Schengen flights alone, and 
more than 1.25 billion journeys made crossing an internal border within the Schengen area.  

102 

 
 
 
                                                 
 
some  Member  States  they  are  optional  in  most.  The  costs  of  the  cards  also  vary  greatly  – 
some Member States even issue them for free. 

ID cards are relied on as the main proof of identity within the Member States. ID cards, as a 
proof of identity, enable citizens to have access to financial services (such as opening a bank 
account or obtaining capital and credit), social benefits, healthcare (such as health insurance), 
education (such as enrolling children in school or applying for scholarships) and political and 
legal  rights  (such  as  voting,  filing  petitions  in  courts,  owning  property  or  receiving  an 
inheritance).  
ID cards (see Tables 2.1 and 2.2 for an overview) are issued by all but two Member States229. 
Some  Member  States230  issue  more  than  one  type  of  ID  card.  ID  cards  or  similar  issued  to 
non-nationals are not identity cards as under Directive 2004/38/EC.  

Table 2.1: A selection of currently national ID cards in valid circulation in the European Union 

Austria 

Belgium 

Belgium - kids 

Bulgaria 

Cyprus 

Czech 1 

Czech 2 

Czech 3 

Czech 4 

Czech 5 

Czech 6 

Czech 7 

Czech 8 

Czech 9 

Czech 10 

Czech 11 

Germany 

Estonia 1 

Estonia 2 

Estonia 3 

Estonia 4 

Greece 

Spain 

Finland 

France 

Croatia 

Hungary 

Ireland* 

Italy 1 

Italy 2 

Lithuania 

Luxembourg 

Latvia 

Malta 

Netherlands 

Poland 

229 UK and DK. IE issues a passport card which enables travel within the EU and therefore matches an ID card. 
230 For example, BE and FI issue a specific ID cards for children; EL issue specific ID cards to the military; IT 
delivers  either  paper  or  plastic  ID  cards  (incl.  biometrics)  depending  on  the  municipality,  as  well  as  ID  cards 
with a different colour to inhabitants of the autonomous regions. 

103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Portugal 

Slovakia 
* Ireland issues a “passport card” which qualifies as an ID card. 

Romania 

Sweden 

Slovenia 

Table 2.2: ID documents and their features issued to individuals in Member States231 

Country 

Machine readable 
zone (MRZ) 232 

Chip 

Biometrics 

Greece233 

Italy234 

France 

Romania235 

Austria 

Belgium 

Bulgaria237 

Croatia 

Cyprus 

No 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

P A P E R   C A R D  
No 

No 

No 

No 

L A M I N A T E D   P A P E R  
No 

No 

No 

No 

No 

P L A S T I C   C A R D  

No 

Contact chip 

236

IM, FP

Contactless238 

IM, FP 

Contact 
chip239 

No 

Contactless 

IM, FP 

eID 

No 

No 

No 

No 

No 

Yes 

Yes 

Yes 

No 

Validity regime 
(in yrs) 

15 
10 (18yrs+) 
5 (minors) 
3 (minors <3yrs) 

15 (adults 18+) 
10 (minors) 
Indefinite (55yrs+) 
10 (25-54yrs) 
7 (18-24yrs) 
4 (minors 14-17yrs) 

10 (12yrs or older); 
5 (minors 2-12yrs); 
2 (minors 0-2yrs) 
30 (over 75yrs) 
10 (adults); 
6 (minors 12-18yrs) 
Indefinite (58yrs plus); 
10 (18-57yrs); 
4 (14-17yrs) 

5 

10 (18yrs plus) 
5 (minors) 

231 Note: DK and UK do not issue ID cards. 
232 According to ICAO. 
233 Based on reports the legislation will be enacted in 2017 followed by an open tendering process. Issuance of 
the new ID card may start in 2019. 
234  From  April  2017,  549  communes  have  started  to  deliver  a  plastic  card,  covering  around  50%  of  the 
population (more than 7600 communes in IT) 
235  Romania  is  currently  in  the  process  of  introducing  an  electronic  ID  card  including  biometrics  accessible 
through a contactless chip. 
236 Ministerial decision from 14/5/2017, yet to be implemented, from 2019 (no database). 
237 New card will be introduced in 2018 which is taken into account in the present table. 
238 Contactless chip can be wirelessly accessed. 
239 With iris print. 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Country 

Machine readable 
zone (MRZ) 232 

Chip 

Biometrics 

eID 

Validity regime 
(in yrs) 

Czech 
Republic 

Estonia 

Finland 

Germany 

Hungary 

Ireland 

Italy234 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Slovakia 

Slovenia 

Spain 

Sweden 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Contact chip 

No 

Yes (in 
preparation) 

Contact chip 

Contact chip 

Contactless 

Contactless 

240

No

No 
IM, FP 
(optional) 

IM, FP (on 
request) 

Contactless 

IM 

Contactless 

IM, FP 

Both 

Both 

Contactless 

Contact chip 

Contactless 

No242 

IM, FP 

IM, FP 

IM 

No 

IM 

No 

Contact chip 

IM, FP 

Contact chip 

No 

No 

No 

Both 

IM, FP 

Contact chip 

IM 

Yes 

Yes 

Yes 

Yes 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

No 

Yes 

No 

35 (over 70yrs) 
10 (adults 15-70yrs) 
5 (0-15yrs) 
5 (or 1 yr card with no 
biometric data) 

5 

10 (adults 24yrs+) 
6 (under 24yrs) 
Indefinite (over 65) 
6 (18yrs+) 
3 (minors) 

5 years 

10 (18yrs+) 
5 (minors) 
3 (minors <3yrs) 
5 (5yrs+) 
2-5 (0-4yrs) 
10 (16yrs+) 
5 (under 16yrs) 
10 (16yrs+) 
5 (4-15yrs) 
2 (0-3yrs) 

10 
10 (18yrs+)241 
5 (minors) 
10 (18yrs+) 
10 (minors 5yrs+) 
5 (minors 0-4yrs) 

5 

10 (indefinite for those 
over 60yrs) 
Indefinite (70yrs+) 
10 (18-70yrs) 
5 (3-17yrs) 
3 (0-2yrs) 
Indefinite (>70yrs) 
10 (30-69yrs) 
5 (5-29yrs) 
2 (minors 0-4yrs) 

5 

Legend:   

IM: facial image 

FP: fingerprint 

240 There is a connection to a database where biometric facial images are stored. 
241 For cards first issued 09.03.2014. Two previous ID card models are still in circulation. (1) NLD-BO-03001: 
card first issued 09.10.2011. Valid maximum 5 years, not valid after 08.03.2019. (2) NLD-BO-02001: card first 
issued 26.08.2006. Not valid after 08.10.2016. 
242 We are awaiting confirmation on the precise capabilities of the current PL ID card. 

105 

 
 
 
 
 
 
 
                                                 
Residence documents issued to mobile EU citizens 

The residence documents addressed in this impact assessment are the documents referred to 
by Directive 2004/38/EC.  

Some Member States  issue other cards to  resident  mobile EU citizens,  for various  purposes 
and  with  different  functions,  such  as  to  help  mobile  citizens  interact  with  the  public 
administration and private service providers in that state. They vary greatly in format and like 
some  ID  cards,  they  might  offer  eID  functionality.  These  cards  are  only  considered  here  if 
they are also a residence document pursuant to Directive 2004/38/EC listed below. 

1. Registration certificates stating the right to reside of mobile EU citizens  

Article  8  of  Directive  2004/38/EC  establishes  the  administrative  formalities  which  can  be 
required  from  EU  citizens  living  in  another  Member  State  and  provides  that,  for  periods  of 
residence  longer  than  three  months,  the  host  Member  State  may  require  Union  citizens  to 
register with the relevant authorities. 

This registration certificate records the right of EU citizens to reside in a given Member State. 
It is only issued in countries which establish a registration system.  

A registration certificate sometimes takes the form of a residence card for a mobile EU citizen 
but  it  may  also  just  be  an  A4  letter.  This  document  may  facilitate  administrative  procedure 
and contacts with private operators (banks, utilities….) in the home and host Member State. It 
is not valid as a travel document, regardless whether the issuing national authorities foresee its 
internal national use for identification purposes. 

2. Document certifying permanent residence for EU citizens 

According  to  Article  16  (1)  of  Directive  2004/38/EC  EU  citizens  acquire  a  permanent 
residence right after having resided legally for a period of five consecutive years in the host 
Member State. 

Article  19  of  Directive  2004/38/EC  states  that  upon  application  Member  States  shall  issue 
Union  citizens  entitled  to  permanent  residence,  after  having  verified  duration  of  residence, 
with  a  document  certifying  permanent  residence.  The  document  certifying  permanent 
residence shall be issued as soon as possible. 

The  “document  certifying  permanent  residence”  is  usually  delivered  in  the  format  of  a 
“Permanent  residence  card  for  an  EU  citizen”.  Again,  those  documents  are  not  travel 
documents,  regardless  of  any  additional  uses  they  may  have  made  available  to  them  under 
national law. 

Residence documents issued to third country ("TCN") family members of EU citizens 

Directive  2004/38/EC  provides  for  a  derived  right  to  move  and  reside  in  the  EU  for  third 
country  nationals  (“TCN”)  who  are  family  members243  of  mobile  EU  citizens  who  join  or 
accompany them. 

The residence or permanent residence cards for TCN family members of EU citizens are not 
travel documents, and a non-EU citizen always needs a passport (or other legally acceptable 
identity document) to travel. However, the TCN FAM residence documents exempt a passport 

243 Family members are defined according to Arts. 2(2) and 3(2) Directive 2004/38/EC. 

106 

 
 
                                                 
holder  from  any  visa  obligation  when  accompanying  or  joining  the  EU  family  member 
(Article 5(2) of Directive 2004/38/EC).  

With respect to this function as visa waiver, higher document security standards are required 
and indeed TCN FAM residence documents are better aligned than the residence documents 
issued to EU citizens because Member States committed in a Council statement at the time of 
the  adoption  of  Regulation  380/2008,  on  18  April  2008244  to  use  the  uniform  format  for 
residence permits for third-country nationals for this purpose.245 Many, but certainly not all, 
Member States followed this – legally non-binding – approach. 

1. Residence cards for third country nationals as family members  of EU citizens (hereafter, 
“TCN FAM residence cards”) 

Article 9 of the Directive provides that Member States shall issue a residence card to non-EU 
family members of a Union citizen, if the planned period of residence is for more than three 
months. According to Article 10, their right of residence shall be evidenced by the issuing of a 
document called “Residence card of a family member of a Union citizen”. 

2. Permanent residence cards for TCN family members of EU citizens ("TCN FAM permanent 
residence cards") 

A  TCN  family  member  of  an  EU  citizen  acquires  a  permanent  residence  right  after  having 
legally resided with the EU citizen for a continuous period of five years in the host Member 
State (Article 16 (2) of Directive 2004/38/EC). 

Article 20 of the Directive provides that Member States – within six months of the submission 
of the application – shall issue a permanent residence card to family members of EU citizens 
who  are  entitled  to  permanent  residence.  Such  permanent  residence  cards  are  automatically 
renewable every ten years. 

Table 2.3: Types of residence documents that are issued to individuals  

Member 
States 

Austria 

Belgium 

Bulgaria 

Croatia 

Residence document issued to EU mobile citizens 

Registration 
Certificate 

Residence 
Card EU 

P 

P 

P 

P 

246

PB

PB 

Document 
certifying 
permanent 
residence 

P 

P / PB 

PNB 

PB 

Residence documents issued to TCN 
family members of EU citizens ("TCN 
FAM") 

Residence Card 
TCN FAM 

Permanent 
Residence Card TCN 
FAM 

PNB 

PB 

PNB 

PB 

PNB 

PB 

PNB 

PB 

244 Council Document of 11 June 2008 (13.06), PV/CONS 26 JAI 188, 8622/08 ADD 1. 
245  Council  Regulation  (EC)  No  1030/2002  provides  for  the  possibility  for  Member  States  to  use  the  uniform 
format for purposes other than those covered by the Regulation. It specifically requires that, where they do so, 
appropriate  measures  are  taken  to  ensure  that  confusion  with  residence  permits  within  the  scope  of  the 
Regulation is not possible and that the purpose is clearly indicated in the card. 
246 Belgium issues residence cards (but labelled registration certificate) to EU citizens in the form of a “Carte E / 
E-kaart”. 

107 

 
 
 
 
 
 
                                                 
Member 
States 

Cyprus 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

Residence document issued to EU mobile citizens 

Registration 
Certificate 

Residence 
Card EU 

P 

P (Booklet) 

P 

P 

P 

Residence documents issued to TCN 
family members of EU citizens ("TCN 
FAM") 

Residence Card 
TCN FAM 

Permanent 
Residence Card TCN 
FAM 

P 

P 

Document 
certifying 
permanent 
residence 

P 

P (Booklet) 

P (Booklet) 

P (Booklet) 

P 

PB 

P 

PB 

P 

P 

PNB 

PB 

PB 

PB 

PB 
247

PB

PNB 

PB 

PB 

PB 

PB 

PB 

P (laminated 
case) 

P (laminated case) 

P (laminated 
case) 

P (laminated case) 

P 

PB 

P 

P 

P 

P 

P 

P 

P 

P 

P 

PB 

PNB 

P 

P 

PB 

P 

P 

PNB 

PB 

PB 

P 

PNB 

PB 

P 

P 

PB 

PNB 

PNB 

PNB 

PB 

PB 

P 

PB 

PB 

PB 
248

PB

249

PNB

PB 

P 

PNB 

PB 

PNB 

PNB 

PNB 

PB 

PB 

P 

PB 

PB 

PB 

PB 

PNB 

PB 

P 

PNB 

PB 

PNB 

Legend: P: Paper; PB : Plastic with Biometric Features; PNB = Plastic No Biometric Features; Type; TCN 
FAM= Third Country Family Member 

247 Greece delivers since 2017 residence cards to family members in the uniform format of residence permit with 
biometrics (facial image and fingerprints) 
248 New format from 19 June 2017 for both kind of cards to family members of EU citizens 
249  According  to  the  study,  RO  intends  to  implement  the  uniform  format  for  residence  cards  to  TCN  family 
members 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Annex 6: Consequences to problems identified 

Fraudulent ID and residence documents 

Citizens: ID theft and related costs (money transactions, purchases, etc.)  

Public authorities (Member States): threat to internal security; fraudulent social security claims and use of 
public  services;  longer  processing  times  at  borders;  circumvention  of  legal  migration  routes;  criminal 
activities of fraudulent residence document holders 

Private  sector  services:  fraudulent  and  criminal  activities  related  to  services,  such  as  banking,  airlines, 
insurance companies, car rental services  

ID cards 

Residence documents 

Citizens:  denial  of  entry  at  borders;  denial  of  boarding 
aircrafts; confusion over travel documentation; refusal of 
acceptance  of  national  ID  cards  by  private  and  public 
services,  such  as  when  opening  bank  accounts, 
registering with social security or job centres, enrolling in 
schools  and  universities;  refusal  to  right  to  vote  in  local 
and EP elections; hassle over renewal of ID cards abroad 

S
E
C
N
E
U
Q
E
S
N
O
C

Public authorities (Member States): security gaps in the 
country;  delays  and 
increased  processing  times  at 
borders;  higher  training  investments  for  border  guards; 
lack  of  compatibility  of  technology  for  checking  IDs  and 
lack of return following major investments (e.g. e-Gates); 
claims for compensations following denial of entry 

for  compensations 
Private  sector  services:  claims 
following  denial  of  service  (boarding  aircraft,  etc.); 
increased  processing  times  and  training  investments  at 
e.g. airports and banks  

confusion 

Citizens: denial of entry of TCN family members 
of  EU  citizens  at  the  border  (despite  visa 
exemption); 
travel 
documentation  (residence  cards  wrongly  used 
for  travel);  delays  and  disproportionate  costs  in 
obtaining  residence  documentation;  denial  of 
private  and  public  services  (due  to  combination 
of not accepted ID and residence documents) 

over 

Public  authorities  (Member  States):  in  public 
services  delays  and  increased  processing  times 
for  documents;  higher  training  investments  for 
staff checking residence documents 

Private sector services: claims for compensation 
following  denial  of  boarding  aircraft  of  TCN 
family  members  of  EU  citizens  (due  to  lack  of 
awareness of visa exemption) 

1. Key trends – fraudulent ID and residence documents  

More  generally  in  the  EU,  the  number  of  persons  using  fraudulent  ID  and  residence 
documents  arriving  from  third  countries  increased  around  80%  from  2011  to  2014  (from 
5 255 to 9 420).250 It then decreased by 11% in 2015 (8 373)251 but this does not necessarily 
imply  a  diminishing  problem  since  this  change  could  also  be  due  to  border  guards  being 
overwhelmed  with  the  influx  of  irregular  migrants  and  thus  incapable  of  carrying  out 
document  checks  systematically.  The  total  number  of  persons  detected  with  fraudulent 
documents either entering or exiting the EU, or in transit, increased around 16% from 2013 to 
2015 (from 13 381 to 15 483). 

250 FRONTEX. 2016. Annual Risk Analysis. Based on EU28. Decisions not available for France, Luxembourg, 
the Netherlands and Sweden. For 2014, data from Austria are not available. Data for France are not available for 
2011 and 2012. 
251  FRONTEX. 2016.  Annual  Risk Analysis. p.  14.  The  trend  is also  confirmed  by  the  2017 FRONTEX  Risk 
Analysis, p.22 where the number of persons using fraudulent documents decreased to 7 044. 

109 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
The trend specifically for ID cards is similar to fraudulent documents overall, with a decrease 
in  detections  in  2016.252  Most  detection  of  fraudulent  ID  cards  was  reported  on  air  routes: 
64%  of  the  total  in  2015,  followed  by  land  (32%)  and  sea  (4%),  with  the  rest  being 
unspecified.253 

The  number  of  document  fraud  incidents  on  intra-EU  Schengen  movements  increased 
dramatically in 2015 and was, for the second year in a row, higher than the number of such 
documents detected on extra-EU arrivals. One example is that of Albanian nationals misusing 
Italian and Greek ID cards to enter the UK, another one Ukrainian nationals abusing authentic 
Polish ID cards to get to the UK. There was also an increase in 20% of detection of fraudulent 
documents on air routes from Greece to Germany.254  

As regards the final destination of travellers caught with fraudulent ID cards, the UK tops the 
list (e.g. 1 522 persons in January to August 2016 out of a total of 4 394), followed by Ireland, 
Germany and Italy.255 
UK Government research on the scale of EU document fraud256 

  Generally,  across  all  EU  Member  States  there  appears  a  lack  of  numerical  data  in  the  area  of 
document fraud. According to the UK estimates, every year over 1 000 non-EU nationals arrive at 
the  UK  Border  and  try  to  gain  entry  by  fraudulently  using  European  Union  documentation  and 
pretending to be a Union citizen with a right of free movement257. In addition, the UK Home Office 
states  that  many  thousands  more  fraudulent  documents  are  detected  on  the  way  to  the  UK  by 
carriers and by UK staff based at airports around the world. 

  Of  the  fraudulent  identity  documents  encountered  by  the  UK  authorities  at  borders  and  ports,  a 
consistently  large  majority  are  fraudulent  EU  (and  EEA)  documentation258.  In  2011  Italian  and 
Greek  identity  cards  were  the  most  commonly  abused  documents  by  non-EU  nationals,  and 
accounted for more than one in five false documents identified at the UK border in 2011.259 In total, 
five  of  the  top  ten  abused  documents  encountered  at  the  UK  border  in  2011  were  EU  identity 
cards260.  The  following  table  shows  the  proportion  of  detected  fraudulent  EU/EEA  travel  and 
identity documents fraud at UK borders and ports261. 

252 FRONTEX considers this is largely due to the EU-Turkey migration deal in place since early 2016 and lower 
number of Syrians travelling with fraudulent documents. 
253 FRONTEX. 2016. Annual Risk Analysis. p. 69 
254 FRONTEX. 2016. Annual Risk Analysis. p. 25  
255 FRONTEX data 
256 House of Commons Europe Committee, Documents considered by the Committee on 22 January 2014, No. 2: 
The Free Movement of EU Citizens, paragraph 2.4. 
(http://www.publications.parliament.uk/pa/cm201314/cmselect/cmeuleg/83-xxviii/8305.htm_  
257 UK Home Office, Free Movement Rights — Initial Information for the European Commission (Provided to 
the Commission on 3 December 2013), section 4.2 Abuse of European Union documentation. 
http://www.publications.parliament.uk/pa/cm201314/cmselect/cmeuleg/83-xxviii/8306.htm  
258 Evidence of Fraud and Abuse of Free Movement in the UK (Submitted by UK Government to the 
Commission on 16 September 2013), Ibid, Section 5 – Fraudulent documents. 
(http://www.publications.parliament.uk/pa/cm201314/cmselect/cmeuleg/83-xxviii/8306.htm) 
259 UK Home Office, Free Movement Rights — Initial Information for the European Commission (Provided to 
the Commission on 3 December 2013), section 4.2 Abuse of European Union documentation. 
260 Ibid. 
261 Evidence of Fraud and Abuse of Free Movement in the UK (Submitted by UK Government to the 
Commission on 16 September 2013), Ibid, Section 5 – Fraudulent documents. The documents referred to are 
documents presented as evidence of EU/EEA identity which are either forged, counterfeit or presented by an 
‘impostor’.  

110 

 
 
 
                                                 
Year 

2009 

2010 

2011 

2012 

Total number of fraudulent 
documents detected 

Total number of EU/EEA fraudulent 
documents detected 

1 770 

1 589 

1 857 

1 652 

1 285 

1 172 

1 511 

1 372 

EU/EEA 

% 

73 

74 

81 

83 

Fraudulent ID cards are mainly detected at gate checks at airports and on ferries. Detections 
mainly  occur  through  random  gate  checks  on  intra-Schengen  travellers  and  through  routine 
border checks at the extra-Schengen border. Random checks are decided on the basis of a risk 
profiling analysis. 

A  total  of  4 142  fraudulent  ID  cards  were  detected  between  January  and  August  2016  (see 
Chart A below). The fraudulent ID cards most commonly detected are Italian ones, followed 
by Romanian and Greek ID cards. FRONTEX experts point out that this is not necessarily an 
indication that those ID cards being more easily counterfeited. It could also mean that Italian 
or Romanian counterfeits can be more easily detected, for example because border guards are 
more familiar with them. In the case of Italy, in addition to counterfeited ID cards, there were 
many cases of stolen blanks used to create fake ID cards, and also a few cases of false images 
on genuine cards.  

Chart A: Fraudulent ID documents (broken down by country issuing document), 2015 

1400

1383 

1200

1000

800

600

400

200

0

519 

454 

318 286 269 261 

197 

81  63  50  46  41  38  38  25  16  14  11  9  5  4  2  2  1  0  0  0 

IT RO EL FR ES BG PL BE LT DE NL CY PT CZ HU SK HR SI SE AT LV UK FI

IE EE DK LU MT

Regarding  residence  documents,  the  FRONTEX  data  do  not  distinguish  between  types  of 
residence documents (including TCN FAM cards) and residence permits.  

Chart B below shows the breakdown of fraudulent residence documents by issuing country.  

Counterfeited  residence  documents  are  the  most  common  type  of  fraud  in  Italy,  but  also  in 
Spain (unlike in case of ID cards where imposters were a more common occurrence in Spain). 
In  France,  as  with  ID  cards,  imposters  are  more  common  than  actually  counterfeited 
documents. It is important to note that these detections are in addition to the travel documents 

111 

 
 
 
 
 
carried  by  those  travellers,  since  residence  documents  cannot  be  used  to  enter  or  exit  the 
Schengen area on their own.  

Chart B: Fraudulent residence documents (broken down by country issuing document), 2015 

307 

217 

146 

105 102 96 

58 

28 

300

250

200

150

100

50

0

15  14  12  12  10  9  6  5  4  4  3  3  2  1  1  1  0  0  0 

IT ES FR BE EL SE DE PT PL UK DK NL SI AT LT HU CY CZ RO MT IE LV BG LU EE FI SK

As  Chart  C  shows,  the  number  of  detected  counterfeits  and  stolen  blanks  of  residence 
documents has actually gone down considerably from its peak in 2014, whereas the number of 
imposters has remained stable between 2013 and 2016. According to FRONTEX, this may be 
due to the use by some Member States of the harmonised residence permit format for TCN 
FAM residence documents.  

Chart C: Residence documents (including residence permits) trend (broken down by fraud 
types)262 

262 CSES study (FRONTEX data, 2015) 

112 

 
 
 
 
                                                 
These  documents  are  particularly  important  because  they  are  presented  at  borders  as  a  visa 
waiver when re-entering the EU. Currently there remains a substantial inconsistency for TCN 
FAM residence documents.  

2. Further consequences related to problems with ID cards 

Consequences for citizens 

The current situation limits the full enjoyment of EU free movement rights. EU citizens and 
their  family  members  need  documents  which  can  be  easily  and  reliably  used  in  their 
interactions with public authorities including at the border and with private entities.  

Differences in security features and their consequences for citizens 

Differences  in  the  security  features  of  ID  cards  can  cause  problems  for  citizens  when  they 
exercise their free movement rights and at borders.  

For intra-EU travel and even for travel to/from specific non-EU countries, ID cards are a valid 
travel  documents.  However,  not  all  ID  cards  conform  to  the  ICAO  standards  for  travel 
documents, or not completely. For example, ID cards may conform to the physical parts of the 
standard  by  using  security  printing  and  including  a  machine-readable  zone,  but  may  omit 
some  elements,  such  as  a  signature  or  personal  mark,  or  for  instance  they  may  not  be 
compliant  with  the  electronic  parts  of  standards  (chip  data,  even  when  present,  may  not  be 
accessible). Although valid national ID cards must be accepted as valid travel documents by 
all  Member  States,  these  differences  can  lead  to  longer  waiting  times  for  EU  citizens  when 
their identity is verified at a border.  

E-gates have been introduced at the external borders of many Member States to speed up the 
entry process and reduce staff costs263. E-gates can only be used by EU/EEA/CH citizens who 
own a biometric passport or suitably equipped ID cards. However, because ID cards are not 
standardised, e-gates are often only capable of working with ID cards from the Member State 
where they are situated and not those from other Member States. EU citizens must then use 
the slower manual lanes. For example, the German authorities recently introduced e-gates at 
airports, but due to lacking interoperability, the e-gates can only be used by German nationals 
while other EU citizens and TCNs are required to go through manual checks.264  

Inconveniences  for  citizens  due  to  lack  of  awareness  of  and  prolonged  checks  by  border 
control officials  

Some EU Member States permit a number of different identity cards versions to remain valid 
(as noted for example, the Czech Republic has 10 valid versions) which makes it difficult for 
border guards to assess their validity.  

France  also  prolonged  the  validity  of  expired  ID  cards  by  five  years  (beyond  their  face 
validity) which gave rise to problems at border crossings, where officials were unaware of this 
change.  Moreover,  the  authorities  of  some  other  Member  States  expressly  refuse  to  accept 
them. 

263 See section on Consequences for authorities and administrations below. 
264http://www.spiegel.de/reise/deutschland/easypass-system-an-deutschen-flughaefen-ist-nun-offiziell-a-
975663.html  

113 

 
 
                                                 
Even  though  Member  States  should  exchange  information  about  all  of  their  valid  ID  cards 
versions,  in  many  cases  older,  but  nonetheless  still  valid,  identity  cards  are  not  accepted  as 
valid  travel  documents  in  practice.265  These  problems  persist  despite  the  existence  of  the 
PRADO and FADO databases.  

Confusion over valid travel documentation 

Some  citizens  can  be  confused  with  the  use  of  ID  cards  and  other  documents,  like  driving 
licenses  for  travel  purposes,  wrongly  believing  that  they  can  safely  use  them  to  travel  to 
another EU Member State, notably when residence documents strongly resemble ID cards (for 
instance, the Belgian example, mentioned above). In the same way, some EU citizens wrongly 
believe that a driving licence266 issued in the uniform EU format is a valid travel document 
simply  because  it  bears  their  name  and  photograph  and  because  it  can  be  accepted  as  an 
alternative form of identification in their home country.  

This  misperception  causes  problems  in  practice  for  citizens  such  as  being  denied  boarding 
travel delays and associated financial loss.  

Citizen issues in relation to accessing public services 

In  some  circumstances  ID  cards  from  other  Member  States  are  not  accepted  by  public 
authorities  as  means  of  identification  and  this  can  limit  or  prevent  citizens  from  accessing 
public services. This concerns, for instance, registering with social security institutions or job 
centres267.  It  also  results  in  complications  for  students  who  are  not  passport  holders  when 
enrolling  in  schools  and  universities  in  different  Member  States.  The  lack  of  knowledge  of 
acceptable forms of identification by local authorities in some cases has resulted in the refusal 
of the right to vote in both European and local elections.268 

Citizen issues in relation to private services 

Some  private  entities  refuse  ID  cards  from  other  Member  States  as  a  valid  proof  of 
identification for their clients. 

Airlines  sometimes  refuse  to  accept  national  identity  cards  and  require  citizens  to  provide 
passports.  This  issue  particularly  affects  many  Italian  citizens.  French  citizens  can  also 
encounter difficulties in using their ID card when travelling in the EU, particularly since their 
validity was extended without fresh cards being issued269.  

265  YEA  Database:  YEA  enquiries  relating  to  non-acceptance  of  identity  cards  for  travel  tend  to  be  reported 
under  the  topic  ‘Entry  procedures’  (subtopics  ‘Travel  documents  for  EU  nationals’  and  ‘Wrong  entry  rules 
applied’). 
266  Directive  2006/126/EC  of  the  European  Parliament  and  of  the  Council  of  20  December  2006  on  driving 
licences (Recast) [2006] OJ L 403/18. This request relates make up 8.6% of the YEA requests (i.e. out of  547 
enquiries on travel documents for EU Nationals 47 related to driving licenses) 
267 YEA database: YEA enquiries relating to non-acceptance of identity cards for social security registration or 
access  to  benefits  tend  to  be  reported  under  the  topic  ‘Social  security’  (subtopics  ‘country  or  insurance  and 
general management’ and ‘unemployment’).  
268  YEA  Database:  YEA  enquiries  relating  to  non-acceptance  of  identity  cards  for  voting  tend  to  be  reported 
under ‘Political rights of EU citizens’. 
269 CSES study. 

114 

 
 
                                                 
Banks  sometimes  refuse  to  provide  services  to  EU  citizens  holding  ID  cards  from  another 
Member State. Instead of an ID card, banks often ask for a passport issued by the authorities 
of the nationality of the person seeking to open a bank account.  
This is the case for some banks in Spain, for instance270. One Spanish banker mentioned that 
“banks  feel  more  comfortable  asking  for  a  passport  because  it  was  a  valid  international 
document and does not generate as many questions as could generate a national document of 
another Member State.”  

In  the  UK,  ID  cards  are  often  not  accepted  as  valid  proof  of  identity  for  opening  a  bank 
account271 and there is evidence from the Your Europe Advice service of this also occurring 
in Sweden272, Romania, and Malta273.  

The Portuguese banking  association pointed out that there are ID cards from some Member 
States (Romania, Bulgaria and other Eastern EU countries) which are not accepted as a proof 
of identity because they lack a signature, a photo, a date of expiry or because the quality is not 
acceptable.  

Similarly, Finnish banks have identified various shortcomings in the security features of non-
national ID cards (for instance, Italian and Romanian ID cards) and therefore have difficulties 
accepting  them  as  a  proof  of  identity.  Likewise,  in  France,  Romanian  ID  cards  are  not 
accepted  because  the  document  lacks  the  cardholder’s  signature. In  these  cases,  citizens  are 
required to provide a passport. 

Residence cards are required in addition to ID cards when opening a bank account in several 
Member States.274 

Other private sector service providers also sometimes refuse to provide services or products to 
EU citizens holding ID cards from another Member State. Telephone and internet companies 
in  some  Member  States  do  not  accept  ID  cards  issued  by  another  Member  State  as  valid 
documentation  for  taking  out  a  telephone  or  internet  subscription  (or  even  residence  cards 
issued by the host Member State)275. Cases were reported to Your Europe Advice in UK of 
supermarkets not being willing to sell alcohol to people with ID cards from another Member 
State,  only  accepting  UK  driving  licences  and  foreign  passports.  This  practice  is  often  the 
subject of prior agreement by the local trading standards authority276. 

There have also been situations where businesses have refused to employ citizens holding an 
ID card from a different Member State. For example, according to the Your Europe Advice, 
EU citizens in Spain are required to obtain a Spanish residence card in order to register with 
the Spanish social security system, a prerequisite for being able to work legally in the country. 

270 CSES study (Interviews conducted with bank officials).  
271  See  for  example:  http://www.kosmopolito.org/2008/10/15/my-word-is-my-bond-but-not-for-eu-
citizens-in-the-uk/  See  also:  YEA  database:  such  YEA  enquiries  tend  to  be  reported  under  topics  ‘Financial 
Services’ (subtopics ‘bank accounts’), 
272 Quarterly Feedback report July-September 2015, p. 65, Quarterly Feedback report April-June 2016, page 67.  
273 Quarterly Feedback report January-March 2015, p. 65. 
274 CSES study. 
275 Recurrent problem reported in YEA Quarterly Feedback reports, see for example report from January-April 
2017, page 68: problems mentioned in NL, SV, DE and MT. 
276 YEA database: Such YEA enquiries tend to be reported under ‘Goods (other than motor vehicles)’ (subtopic 
‘Goods subject to excise duties’) and ‘Other consumer issues’ (subtopic ‘Other’). 

115 

 
 
                                                 
National  identity  cards  from  the  EU  Member  States  of  origin  are  not  accepted,  although 
passports are. The same situation arises in Sweden.277 

Problems using a Romanian ID card in France leading to legislative reform 

  GISTI278  (migrant  information  and  support  group),  underlined  that  in  recent  years  Romanian 
nationals  moving  to  France  have  encountered  difficulties  using  their  ID  cards.  Such  cards  were 
frequently not accepted as proof of the cardholder’s identity by French banks and other institutions 
on the basis that these cards did not show the holder’s signature. The result according to GISTI has 
been  considerable  inconvenience  to  these  EU  citizens  and  a  practical  constraint  on  their  free 
movement rights.  

  Responding to complaints by NGOs and affected individuals, in February 2013 the Défenseur des 
droits (an independent institution of the French state established in 2011 with a remit to uphold the 
rights  of  individuals)279  also  underlined  that  Romanian  nationals  should  not  be  prevented  from 
opening bank accounts in France because their ID cards do not show a signature280. Following this 
Decision,  the  relevant  regulations  were  amended  by  the  Finance  Ministry  so  that  the  list  of 
acceptable supporting documents for opening a bank account no longer contains any requirement 
that the necessary identity document, if otherwise valid and issued by a public administration, must 
show the holder’s signature281.  

 

In a further Decision of May 2015,282 the Défenseur des droits requested that the French Banking 
Federation  and  the  French  Association  of  Financial  Companies  circulate  information  about  the 
revised rules among their respective networks within two months.283  

Consequences for authorities and administrations including border control 

ID  cards  which  do  not  possess  sufficient  security  features  and  information  create  a security 
gap, as they allow the holders of such documents to exercise free movement rights and enter 
the  EU.  Simultaneously,  such  documents  increase  delays  including  at  borders  because  they 
complicate  the  identification  and  document  authentication  procedure.  Verification  of  the 
authenticity  of  travel  documents  is  a  key  element  of  border  checks  and  pre-requisite  for 
effective  border  control.  As  ID  cards  and  residence  documents  which  become  increasingly 
sophisticated in terms of their physical, optical and electronic security features, they represent 
significant challenges for public authorities including border control officers who increasingly 
need to rely on electronic and automated document inspection systems to ensure that border 
controls  do  not  cause  disproportionate  delays  for  travellers  whilst  maintaining  security284. 

277 YEA database: YEA enquiries relating to such problems tend to be reported under topic ‘Work’ (subtopic: 
‘Access to employment’).  
278 Groupe d’information et de soutien des immigrés (GISTI). 
279 http://www.defenseurdesdroits.fr/fr/institution/presentation  
280 Décision du Défenseur des droits numéro MLD-2013-10, 28 February 2013.  
281 See L’arrêté du 31 juillet 2015 fixant la liste des pièces justificatives pour l’exercice du droit au compte 
auprès de la Banque de France 
(http://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000030981153).  
282 Décision du Défenseur des droits numéro MLD-2015-098, 28 May 2015. 
283 See paragraph 25 of the Decision. It should be noted, however, that the representative from GISTI expressed 
some  reservation  as  to  whether,  in  practice,  the  revised  regulations  in  France  have  led  to  banks  accepting 
Romanian ID cards as valid documents for establishing the identity of the cardholder. 
284  FRONTEX. 2014.  The  Document  Challenge  II.  Testing  human  and  machine  performance  in  detecting  and 
classifying genuine and false travel documents. Short Summary – Public Release p. 3. 

116 

 
 
 
 
 
                                                 
Specifically in relation to ID cards, FRONTEX recognises the strain on border control staff, 
noting that: 

“Lack of reference knowledge, as well as non-standard or unsuitable design and production 
[…]  significantly  affect  the  effectiveness  of  both  technical  and  human  capacities  [at  border 
crossing points]”.285  
This  has  been  confirmed  by  some  Member  States.286  For  instance,  in  the  view  of  the 
Bulgarian  authorities,  the  main  problems  in  relation  to  border  control  stem  from  older 
versions  of  ID  cards  from  countries  such  as  France,  Germany,  Greece,  and  Italy,  which 
continue to be legitimate travel documents. These require manual checks which is more time-
consuming.  The  Estonian  border  control  authorities  maintain  that  some  travel  documents 
issued in the EU28 are not registered in the central databases (i.e. FADO).  

An additional complication is that, whereas all EU Member State passports (except UK and 
IE) comply with the same security features287, Member States have technology and equipment 
in place at the border to scan and process the passports, while this is currently not possible for 
most ID cards. One consequence is that border guards can often only check the authenticity of 
their own national ID cards and residence documents properly and cannot take advantage of 
the latest security features in authenticating other countries’ documents.  

Simultaneously, wherever border control points are equipped to access the advanced features 
of already harmonised biometric passports, they will also be in a position to do so for ID cards 
with similar features. In addition to machine readers, border guards need to have access to the 
latest  software,  databases  and  certificates  in  order  to  verify  a  document’s  authenticity 
effectively. It is technically extremely challenging to have inspection systems in place across 
the  EU28  which  can  deal  with  the  great  diversity  of  security  mechanisms  used  in  ID  and 
residence  documents  (and  the  frequent  absence  of  such  mechanisms),  a  problem  which  is 
compounded by the diversity of incompatible chip technologies currently in use. 

A manual border gate requires one border guard per lane while an e-gate requires on average 
two  border  guards  per  five  lanes  (one  supervisor,  one  for  intervention).  Currently  only  15-
20% of eligible travellers use e-gates while actually up to 68% of travellers could be expected 
to use them, as data from countries with well-established e-gate systems show.288 

If  e-gates  were  accessible  for  all  EU  citizens  holding  ID  cards,  savings  would  apply  to  40-
50% of EU travellers.289 

Consequences for private sector services 

285 FRONTEX. The Document Challenge II. p. 4 
286 CSES study. 
287 Passports issued by EU Member States, except UK and IE, comply with Council Regulation 2252/2004 and 
its implementing measures. By this Regulation, passports are not identical but remain specific to each Member 
State,  but  they  all  comply  with  ICAO  standard  9303  and  have  common  security  features,  both  optical  and 
electronic. The Regulation took the option of including the images of two index fingers in the chip’s passport in 
addition to the facial image that is mandatory according to the applied standard. The chip protection is defined in 
implementing  measures,  like  e.g.  C(2013)6181  that  defines  Supplemental  Access  Control  to  protect  the 
biographical data and the facial image on the chip.  
288 Data based on findings from ABC working group at FRONTEX. 
289 CSES study 

117 

 
 
                                                 
The private sector has a similar problem to public administration in dealing with the diversity 
of  documents  and  their  potential  forgeries  when  they  are  not  sufficiently  secured,  firstly 
because  of  the  confusion  arising  from  so  many  different  types,  the  adaptation  of  business 
processes  to  include  effective  manual  document  checks,  and  the  loss  of  staff  time  checking 
documents and the cost of training staff to check them. Moreover, while a cautious approach 
to  accepting  non-national  identity  documents  (i.e.  turning  away  potential  clients)  means 
reduced turnover, a less conservative approach can expose an enterprise or its clients to fraud, 
and the costs for insuring against and preventing such fraud. 

Air travel 

Airlines routinely check ID cards to establish that the holder is the same person as the name 
printed on the boarding card. In case of denial of the right to travel, this can lead to substantial 
claims for compensation if it is subsequently determined as a wrong decision. The fact that ID 
cards can rarely be used at e-gates in airports can also affect airlines by causing further delays.  

Access to financial services/banking 

Although dependent on circumstances, the time for handling the opening of a bank account is 
two to eight times more time-consuming in case there are doubts about his/her identity which 
has to be verified through the Central Bank.  

Apart  from  the  inconvenience  to  citizens,  there  can  also  be  considerable  costs  to  banks 
involved in training staff to deal with different types of ID cards. Especially in recent years 
the  ‘know  your  customer’  regulations  which  apply  to  banks  have  become  stricter  requiring 
them to carry out thorough checks before services can be provided. Staff need to be trained to 
determine the validity of ID cards (and sometimes residence documents). 

Procedures can also take longer with non-nationals in verifying their identity. According to an 
Italian  bank,  the  procedure  for  verifying  a  mobile  EU  citizen’s  identity  takes  considerably 
more time than for nationals. There can also be legal problems (and costs linked to this) due 
to misidentification of customers.  

The  Portuguese  banking  association  provided  an  estimate  of  the  time  spent  to  verify  the 
identity of individual in opening a bank account: if the customer is a Portuguese citizen and 
all  the  documents  are  provided  and  are  valid,  this  procedure  could  take  a  maximum  of  one 
hour  to  complete.  If  the  individual  is  an  EU  citizen  and  if  there  are  doubts  about  his/her 
identity which has to be verified through the Central Bank’s (Banco do Portugal) or the EU 
citizen  has  just  arrived  in  Portugal  and  he/she  does  not  yet  have  an  address  the  same 
procedure can take from two hours to more than a day.  

In contrast, a bank in Spain stated that the procedure involved in opening a bank account is 
quick (5-10 minutes) and it does not differ whether the individual is a national or from other 
EU  Member  State.  In  addition,  the  interviewee  stressed  that  the  time  taken  to  open  a  bank 
account  does  not  depend  on  the  nationality  but  on  the  experience  and  knowledge  of  the 
employee  of  the  bank  who  deals  with  the  procedure.  There  are  some  bank  branches  which 
have  many  EU  citizens  from  other  countries  as  customers and  others which  are  not  used  to 
dealing with non-nationals. 

118 

 
 
3. Further consequences related to problems with residence documents 

lengthy  administrative  procedures 

Of the respondents to the 2015 citizenship consultation who moved to another Member State, 
36% had encountered some difficulties after having moved. Most of the problems related to 
unclear  and 
lack  of 
information/unawareness about rights  as  non-nationals (51%).  Most mobile EU citizens had 
looked  for  information  on  residence  documents,  including  on  how  to  register  in  the 
municipality  (69%)  as  well  as  information  on  employment  and  working  conditions  (45%), 
social security and welfare (41%) as well as access to healthcare. As pointed out by a citizen’s 
submission which was taken up by the REFIT platform290 this argues for the introduction of 
special  departments  (or  contact  points)  to  deal  with  the  cases  and  concerns  of  mobile  EU 
citizens. 

followed  by  a 

(69%), 

A majority of Member States requires registration from EU citizens residing in their territory. 
In France, the United Kingdom and the Czech Republic, EU citizens are given the option to 
request a registration document (which can be in the form of a residence card, see Table 2.2).  

The inconsistency of Member States’ residence documents creates problematic consequences 
for citizens when they are required to evidence their residence in another Member State. This 
can  be  an  obstacle  to  accessing  public  and  private  services  and  creates  costs  for  all 
stakeholders.  

Specific issues related to TCN FAM residence documents  

One problem continues to be the lack of awareness in public authorities concerning the extent 
of the visa exemption contained in Article 5(2) of Directive 2004/38. This exemption means 
that possession of a valid residence card by a family member of a mobile EU citizen should 
exempt  such  family  members  from  the  visa  requirements  for  short  stays.  This  exemption 
requires that this  specific residence card must  be delivered to  a family  member of  a mobile 
EU citizen.  

For the visa exemption to apply, the family member needs to travel with the EU citizen or join 
him/her  in  another  Member  State.  Problems  of  acceptance  continue  to  be  reported,  for 
instance  as  regards  family  members  of  British  citizens  seeking  to  travel  to  the  UK  after 
residing in another Member State under the CJEU’s  Surinder  Singh ruling. This means that 
situations  persist  where  family  members  of  EU  citizens  cannot  travel  freely  within  the  EU 
without a visa, even after many years of residence, because the visa exemption is not being 
observed.  

The notion of valid  travel documents  is  often misunderstood and private transport company 
staff  also  appears  to  be  unaware  of  the  visa  exemptions.  As  a  consequence,  TCN  family 
members of EU citizens and with them, EU citizens, are refused boarding even though they 
have  a  valid  residence  card  or  a  permanent  residence  card.  This  can  lead  to  significant 
financial loss and inconvenience.291 

290 LtL 242 
291  YEA,  Quarterly  Feedback  report  October-December  2015,  page  20  and  21;  Quarterly  Feedback  report 
January-April 2016, page 20 and 65.  

119 

 
 
                                                 
The problem is compounded by the absence of correct information about the visa exemption 
on  the  TIMATIC292  website  administered  by  the  International  Air  Transport  Association 
(IATA)  which  most  airlines  use  to  verify  the  validity  of  travel  documents.  Problems  have 
been  reported  not  only  in  the  UK,  but  also  Croatia,  the  Netherlands  and  airlines  operating 
flights originating from outside the EU with a destination inside the EU.  

Confusion over valid travel documentation 

There are awareness-related problems such as the misperception that residence cards can be 
used as valid travel documents.293 There are many cases of residents who have attempted to 
use their registration certificate and residence cards as valid travel document and were refused 
travel. Citizens are therefore obliged to abandon their journey and often incur financial loss.  

Citizens  may  be  especially  confused  by  the  more  sophisticated,  feature-full  types  which 
resemble identity documents. For instance,  confusions arose between ID card and residence 
documents in Belgium as the residence card issued closely resembles an ID card.  

Issuance and handling of residence documents 

Registration certificates are  not required  in all  EU jurisdictions294  but  in  19 Member  States, 
they  are  mandatory  for  persons  residing  longer  than  a  certain  period.295  This  can  cause 
applicants  significant  inconvenience  if  they  are  obliged  to  wait  weeks  or  even  months  to 
obtain a certificate.  

Delays in issuing registration certificates have been observed in Italy. EU citizens who are not 
economically  active  have  to  prove  they  have  sufficient  resources  for  themselves  and  their 
family members in order to not to become a burden on Italy’s social assistance system. The 
relevant individual  must  allow the relevant  authorities to  carry out  financial checks on their 
bank accounts. This procedure is lengthy, and researchers have noted that it overloads public 
administrations296. 

Another  issue  encountered  by  EU  citizens  relates  to  the  costs  of  obtaining  residence 
documentation.  For  instance,  in  a  case  involving  a  Belgian  national  reported  in  the 
Citizenship Consultation: “We moved from Belgium to the Netherlands. For each application 
(requesting an ID, registering my bicycle, registering to vote, registering my car, insurance, 
bank etc.) I needed to request a proof of residency from the municipality. Each time this costs 
EUR 12.50 as the proof is only valid for three months it becomes an expensive joke.”297  

292 https://www.timaticweb.com/ 
293 Anecdotal evidence as revealed by requests directed to YEA. 
294 See Art. 8(1) of Directive 2004/38/EC. 
295 See Table 2.2. Registration is optional in FR, CZ and UK. As mentioned above, EE, FR, MT, NL delivers 
residence cards which are not linked with residence documents provided for in Directive 2004/38/EC. 
296 CSES interviewed the Italian researchers for the Citizens Without Borders project. For further information of 
this EU Commission funded project, see http://www.meltingpot.org/+-CitizensWithoutBorders-+.html.  
297 Situation of Belgian Respondent expressed in Citizenship Consultation Report, p. 33. 

120 

 
 
 
 
                                                 
Annex 7: Policy Options - details 

Table 5.1: Mandatory elements for ID cards under option ID 1) 

1.  The title of the document (‘ID card’ or ‘identity card’298) shall appear in the language(s) 
of  the  issuing  Member  State.  Repetition  of  the  document  title  in  at  least  one  other 
(maximum two) official languages of the institutions of the Union, in order to facilitate 
the recognition of the card as ID card. 

2.  Format ID-1299 including positioning of data fields according to ICAO. 
3.  Substrate and printing techniques according to ICAO 
4.  Contactless chip (including facial image)300 
5.  The  ICAO  "Chip  inside"  symbol  for  a  machine-readable  travel  document  with  a 
contactless integrated circuit (microchip) that can be used for biometric identification 
of the holder. 

6.  Machine-readable  zone  (MRZ).  The  machine-readable  zone  shall  conform  to  the 
relevant  ICAO  specifications  set  out  in  ICAO  Document  9303  on  machine-readable 
travel documents. 

7.  Security features (conform to the ICAO Doc 9303).301  
8.  The three-letter country code of the issuing Member State. 
9.  The document number.302  
10. The Card Access Number (CAN). 
11. Name: surname(s) and forename(s), in that order.  
12. Sex. 303 
13. Nationality. 
14. The expiry date of the document. 
15. Date of birth. 
16. Place of birth. 
17. Date of  issue,  place of  issue/  issuing authority: The  date and  place of  issue of the ID 

card.  

18. Signature of the holder. 
19. An identity photograph shall be securely integrated into the card body. 

Table 5.2: Mandatory and optional elements for TCN FAM cards following the uniform format 

In addition to the elements covered by RES 1 (document title, document number, surname 

298 Please note that IE issues a so-called ‘passport card’ which bears the function of an ID card as referred to by 
Art 4 and 5 of Directive 2004/38/EC. 
299 The ID-1 format specifies a size of 85.60 × 53.98 mm (3-3/8 in × 2-1/8 in) and rounded corners with a radius 
of  2.88–3.48  mm.  It  is  commonly  used  for  payment  cards  (ATM  cards,  credit  cards,  debit  cards,  etc.).  See 
http://www.wikiwand.com/en/ISO/IEC_7810#/Card_sizes for more details. 
300 Optionally, dual interface or in addition contact chip for other (national) purposes. 
301 E.g. the use of upgraded diffractive optically variable image device (DOVID). 
302 As good practice, the document number is repeated (with special security features). 
303 <F>, <M> or <X> according to ICAO guidelines. 

121 

 
 
 
 
                                                 
and forename(s) of the holder, date of issue and place of issue 

1.  The  three-letter  country  code  of  the  issuing  Member  State  integrated  into  the 

background printing. 

2.  The  ICAO  "Chip  inside"  symbol  for  a  machine-readable  travel  document  with  a 
contactless integrated circuit (microchip) that can be used for biometric identification 
of the holder. 

3.  The Card Access Number (CAN). 
4.  Sex.304 
5.  Nationality. 
6.  Date of birth. 
7.  An identity photograph shall be securely integrated into the card body and secured by 

a diffractive optically variable image device (DOVID). 

8.  Signature of the holder. 
9.  Place of birth. 
10. Optional entries such as “Address of the holder”. 
11. Optional field for information related to the production of the card, such as name of 

the producer, version number etc.  

12. Machine-readable  zone.  The  machine-readable  zone  shall  conform  to  the  relevant 
ICAO  specifications  set  out  in  ICAO  Document  9303  on  machine-readable  travel 
documents. 

13. The printed area shall contain the national emblem of the Member State to distinguish 

the residence card and provide certainty as to its national origin. 

14. The  machine-readable  zone  shall  contain  printed  text  in  the  background  printing 
indicating the issuing Member State. This text shall not affect the technical features of 
the machine-readable zone. 

15. An RF chip shall be used as a storage medium. Member States may also incorporate in 
the  residence  card  a  dual  interface  or  a  separate  contact  chip  for  national  use.  Such 
contact  chips  shall  be  placed  on  the  reverse  of  the  card,  comply  with  ISO  standards 
and in no way interfere with the RF chip. 

16. Optional transparent window. 
17. Optional transparent border. 

304 <F>, <M> or <X> according to ICAO guidelines. 

122 

 
 
 
 
 
                                                 
Annex 8: The preferred option(s) - details 

Figure 8.1: ID card holders affected by preferred option 

Potential number of ID card holders affected by the preferred option  

Total number of potential ID card holders
in 26 MS (assumption based on EU
population above age of 15, except DK
and UK; Eurostat 2016)
Potential ID card holders in 26 Member
States affected by changes in format and
security of ID cards as introduced by the
preferred option
ID card holders in BE, BG, CZ, EL, ES, FR,
HU,  IT, RO, SK, SI potentially affected by
earlier replacement of ID cards (phasing
out)
ID card holders in BE, BG, EL, ES, HU, RO,
SK who must earlier replace their ID card
because holding an ID card is obligatory

0

100

200

300

400

Million ID card holders 

Figure 8.2: Phasing in ID cards under preferred option – key changes305 

305 With the exception of changes to data, the changes noted in the map are largely cumulative, in that Member 
States which have to make their cards machine readable, will also have to introduce biometrics and contactless 
chips, and those introducing biometrics will also need to introduce contactless chips. See Table 8.2. 

123 

 
 
 
 
                                                 
Table 8.2: Phasing in regime ID cards according to preferred option  

.Member 
State 

Austria 

Belgium 

Bulgaria* 

Croatia 

Cyprus 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy** 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

Upgrade of 
biographical 
data or title 

Upgrade 
to ICAO 
MRZ 

Upgrade of 
substrate 
(paper/laminated 
paper to plastic) 

Upgrade 
from "no 
chip" to 
chip 

Upgrade of 
chip (contact 
chip to 
contactless) 

Upgrade of 
biometrics 

no 

yes 

no 

yes 

no 

no 

yes 

no 

yes 

yes 

no 

no 

yes 

no 

no 

no 

no 

no 

no 

no 

no 

yes 

no 

yes 

no 

no 

no 

no 

no 

no 

no 

no 

yes 

no 

no 

no 

no 

yes 

Not applicable because no ID card produced 

no 

no 

yes 

no 

yes 

no 

no 

no 

no 

yes 

no 

yes 

no 

no 

yes 

yes 

no 

yes 

no 

yes 

yes 

yes 

yes 

no 

yes 

no 

no 

yes 

no 

no 

yes 

no 

yes 

yes 

yes 

yes 

no 

yes 

no 

no 

yes/no 

yes/no 

yes/no 

yes/no 

yes/no 

yes/no 

no 

no 

no 

yes 

no 

yes 

yes 

yes 

no 

no 

yes 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

yes 

no 

no 

no 

no 

no 

no 

no 

no 

no 

yes 

yes 

yes 

yes 

yes 

no 

yes 

no 

no 

no 

yes 

no 

yes 

yes 

yes 

yes 

yes 

no 

yes 

no 

no 

no 

yes 

no 

yes 

yes 

yes 

yes 

yes 

no 

yes 

Not applicable because no ID card produced 

Legend: "*" Does only apply to new BG cards from 2018 onwards 
municipality. 

"**": IT issues two types of ID cards depending on the 

124 

 
 
 
Figure 8.3: Phasing in TCN Family Member residence cards under preferred option  

Table 8.3: Phasing in regime TCN FAM cards according to preferred option  

Member 
State 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech 
Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece* 

Hungary 

Upgrade of 
biographical 
data or title  

Upgrade 
of layout 
and card 
format 
(ID-1) 

Upgrade of substrate 
(paper/laminated paper 
to plastic) 

Upgrade 
from 
"no chip" 
to "chip" 

Upgrade of 
chip 
(contact chip 
to 
contactless) 

Upgrade 
of 
biometrics 

yes 

yes 

yes 

no 

yes 

yes 

no 

no 

yes 

yes 

no 

no 

yes 

yes 

yes 

yes 

no 

yes 

yes 

no 

no 

no 

no 

no 

no 

yes 

no 

no 

no 

no 

yes 

yes 

no 

no 

no 

no 

no 

no 

no 

125 

yes 

no 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

no 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

no 

no 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

no 

no 

yes 

 
 
 
 
Member 
State 

Ireland* 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal* 

Romania* 

Slovakia 

Slovenia 

Spain 

Sweden 

UK 

Upgrade of 
biographical 
data or title  

Upgrade 
of layout 
and card 
format 
(ID-1) 

Upgrade of substrate 
(paper/laminated paper 
to plastic) 

Upgrade 
from 
"no chip" 
to "chip" 

Upgrade of 
chip 
(contact chip 
to 
contactless) 

Upgrade 
of 
biometrics 

no 

yes 

yes 

no 

yes 

yes 

no 

yes 

no 

no 

yes 

no 

yes 

yes 

no 

no 

no 

no 

no 

yes 

no 

no 

yes 

no 

no 

no 

yes 

yes 

no 

yes 

no 

no 

no 

no 

yes 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

no 

yes 

no 

no 

yes 

no 

no 

no 

no 

no 

no 

yes 

yes 

no 

yes 

no 

yes 

no 

no 

yes 

yes 

no 

no 

no 

no 

no 

yes 

yes 

no 

yes 

no 

yes 

no 

no 

yes 

yes 

no 

no 

no 

no 

no 

yes 

yes 

yes 

yes 

Legend: "*": EL, IE, PT and RO only recently introduced the required upgrades, which have to be monitored to confirm the 
full compliance. 

Table 8.4: Phasing in regime residence documents to mobile EU citizens according to preferred 
option  

Member State  Upgrade of title and target data required 

All Member States except CY, NL, RO and SI. 

126 

 
 
 
 
 
 
Table 8.5: Overview about the compliance cost of the preferred (legislative) option for ID cards on the Member States 

ID cards 
Phasing in regime (ID cards) 

AT  BE  BG*  CY  CZ  DE  DK  EE  EL  ES  FI 

FR  HR  HU* 

IE 

IT 

LT 

LU 

LV  MT  NL  PL  PT  RO  SE  SI  SK  UK 

Compliance 
cost 

y 

y 

y 

y 

na 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

na 

Phasing out regime (ID cards) 

Compliance 
cost (EUR 
millions) 
Legend: “y”: yes (not quantifiable due to lack of data),  “na”: not applicable as no ID cards produced, "*" only old BG+HU cards with unlimited validity phased out 

74  33 

435 

157 

17* 

na 

41 

5* 

3 

5 

1 

6 

na 

Table 8.6: Overview about the compliance cost of the preferred (legislative) option for TCN FAM residence documents on the Member States 

TCN FAM  AT  BE  BG  CY  CZ  DE  DK  EE  EL 

ES 

FI 

FR  HR  HU 

IE 

IT 

LT 

LU 

LV  MT  NL  PL  PT  RO  SE  SI  SK  UK 

Phasing in regime (TCN FAM residence and permanent residence cards) 

Compliance cost 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

Phasing out regime (does only affect TCN FAM permanent residence cards, since validity of TCN FAM residence cards is always five years) 
Compliance cost 
12 
(EUR thousands) 

2 168  13 

540 

16 

83 

50 

60 

56 

52 

8 

1 

* 

* 

* 

* 

y 

60 

Legend: “y”: yes (not quantifiable due to lack of data) 

“*”: only cost implications if uniform format not implemented within the time frame announced. 

Table 8.7: Overview about the compliance cost of the preferred (legislative) option for residence documents (except TCN FAM documents) 

Residence docs  AT  BE  BG  CY  CZ  DE  DK  EE  EL  ES  FI  FR  HR  HU 
Phasing in regime (Residence documents) 

IE 

IT 

LT 

LU 

LV  MT  NL  PL  PT  RO  SE  SI  SK  UK 

Compliance cost 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

y 

No phasing out regime 

Legend: “y”: yes (not quantifiable due to lack of data)

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 9: Monitoring and evaluation of impacts - details 

Table  9.1  Key  indicators  for  monitoring  the  implementation  of  the  preferred 
options 

Specific 
objectives 

Improve the 
acceptance of 
documents 
and improve 
the 
identification 
of people 

Improve 
authentication 
of documents 
and reduce 
document 
fraud 

Raise 
awareness 
among all 
stakeholders 
about 
documents, 
rights linked 
to them, 
including 
training 

Simplify the 
daily life for 
EU citizens, 
cut red tape 
and lower 
costs for all 
stakeholders 

Indicators 

Data sources 

 Reports  from  Member 
likely 
States,  most 
Committee, 
through 
experts group or Council 
Working Group format 

 FRONTEX  risk  analyses 
fraudulent 

on 
documents  

 Europol  analytical  files 
(forged  documents  used 
in  THB,  number  of 
identity thefts…) 

 Number  of 

fraudulent 
travel  documents  in  the 
Schengen 
Information 
System 

 Member States agencies 
 Reports  from  EU  and 
Member 
States 
authorities and agencies 

 Number  of  complaints  received  by  citizens  who  faced 
problems related to the acceptance of their documents 
 Proportion  of  ID  cards  and  residence  documents  in 
circulation in different EU that have upgraded features 
  Member  States implementing  effective  administrative 
security/format 

measures/legislation 
upgrade of ID cards and residence documents 

achieve 

to 

 Improved  security  and  the  number  of  fraudulent  (ID 
in  different 

and  residence)  documents  reported 
sources 

 Number  of  Member  States  engaged  in  different  types 
of  enhanced  administrative  cooperation  activities  on 
document 
(FRONTEX,  Europol,  Schengen 
Information System,….) 

fraud 

 Number  of  people  who  self-report  being  victims  of 

identity theft 

 Number  and  type  of  initiatives  to  raise  awareness  of 

rights under the Directive 

 Number  of  citizens  reached  by  awareness-raising 

measures  

 Number  of  users  of  specific  channels,  such  as  Your 

Europe (and later the single digital gateway)  

 Number  and  type  of  training  sessions  (FRONTEX,  etc.) 
and  number  and  type  of  participants  from  different 
Member  States.  Indicators  on  the  training  session 
include:  number  and  type  of  participants,  length  and 
content of sessions, feedback on ‘lessons learned’ from 
the sessions.  

 Reduction  in  hassle  costs  and  administrative  barriers 

 Reports  from  YEA  and 

for mobile EU citizens and their family members  

SOLVIT 

 Enhanced  access  to  public  services  for  non-nationals 

residing in host MSs  

 Eurobarometer surveys 
 Feedback  from  citizens’ 

 Reduction in hassle costs and benefits to private sector 

organisations 

entities (airlines, banks, etc.) and their customers 

 Reduction in hassle costs for public authorities 
 Less delays when EU mobile citizens request and renew 

documents  

128 

 
 
 
  
 
 
Annex 10: Impact of preferred option per Member State 

The following tables provide a summary of the detail of impact of the proposed initiative 
on the existing current national documentation regimes. 

CURRENT SITUATION IN AUSTRIA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 

Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics 
Validity in years 

 

 
 
x 

x 
10 

IDENTITY CARD 
No change 

No change 
No change 

Inclusion of a contactless chip - 

 
  Possibility for Austrian citizens to use e-

 

gates 
Insertion of facial image 
No impact (phasing out of 10 years)  

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in 
another EU language 
Target data present 

x 

 

  Translation to be added 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 

Use of the uniform format 
including correct title and 
storage medium and 
biometrics306 

x 

x 

  Translation to be added 

  Title to complete(FAM)  
  Obligation to use the uniform format  
  Lay-out of the photo: left and central  
 
 
Phasing out of 5 years: 

Insertion of contactless chip  
Insertion of biometrics 

Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 5 
10  

No impact  
Impact 

 

 

 

 

 

 

 
 
 

 

CURRENT SITUATION IN BELGIUM 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 

 

x 

IDENTITY CARD 
No change 

  Lay-out of the photo: left and central 

 

306  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
ICAO compliance (MRZ) 
Chip 

 
x 

No change 

  Change to contactless chip  
  Possibility for Belgian citizens to use e-

 
 

Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

 
10 
30 (>75) 

gates 
No change 
No impact (phasing out of 10 years)  

  Yes (phasing out within 10 years) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
  Change of title 

x 

No change 
RESIDENCE DOCUMENTS FOR NON-EU FAMILY MEMBERS 

 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 

Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
x 

5 
5 

  Change of title  
  Obligation to use the uniform format  
  Lay-out of the photo: left and central  
  Change to contactless chip 
 
Insertion of fingerprints  
Phasing out in 5 years 

No impact  
No impact  

 

 

 

CURRENT SITUATION IN BULGARIA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

IDENTITY CARD 
Correct title and title in another 
EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

No change 

 
 
 
 
10 
∞ (>58) 

No change 
No change 
Change from 2018 to monitor 
Change from 2018 to monitor 
No impact (phasing out of 10 years)  

  Yes (phasing out within 10 years) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
Correct title and title in another 
EU language 
Target data present 

x 

x 

  Correction of title (registration 

 

certificate) 
Insertion of place of issue (registration 
certificate) 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

 

 

 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and biometrics 

 

x 

Validity in years 
- Res. cards FAM  

  Change of title for permanent residence 

 

card  

  Obligation to use the uniform format 
 
Insertion of a contactless chip  
 
Insertion of biometrics  
Phasing out of cards in 5 years: 

5 

No impact  

130 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- Perm. res. cards FAM 

10 

 

Impact 

 

CURRENT SITUATION IN CYPRUS 

IMPACT OF THE PROPOSAL 

Potential 
costs drivers 

Correct title and title in another 
EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 
 
 
 
10 

IDENTITY CARD 
No change 

No change 
No change 
No change 
No change 
No impact (phasing out of 10 years)  

RESIDENCE DOCUMENTS FOR EU CITIZENS 
No change 

 

No change 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

 

Correct title and title in another 
EU language 
Target data present 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and biometrics 

Validity in years 
- Res. cards FAM 
- Perm. res. cards FAM 

 
x 

5 
10 

  Title to correct for residence cards (first 

 

5 years) 

Insertion of a contactless chip 
Insertion of biometrics  

  Use of uniform format  
 
 
Phasing out in 5 years: 
No impact  
Impact 

 

CURRENT SITUATION IN CZECH REPUBLIC 

IMPACT OF THE PROPOSAL 

Correct title and title in another 
EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics 
Validity in years 

IDENTITY CARD 

No change 

No change 
No change 

  Inclusion of a contactless chip  
  Possibility for Czech citizens to use e-

gates 

  Insertion of facial image 

No impact (phasing out of 10 years) 

  Yes (phasing out within 10 years) 

 

 
 
x 

x 
10 
35 
(>70) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in another 
EU language 
Target data present  

x 

 

  Change of title (permanent residence 

document) 

No change 

131 

 

Potential 
costs drivers 

 

 

 

 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics307 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
x 

5 
10 

  Change of title  
  Obligation to use the uniform format  
  Insertion of a contactless chip 
  Insertion of biometrics  

Phasing out in 5 years 
No impact  

  Impact 

 

 

CURRENT SITUATION IN GERMANY 

IMPACT OF THE PROPOSAL 

Potential 
costs drivers 

Correct title and title in another 
EU language 
Biographical data and format 

ICAO compliance (MRZ) 
Chip 
Biometrics 

Validity in years 

 

x 

 
 
 
10 

IDENTITY CARD 
No change 

 

 

Insertion of the sex in the biographical 
data 
No change 
No change 
No change 

No impact (phasing out of 10 yrs) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in another 
EU language 
Target data present 

x 

 

  Translation of title (permanence 

 

document) 
No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and biometrics 
Validity in years 
- Res. cards FAM 
- Perm. res. cards FAM 

 
 

5 
∞  

No change 
No change 

Phasing out in 10 years 

No impact  
Impact  

 

CURRENT SITUATION IN DENMARK 

IMPACT OF THE PROPOSAL 

Correct title and title in another EU 
language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 

IDENTITY CARD 

No Identity card 

 

Potential 
costs drivers 

307  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Unknown format  

Unknown format  

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
Image unknown 

Correct title and title in 
another EU language 
Use of the uniform format 
including storage medium and 
biometrics 
Validity in yrs 
(Res cards FAM)  
(Perm. res. c FAM) 

x 

  Insertion of a contactless chip 
  Insertion of biometrics  

Phasing out in 5 years: 

5 
∞  

No impact  

  Impact  

CURRENT SITUATION IN ESTONIA 

IMPACT OF THE PROPOSAL 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics 
Validity in years 

 

x 
 
x 

x 
5 

IDENTITY CARD 
No change 

 

Insertion of the issuing authority 
No change 

  Change to contactless chip  

 

Possibility for Estonian citizens to use e-gates 
Insertion of facial image 
No impact 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in 
another EU language 
Target data present 

x 

x 

  Change of title 

 

Insertion place of issue 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
x 

5 
5 

No change 

  Change to contactless chip 
 
Insertion of facial image 

Phasing out in 5 years: 

No impact  
No impact  

 

 

Potential 
costs drivers 

 

 

 

 

 

 

CURRENT SITUATION IN GREECE 

IMPACT OF THE PROPOSAL 

Potential 
costs drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 

 

 
x 

IDENTITY CARD 
No change 

No change 
Inclusion of MRZ (amongst others) 

 

 

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chip 

Biometrics 

x 

x 

 

 

Inclusion of a contactless chip  
Possibility for Greek citizens to use e-gates 
Insertion of a facial image 

Validity in years 

15 

 

Impact (phasing out in five years) 

Correct title and title in 
another EU language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
translation of title 

 

x 

 

No change 

 

 

 

 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 

Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. c FAM 

 

 

No change; 
Recent introduction to monitor 
No change 
Recent introduction to monitor 

(if uniform format fully applied) 

5 
10 

No impact  
No impact 

CURRENT SITUATION IN SPAIN 

IMPACT OF THE PROPOSAL 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

IDENTITY CARD 
  Title to translate 

No change 
No change 
No change 
No change 
No impact (phasing out in 10 years) 
Impact (phasing out in 10 years) 

 

x 

 
 
 
 
10 
∞ 
(>7
0) 

Potential cost 
drivers 

 

  see below 

Correct title and title in 
another EU language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
  Translation of title 

x 

 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

x 
x 

  Translation 
  Change of title  
  Use of the uniform format 
 
 Change to contactless chip 
 
Insertion of biometrics 
Phasing out in 5 years 

5 
10 

No impact  
Impact 

 

 

 
 

 

134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CURRENT SITUATION IN FINLAND 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

IDENTITY CARD 
No change 

No change 
No change 

  Change to contactless chip 
  Possibility for Finnish citizens to use e-gates 
 

Insertion of facial image 
No impact (phasing out of ten years) 

 

 
 
x 

x 
5 

 
 

 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Unknown document 

Unknown document 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
No change 

  Mention of family member of Union citizen 

 

 
x 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

Phasing out in 5 years: 

5 
∞  

No impact  
Impact  

 

 

Potential cost 
drivers 

 

 
 

 

 
 

 

CURRENT SITUATION IN FRANCE 

IMPACT OF THE PROPOSAL 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 

Chip 

x 

x 
x 

x 

Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

IDENTITY CARD 
  Translation needed 

 

  Plastic 
  Modification of MRZ  
Addition of an OVD 
Inclusion of a contactless chip  
Possibility for French citizens to use e-
gates 
Insertion of facial image 
Impact (phasing out in five years) 

 
x 
15   

RESIDENCE DOCUMENTS FOR EU CITIZENS 

x 

  Correct title and translation  

 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 

x 
 

  Translation  
No change 

 

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

Phasing out in 10 years 

5 
10 

No impact  
No Impact  

CURRENT SITUATION IN CROATIA 

IMPACT OF THE PROPOSAL 

Potential costs 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

IDENTITY CARD 
No change 

 

Insertion of end of validity date 
No change 

  Change to contactless chip 
 
Insertion of facial image 

No impact (phasing out in ten years) 

 

x 
 
x 
x 
5 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

x 

  Change of title 

 

No change 

 

 
 

 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics308 
Validity in years 
- Res. cards FAM 
- Perm. res. cards FAM 

 
x 

No change 

  Change to contactless chip 

 

Phasing out in 5 years 

5 
10 

No impact  
Impact 

 

CURRENT SITUATION IN HUNGARY 

IMPACT OF THE PROPOSAL 

Potential costs 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 
 
 
 
6 

 

∞ 
(>70) 

IDENTITY CARD 
No change 

No change 
No change 
No change 
No change² 
No impact (phasing out in 10 years) 
Impact (phasing out in 10 years) 

Correct title and title in 
another EU language 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
  Translation of title (registration 

x 

certificate) 

 

 

308  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Target data present 

 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 

Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
x 

No change 
 
Indication that FAM of Union citizen 
  Obligation to use the security features of 

 

the uniform format  
Insertion of contactless chip 
Insertion of facial image 

 
 
Phasing out in 5 years: 

5 
10 

No impact  
Impact  

 

 

Potential costs 
drivers 

CURRENT SITUATION IN IRELAND 

IMPACT OF THE PROPOSAL 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

IDENTITY CARD 

x 

  Title of "passport card" needs change 

 

 
 
 
 
5 

No change 
No change 
No change 
No change 
No impact (phasing out in 10 years) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

  Format unknown (no registration, only 
doc. certifying permanent residence) 
Format unknown (no registration, only 
doc. certifying permanent residence) 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 

 
 

  Transition to uniform format to monitor 
  Transition to uniform format to monitor 

- Res. cards FAM  
- Perm. res. cards FAM 

5 
10 

No impact  
No impact  

 (if uniform format fully applied) 

CURRENT SITUATION IN ITALY 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 

ICAO compliance (MRZ) 

 

 

 

  a
nd x 
  a
nd x 
  a
nd x 

IDENTITY CARD 
ICAO compliant card to be issued to all IT 
nationals 
ICAO compliant card to be issued to all IT 
nationals 
ICAO compliant card to be issued to all IT 
nationals 

 

 

 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chip 

Biometrics 

Validity in years 

Correct title and title in 
another EU language 
Target data present 

 

 

  a
nd x 
  a
nd x 
10 

ICAO compliant card to be issued to all IT 
nationals 
ICAO compliant card to be issued to all IT 
nationals 
Impact (phasing out of 5 years) 
RESIDENCE DOCUMENTS FOR EU CITIZENS 
  Change of title and translation 

x 

 

 

 

 

 

No change  

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
  Correct translation 
  Correct title  
 
 

Insertion of contactless chip 
Insertion of biometrics  

x 
x 

 
 

Phasing out of 5 years: 

5 
5 

No impact  
No impact  

CURRENT SITUATION IN LITHUANIA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language  
Biographical data and format 
ICAO compliance (MRZ) 
Chip  
Biometrics  
Validity in years 

Correct title and title in 
another EU language 
Target data present 

 

 
 
 
 
10 

IDENTITY CARD 
No change 

No change 
No change 
No change 
No change 
No impact (phasing out in 10 years) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Unknown document 

Unknown document 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
 

  No change 
  No change 

5 
10 

No impact  
No impact 

CURRENT SITUATION IN 
LUXEMBOURG 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

138 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 
 
 
 
10 

IDENTITY CARD 
No change 

No change 
No change 
No change 
No change 
No impact (phasing out in 10 years)  

Correct title and title in 
another EU language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
  Translation of the title 

x 

 

 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
  Translation of the title 
  Uniform format 
 
 

Insertion of a contactless chip 
Insertion of biometrics  

x 
x 

 
 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics 
Validity in years 
- Res. cards FAM 
- Perm. res. cards FAM 

Phasing out in 5 years: 

5 
10 

No impact  
Impact 

 

CURRENT SITUATION IN LATVIA 

IMPACT OF THE PROPOSAL 

Correct title and title in 
another EU language 
Biographical data and 
format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 

 
 
 
5 

IDENTITY CARD 
No change 

No change 

No change 
No change 
No change 
No impact (phasing out in 10 years) 

Correct title and title in 
another EU language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

x 

Change of title 

 

No change 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

 

Title in another EU 
language 
Use of the uniform format 
including correct title and 

x 

 

Title unclear because not readable 

No change 

139 

 

Potential cost 
drivers 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
storage medium and 
biometrics309 
Validity in yrs 
- Res. cards FAM 
- Perm. res. cards FAM 

Phasing out in 10 years: 

5 
10 

No impact  
No impact  

CURRENT SITUATION IN MALTA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in another 
EU language 
Biographical data and format 
ICAO compliance (MRZ) 

Chip 
Biometrics 
Validity in years 

x 

 
 

x 
 
10 

IDENTITY CARD 

  Third EU language needed (MT and 

 

EN official languages in MT) 
No change 
No change 

  Change to contactless chip  

No change 
No impact (phasing out of 10 years) 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in another 
EU language 
Target data present 

x 

 

  Translation of the title 

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics310 
Validity in yrs 
(Res cards FAM)  
(Perm. res. c FAM) 

x 
x 

5 
5 

  Title to translate 
  Change to contactless chip 

Phasing out in 5 years: 

No impact  
No impact  

 

 

 
 

CURRENT SITUATION IN THE 
NETHERLANDS 

IMPACT OF THE PROPOSAL 

Potential costs 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 
 
 
 
10 

IDENTITY CARD 
No change 

No change 
No change 
No change 
No change 
10 

309  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 
310  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

140 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in 
another EU language 
Target data present 

 

 

No change 

No change 

RESIDENCE DOCUMENTS FOR NON-EU FAMILY MEMBERS (FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics311 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 
 

5 
5 

No change 
No change 

Phasing out in 10 years: 

No impact  
No impact  

CURRENT SITUATION IN POLAND 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

x 
 
x 
x 
10 

IDENTITY CARD 
No change 

  Add signature of the holder 

No change 
Inclusion of a contactless chip  
Inclusion of facial image 

 
 

No impact (phasing out in 10 years) 

 

 
 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

x 

  Title (for permanent residence) and 

 

 

translation (for both) 
No change 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
 
  Translation of title 
 
  Obligation to use the full format 
(ICAO and biometrics ok, colours 
missing) 

x 
x 

Correct title and title in 
another EU language 
Target data present 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics312 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

Phasing out in 5 years: 

5 
10 

No impact  
Impact 

 

CURRENT SITUATION IN PORTUGAL 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

311  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 
312  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

141 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics 
Validity in years 

IDENTITY CARD 

  Title of "citizen card" needs change 

 

No change 
No change 

  Change to contactless chip  
  Possibility for Portuguese citizens to 

 

use e-gates 
No change 
No impact (phasing out in 10 years) 

x 

 
 
x 

 
5 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in 
another EU language 
Target data present 

x 

Translation of title of registration 
certificate 
No change 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

 

 

Title in another EU language 

Use of the uniform format 
including correct title and 
storage medium and 
biometrics313 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 

 

5 
10 

Implementation of uniform format in 
2017, to monitor 
Implementation of uniform format to 
monitor 

(if uniform format fully applied) 
No impact  
No impact 

CURRENT SITUATION IN ROMANIA 

IMPACT OF THE PROPOSAL 

Potential 
cost drivers 

IDENTITY CARD 

No change 

Correct title and title in 
another EU language 
Biographical data and format 

ICAO compliance (MRZ) 

Chip 

Biometrics 
Validity in years 

 

x 

 

x 

x 
10 
∞ (>55) 

 

Insertion of date of birth and 
signature – plastic card 
No change 

 
Inclusion of a contactless chip  
  Possibility for Romanian citizens to 

 

use e-gates 
Insertion of facial image 
No impact (phasing out in 10 years) 
Yes with phasing out in 10 years 

 

 

 

  see below 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in 
another EU language 
Target data present 

 

 

No change 

No change 

313  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

142 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics314 
Validity in years 
- Res. Cards FAM  
- Perm. Res. Cards FAM 

 
 

No change 

Introduction of uniform format to 
monitor 

(if uniform format fully applied) 

5 
10 

No impact 
No impact 

CURRENT SITUATION IN SWEDEN 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 
Biometrics 
Validity in years 

 

 
 
x 
 
5 

IDENTITY CARD 
No change 

 

No change 
No change 
Insertion of a contactless chip 
No change 
No impact (Phasing out in 10 years) 

 

RESIDENCE DOCUMENTS FOR EU CITIZENS 
x  Unknown format 

  Unknown format 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
No change 

  Complete title (mention FAM) 
 
Insertion of fingerprints 

 

 
x 

Correct title and title in 
another EU language 
Target data present 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics315 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

Phasing out in 5 years 

5 
5 

No impact  
No impact  

CURRENT SITUATION IN SLOVENIA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in 
another EU language 
Biographical data and format 
ICAO compliance (MRZ) 

 

 
   

IDENTITY CARD 
No change 

No change 
No change 

314  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 
315  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

143 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Chip 

Biometrics 
Validity in years 

Correct title and title in 
another EU language 
Target data present 

Title in another EU language 
Use of the uniform format 
including correct title and 
storage medium and 
biometrics316 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

x 

Insertion of a contactless chip  

 
  Possibility for Slovenian citizens to use e-

 

gates at border controls 
Insertion of facial image  
No impact (phasing out in 10 year) 
Impact 

x 
10 
∞ (>70) 
RESIDENCE DOCUMENTS FOR EU CITIZENS 
No change 

 

 

 

 

  see below 

 

No change 
RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 
No change 

   
x 

  Use of uniform format 
 
Insertion of a chip  
 
Insertion of biometrics  

 

Phasing out in 5 years 
No impact  
Impact 

 

5 
∞  

CURRENT SITUATION IN SLOVAKIA 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

Correct title and title in another 
EU language 
Biographical data and format 
ICAO compliance (MRZ) 
Chip 

Biometrics  

Validity in years 

IDENTITY CARD 

 

No change 

 
   
x 

x 

No change 
No change 
  Change to contactless chip  
  Possibility for Slovak citizens to use 

e-gates 
Insertion of a facial image 

 

10 
∞ (>60) 

No impact (phasing out in 10 years) 
 

Impact 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

Correct title and title in another 
EU language 
Target data present 

x 

 

  Correct title and translation  

No change 

Title in another EU language 

x 

  Translation  

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

 

 

 

 

 

316  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Use of the uniform format 
including correct title and storage 
medium and biometrics317 
Validity in years 
- Res. cards FAM  
- Perm. res. cards FAM 

 

No change 

Phasing out in 10 years 

5 
10 

No impact  
No impact 

CURRENT SITUATION IN UNITED-KINGDOM 

IMPACT OF THE PROPOSAL 

Potential cost 
drivers 

IDENTITY CARD 

NO ID CARD 

Correct title and title in another EU 
language 
Target data present 

RESIDENCE DOCUMENTS FOR EU CITIZENS 

x 

  Translation of the title 

   

No change 

RESIDENCE DOCUMENTS FOR TCN FAMILY MEMBERS (TCN FAM) 

Title in another EU language 

Use of the uniform format including 
correct title and storage medium and 
biometrics318 

Validity in years 
- Res. cards FAM 
- Perm. res. cards FAM 

X 

x 

5 
10 

  Translation of the title 

  Obligation to use the uniform 

format 
Insertion of a contactless chip 
Insertion of biometrics 

 
 
Phasing out in 5 years 

No impact  
Impact 

 

 

 

 

 

317  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 
318  as  established  by  Council  Regulation  (EC)  1030/2002  and  amended  by  Council  Regulation  (EC) 
380/2008 

145