COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a COUNCIL DIRECTIVE establishing an EU Emergency Travel Document and repealing Decision 96/409/CFSP
Date: 2019-04-30
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: EU national, European passport, consulate, diplomatic protection, free movement of persons, third country

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.4.2019  SWD(2018) 273 final/2  This document corrects document SWD(2018)273 final of 31.5.2018. Wrong hyperlinks in page 4 and 13 footnotes. The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document Proposal for a   COUNCIL DIRECTIVE establishing an EU Emergency Travel Document and repealing Decision 96/409/CFSP {COM(2018) 358 final}  - {SEC(2018) 263 final}  - {SWD(2018) 272 final}  
 
 
TABLE OF CONTENTS 

TABLE OF CONTENTS ................................................................................................................. 1 

GLOSSARY ..................................................................................................................................... 2 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 3 

PROBLEM DEFINITION ....................................................................................................... 7 

2.1  What are the problems and their drivers? .................................................................................. 7 

2.2 

How will the problem evolve? ................................................................................................. 12 

3.  WHY SHOULD THE EU ACT? ........................................................................................... 14 

3.1 

3.2 

3.3 

Legal basis ............................................................................................................................... 14 

Subsidiarity: Necessity of EU action ....................................................................................... 14 

Subsidiarity: Added value of EU action .................................................................................. 14 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 15 

4.1 

4.2 

General objectives ................................................................................................................... 15 

Specific objectives ................................................................................................................... 15 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 16 

5.1  What is the baseline from which options are assessed? ........................................................... 16 

5.2 

5.3 

Description of the policy options ............................................................................................. 16 

Options discarded at an early stage .......................................................................................... 26 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 30 

6.1 

6.2 

6.3 

Impacts from Policy Option 1 .................................................................................................. 30 

Impacts from Policy Option 2 .................................................................................................. 30 

Impacts from Policy Option 3 .................................................................................................. 38 

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

8. 

PREFERRED OPTION ......................................................................................................... 42 

8.1.  REFIT (simplification and improved efficiency)..................................................................... 45 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 46 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................. 49 

ANNEX 2: STAKEHOLDER CONSULTATION ........................................................................ 52 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 66 

ANNEX 4: ANALYTICAL METHODS ....................................................................................... 69 

EN 

  EN 

 
 
 
 
GLOSSARY 

Term or acronym 

Meaning or definition 

Consular Protection Directive 

Directive (EU) 2015/637 

DOVID 

EEAS 

ETD 

EU ETD 

Diffractive 
optically 
(holographic element) 

variable 

image 

device 

European External Action Service 

Emergency  Travel  Document  is  a  temporary  travel 
document issued to a citizen when his or her passport 
or travel document has been lost, stolen or destroyed 
or  is  temporarily  unavailable.  This  can  include  both 
national  ETD  and  the  European  Format  ETD  (as 
provided for in Decision 96/409/CFSP) 

ETD issued to EU unrepresented citizen on the basis 
of  a  common  format  provided  for  in  Decision 
96/409/CFSP 

EU ETD Decision 

Decision 96/409/CFSP 

EUR/€ 

Euro 

Member States 

Member States of the European Union 

MRTD 

PKI 

TEC 

Machine Readable Travel Document 

Public Key Infrastructure 

Treaty Establishing the European Community  

2 

 
 
 
 
 
 
 
 
 
 
 
 
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The  right  to  equal  treatment  regarding  consular  protection  is  one  of  the  specific  rights 
granted by the Treaties to EU citizens on the basis of their EU citizenship. This right is set out 
in Articles 20(2)c and 23 of the Treaty on the Functioning of the European Union (TFEU) and 
Article  46  of  the  EU  Charter  of  Fundamental  Rights.  It  is  further  spelled  out  in  an  EU 
Directive  on  consular  protection  for  unrepresented  European  citizens  living  or  travelling 
outside the EU, which was adopted on 20 April 2015 and will enter into application on 1 May 
20181.  

On  the  basis  of  this  right,  European  citizens  are  entitled  to  seek  help  from  the  embassy  or 
consulate  of  any  other  EU  Member  State  if  they  find  themselves  in  a  situation  where  they 
need  advice  or  assistance  outside  the  EU,  with  no  embassy  or  consulate  from  their  own 
country to help them (if they are "unrepresented"). 

Decision  96/409/CFSP2  introduced  the  EU  common  format  Emergency  Travel  Document 
(hereafter, "EU ETD") to be issued by Member States to unrepresented EU citizens in third 
countries.  EU  emergency  travel  documents  are  documents  being  issued  such  citizens  when 
their  passport  or  travel  document  has  been  lost,  stolen  or  destroyed  or  is  temporarily 
unavailable. 

EU ETDs are issued in relatively small numbers3, but they constitute the most frequent type 
of  assistance  provided  by  Member  States  to  unrepresented  EU  citizens  in  distress  in  third 
countries4  and  are  indispensable  in  helping  these  citizens  return  safely  home.  Issuing  EU 
ETDs  is  a type of assistance which normally (outside the EU) cannot  be substituted by any 
other type of assistance, as holding a travel document is a prerequisite for travelling back to 
and crossing the external borders of the EU. 

European citizens can thus rely in third countries on the protection deriving from their status 
as  European  citizens.  This  right  is  an  expression of  EU  solidarity  and  of  the  identity  of  the 
European  Union  in  third  countries,  as  well  as  one  of  the  practical  benefits  of  being  an  EU 

1  

2  

3  

4  

p. 

4–11), 

Council  Directive  (EU)  2015/637  of  20  April  2015  on  the  coordination  and  cooperation  measures  to 
facilitate  consular  protection  for  unrepresented  citizens  of  the  Union  in  third  countries  and  repealing 
Decision 95/553/EC (OJ L 106, 24.4.2015, p. 1–13) 
Decision  96/409/CFSP  of  the  Representatives  of  the  Governments  of  the  Member  States,  meeting 
within the Council of 25 June 1996 on the establishment of an emergency travel document (OJ L 168, 
http://eur-lex.europa.eu/legal-
6.7.1996, 
content/EN/ALL/?uri=CELEX:41996D0409 
In  absolute  terms  the  number  of  EU  ETDs  issued  is  relatively  low.  The  annual  numbers  have  been 
estimated at around 320 outside the EU and another 250 within the EU. It is estimated that another 400-
500 unrepresented citizens are issued annually national ETDs by the Member States not using the EU 
ETD.  However,  the  figures  concerning  EU  ETDs  are  fragmentary  and  probably  underestimated,  as 
currently not all Member States collect precise data on EU ETDs.   
According  to  the  2017  EU  Citizenship  Report  (COM  (2017)  30  final/2),  the  “issuance  of  emergency 
travel documents is in practice the most frequent form of assistance given by the MSs to unrepresented 
EU citizens (more than 60% of all cases)”. 

available 

at: 

3 

 
                                                           
 
citizen. It fully aligns with the priorities of the Commission of bringing the EU closer to its 
citizens.  

Twenty years on, as the evaluation report accompanying this Impact Assessment shows, there 
is fragmentation amongst EU Member States in the application of Decision 96/409/CFSP by 
the Member States.  Furthermore, important changes that have taken place since 1996 in the 
EU acquis on unrepresented citizens' right to consular protection and the global security 
environment, including improvements to the security of travel documents, are not reflected in 
this Decision.  

This  Impact  Assessment  assesses  possible  policy  options  to  address  the  difficulties 
unrepresented  citizens  face  when  exercising  their  right  to  consular  protection  in  the  area  of 
emergency  travel  documents.  It  is  based  on  the  findings  of  an  external  study,  public  and 
stakeholder consultations and other sources. 

Political context 

The  EU  common  format  emergency  travel  document  was  established  by  Member  States  in 
1996 both to provide genuine help to unrepresented EU citizens in distress and to demonstrate 
the practical benefits of being a citizen of the Union. The EU ETD adds an external dimension 
to  the  concept  of  Union  citizenship  and  strengthens  the  idea  of  European  solidarity  and  the 
identity of the Union in third countries. 

On 18 January 2011, the Council invited the European Commission to make a proposal for a 
new European ETD containing security features in line with current practices.  

In 2012, in its communication Consular protection for EU citizens in third countries: State of 
play and way forward5, the Commission acknowledged that consideration should be given to 
a possible update of the format of ETDs.  

In parallel, the International Civil Aviation Organisation (www.icao.int) worked on Guidance 
on  Emergency  Travel  Documents6,  including  principles  for  recommended  practice.  The 
Guidance was published in May 2016 containing an explicit reference to the EU ETD7.  

During their presidencies of the Council, both Lithuania and Luxemburg initiated work in the 
Competent Working Group of the Council (COCON) regarding the EU ETDs. 

More  recently,  in  its  Communication  entitled  “Enhancing  security  in  a  world  of  mobility: 
improved information exchange in the fight against terrorism and stronger external borders”, 
the  Commission  committed  to  "by  December  2016,  adopt  an  Action  Plan  on  document 

5  
6  

7  

COM(2011) 149 final. 
Available at: 
https://www.icao.int/Security/mrtd/Downloads/Guidance%20Material/Guidance%20on%20Emergency
%20Travel%20Documents%20May%202016%20final.pdf  
The Commission followed actively the work of ICAO on ETDs as it does for all documents relevant for 
the European Union. 

4 

 
                                                           
security, as well as to explore enhanced security features for Emergency Travel Documents”8. 
By  enhancing  the  security  features  of  the  EU  ETD,  the  risk  of  counterfeiting  and  forgery 
would be reduced, thereby combating fraud as well as the misuse of travel documents. In turn, 
this should support the fight against terrorism and organised crime. On 8 December 2016, The 
Commission  published  the  "Action  plan  to  strengthen  the  European  response  to  travel 
document  fraud"9.  On  the  basis  of  the  Action  plan,  the  Council  adopted,  in  March  2017, 
Council  Conclusions  highlighting  the  crucial  importance  of  secured  travel  and  identity 
documents and called the Commission to ensure appropriate follow-up10. 

In  the  2017  Citizenship  Report11,  the  Commission  committed  to  "in  2017  assess  how  to 
modernise the rules on emergency travel documents for unrepresented EU citizens, including 
the  security  features  of  the  EU  common  format,  to  guarantee  that  citizens  can  effectively 
exercise their right to consular protection". 

On  this  basis,  the  Council  adopted  in  May  2017  Council  Conclusions  highlighting  the 
importance  of  secured  travel  and  identity  documents  and  called  the  commission  to  ensure 
appropriate  follow-up.  The  Council  in  its  Conclusions12  adopted  in  June  2017  on  the  2017 
Citizenship  Report  invited  the  Commission  to  "strengthen  the  security  of  citizens  through 
continuing  to  support  implementation  of  the  European  Agenda  on  Security  and  to  improve 
where necessary the security of identity, residence and travel documents."  

The  European  Parliament  in  its  resolution13  adopted  at  the  end  of  2017  on  the  2017 
Citizenship  Report  called  on  the  Commission  "to  make  a  proposal  for  a  new,  more  secure 
format for an EU emergency travel document  for unrepresented EU citizens outside the EU 
whose  passport  has  been  stolen,  lost,  destroyed  or  is  temporarily  unavailable,  in  order  to 
guarantee that they can return home safely." 

The  Commission  has  announced  in  its  work  programme  for  2018  that  it  would  consider  a 
proposal for a Council Directive to replace the Decision on the establishment of an emergency 
travel document. 

Legal context 

The  existing  applicable  legal  instrument  is  the  Decision  of  the  Representatives  of  the 
Governments  of  the  Member  States  meeting  within  the  Council  of  25  June  1996  (Decision 
96/409/CFSP)  on  the  establishment  of  an  emergency  travel  document,  which  defines  the 
common format for such EU ETDs, the circumstances under which they should be issued and 
their security features.  

8  
9  
10  

11  
12  
13  

COM (2016) 602 final. 
COM(2016) 790 final. 
Council  Conclusions  on  the  Commission  Action  plan  to  strengthen  the  European  response  to  travel 
document fraud, 7696/17. 
Available at: http://europa.eu/rapid/press-release_IP-17-118_en.htm  
Council Conclusions on the EU Citizenship Report 2017, 8028/1/17 REV 1. 
European  Parliament  resolution  of  12  December  2017  on  the  EU  Citizenship  Report  2017: 
Strengthening Citizens’ Rights in a Union of Democratic Change (2017/2069(INI)). 

5 

 
                                                           
This Decision was adopted under the legal regime prior to the Lisbon Treaty, where Member 
States  had  to  establish  among  themselves  the  necessary  rules  to  ensure  equal  treatment  on 
consular protection. Two succinct sui generis decisions were adopted, the one  on ETDs and  
Decision  95/535/EC  on consular  protection,  which  has  since  been  repealed  and  replaced  by 
the Directive on consular protection adopted in 2015 on the basis of Article 23 TFEU. 

The Treaty of Lisbon abandoned the previous logic of intergovernmental sui generis decision-
making  and  empowered  the  Commission  to  initiate  legislation  on  the  coordination  and 
cooperation  measures  necessary  to  facilitate  the  right  to  equal  treatment  on  consular 
protection.  The  Treaty  took  into  account  the  increased  need  for  a  European  dimension  for 
consular protection by reinforcing and clarifying the capacity of the Union to  act.  By doing 
so,  it  reinforced  the  status  of  Union  citizenship and  strengthened  the  rights  derived  from  it.  
Article 23 TFEU now provides for the adoption of directives establishing the cooperation and 
coordination measures necessary to facilitate consular protection for unrepresented citizens of 
the Union.  

Article  23  TFEU  confers  to  the  Commission  the  right  to  initiate  legislative  proposals,  i.e. 
directives establishing cooperation and coordination measures necessary to facilitate the right 
to consular protection for unrepresented EU citizens. Such legislative proposals are, following 
consultation of the European Parliament, subject to qualified majority voting in the Council.  

Furthermore,  the  right  to  protection  by  consular  and  diplomatic  authorities  as  enshrined  in 
Article 23 TFEU is subject to judicial review. The provisions of Part Two of the TFEU are 
under full review of the European Court of Justice. Also national courts have to apply Article 
23 TFEU as any other provision of Union law14. 

In this context the Council approved on 20 April 2015 a Directive “on the coordination and 
cooperation measures to facilitate consular protection for unrepresented citizens of the Union 
in  third  countries”  (the  Consular  Protection  Directive)15,  which  lays  down  the  coordination 
and  cooperation  measures  necessary  to  facilitate  the  exercise  of  the  right  of  EU  citizens  to 
enjoy,  in  the  territory  of  a  third  country  in  which  the  Member  State  of  which  they  are 
nationals is not represented, the protection of the diplomatic and consular authorities of any 
Member State on the same conditions as the nationals of that Member State. 

The  Consular  Protection  Directive  provides  a  general  framework  of  coordination  and 
cooperation measures applicable to all types of assistance provided by the Member States to 
unrepresented citizens in third countries. Article 9 of the Directive expressly mentions among 
the  types  of  assistance  included  in  the  scope  of  consular  protection  the  need  for  emergency 
travel documents as provided for in Decision 96/409/CFSP.  

14  
15  

See COM(2011) 149 final. 
Council  Directive  (EU)  2015/637  of  20  April  2015  on  the  coordination  and  cooperation  measures  to 
facilitate  consular  protection  for  unrepresented  citizens  of  the  Union  in  third  countries  and  repealing 
Decision 95/553/EC. 

6 

 
                                                           
The  Consular  Protection  Directive  shall  be  transposed  by  1  May  2018.  Any  update  of  the 
Decision  96/409/CFSP  in  the  form  of  a  new  Directive  would  therefore  particularise  and 
complement the Consular Protection Directive concerning consular protection by means of an 
EU ETD. 

Finally, in  line with  Article 35 of the Treaty on the European Union and  as  reflected in  the 
Directive on consular protection, Union delegations, in close cooperation with the diplomatic 
and consular missions of the Member States, contribute to the implementation of the right of 
union citizens to consular protection16. 

2. PROBLEM DEFINITION 

1.1.  What are the problems and their drivers? 

This  Impact  Assessment  has  been  undertaken  following  the  request  of  the  Council  to  the 
Commission  to  “make  a proposal  for  the  production  of  a  new  European  Emergency  Travel 
Document that contains security features in line with current practices, updating the features 
described in Decision 96/409/CFSP”17. More recently, in 2017, the Council adopted two set of 
Council Conclusions recognising the importance of secured travel and identity documents and 
calling on the Commission to ensure proper follow-up18. This request was recently echoed by 
the European Parliament in its Resolution on the 2017 EU citizenship report19. 

In  line  with  the  case-law  of  the  Court  of  Justice,  citizenship  of  the  Union  should  be  the 
fundamental  status  of  EU  citizens  when  exercising  their  rights  under  the  Treaties.  Citizens 
should be able to make use of their rights with legal certainty. This is not the case currently, 
since  Decision  96/409/CFSP,  as  an  inter-governmental  Decision,  is  not  enforceable  and 
does  not  allow  the  Commission  to  perform  its  role  of  monitoring  and  instigating  an 
action against Member States for breaching the rules if necessary. In addition, the wording of 
the very short Decision is ambiguous on the scope of the legal obligation for Member States 
to make use of the common format.  

16  

17  
18  

19  

As referred to in  Article 20(2)(c) of the  Treaty on the  Functioning of the European Union and of the 
measures adopted pursuant to Article 23 of that Treaty. 
http://data.consilium.europa.eu/doc/document/ST-5287-2011-INIT/en/pdf  
Council  Conclusions  on  the  Commission  Action  plan  to  strengthen  the  European  response  to  travel 
document fraud, 7696/17 and Council Conclusions on the EU Citizenship Report 2017, 8028/1/17 REV 
1. 
European  Parliament  resolution  of  12  December  2017  on  the  EU  Citizenship  Report  2017: 
Strengthening 
Change 
http://www.europarl.europa.eu/sides/getDoc.do?type=TA&reference=P8-TA-2017-
0487&language=EN&ring=A8-2017-0385  

Democratic 

Citizens’ 

Rights 

Union 

of 

in 

a 

7 

 
 
 
                                                           
Box 2-1: Lack of enforceability 

JG, an EU citizen of Member State A was attacked and robbed on her first day of holiday in 
third  country  B,  where  her  Member  State  is  not  represented.  Amongst  her  stolen 
possessions  were  her  passport  and  ID  card.  She  called  Member  State  A's  nearest 
representation  abroad  to  ask  for  assistance,  but  was  told  to  call  the  embassy  of  another 
neighbouring country. With no response from them, she turned to her family for help. She 
was told to contact a certain EU Member State's embassy which should provide consular 
protection,  but  was  denied  any  assistance.  She  then  tried  another  6  embassies  and 
consulates in order to obtain an ETD – alas without success. She then again called her own 
Member State's representation in a neighbouring country and spoke with a member of staff 
that facilitated the procedure by directly contacting one of the embassies in third country B 
that  JG  had  already  turned  to.    (Report  by  a  citizen  submitted  during  the  public 
consultation)  

Neither  the  Commission  nor  the  Court  of  Justice  is  empowered  to  enforce  the  specific 
provisions  of  Decision  96/409/CFSP.  At  the  same  time,  the  Commission  and  the  Court  of 
Justice  are  competent  as  regards  the  Treaty  provisions  on  consular  protection  and  the 
Consular Protection Directive that will enter into application in May 2018. This creates issues 
of legal uncertainty. 

Overall, the evaluation  found that the issuance of EU ETDs has been effective in  providing 
genuine  help  to  EU  citizens  in  distress  in  third  countries  and  provided  a  practical 
demonstration of the benefits of EU citizenship. EU ETDs are expected to remain relevant in 
the future. However, there is room to improve the implementation of the EU ETD Decision, 
to  ensure  its  consistency  with  the  Consular  Protection  Directive,  which  will  enter  into 
application  very  soon,  and  to  improve  the  security  of  the  EU  ETD  format  in  a  context  of 
changing security needs. This impact assessment addresses the key problems identified by the 
evaluation, which are outlined and elaborated below. 

The  evaluation  conducted  has  revealed  a  fragmented  approach  regarding  the  use  of  EU 
ETDs,  lacking  the  necessary  clarity  for  citizens  and  stakeholders.  Three  Member  States  are 
not  issuing  the  EU  ETD  due  to  concerns  regarding  its  security  features.  The  problem  of 
non-issuance is aggravated because the three countries in question (UK, Germany and France) 
are  the  Member  States  with  the  highest  level  of  consular  representation  in  third  countries. 
Instead of using the harmonised EU format, these countries issue national ETDs, arguing that 
their security features surpass those of the EU ETD20.  

Another issue is the security of the documents used. Document fraud is seen as an enabler of 
terrorism and organised crime, and is linked to the trafficking of human beings and migrant 
smuggling21. However, the evaluation has revealed that very limited information and data are 
being  gathered  by  national  and  international  authorities  on  forgery  of  the  EU  ETD. 

20  
21  

National ETDs of other Member States have largely similar security features to those of the EU ETD. 
COM (2016) 790 final. 

8 

 
 
 
                                                           
Consultation  with  the  Member  States  competent  authorities,  Interpol,  Frontex  and  border 
police22 seems to suggest that at the moment the problem remains limited in scope, although 
this  may  be  due  to  the  low  numbers  of  EU  ETD  issued  annually  in  comparison  with 
emergency  and  non-emergency  passports.  However,  recent  discoveries  (see  box  below), 
developments  regarding  other  travel  documents,  including  ID  cards,  and  recently  published 
international  guidance  by  the  ICAO  give  cause  for  concern  that  the  EU  ETD,  in  its  current 
form, does not have a sufficient level of security features. The current format ETD has indeed 
little protection against fraud and counterfeits.  

Box 2-2: EU ETD and counterfeit passports 

Since  July  2017,  EU  Member  States  authorities  have  discovered  a  few  counterfeited 
ePassports allegedly issued by other EU Member States containing a paper watermark that 
appears  to  be  the  same  as  the  one  used  in  EU  Emergency  Travel  Document.  The 
investigation is ongoing, but it demonstrates that the 'weak link' of ETDs may have already 
been  targeted  by  criminal  networks  trafficking  in  false  documents  and  that  the  security 
features should be increased. (Report by a Member State) 

Therefore,  improving  security  features  is  not  only  important  for  meeting  the  standards 
expected  by  the  Member  States,  but  will  also  enhance  the  future-proofing  of  the  document 
and  contribute  to  the  wider  goal  of  EU  security,  as  EU  ETDs  can  be  used  by  a  European 
citizen to travel to his or her country of origin, his or her country of permanent residence or 
exceptionally to another destination. 

lack  of  enforceability,  other  areas  generating 

legal  uncertainty  are 
Apart  from 
inconsistencies between the EU ETD Decision and the Consular Protection Directive, which 
explicitly  refers  to  EU  ETDs  as  a  type  of  consular  assistance  provided  to  unrepresented 
citizens. These inconsistencies include key concepts such as “absence of representation” and 
Member State “clearance”.  

Under the Consular Protection Directive, absence of representation has been further defined 
to ensure "the effectiveness of the right of unrepresented citizens to be protected by another 
Member  State's  embassy  or  consulate  in  a  non-discriminatory  way,  taking  into  account  the 
circumstances  of  each  particular  case."  According  to  the  Directive,  a  European  citizen  is 
unrepresented  in  a  third  country  even  if  their  Member  State  of  nationality  is  locally 
represented, but is unable for any reason to provide the protection. The Directive states that 
when establishing the absence of representation, "accessibility and proximity" should be taken 
into consideration, so that large  geographical  distances or poor transport  connections within 
some third countries can be taken into account. 

Decision  96/409/CFSP,  for  its  part,  refers  exclusively  to  “citizens  of  the  Union  in  places 
where  those  citizens'”  Member  State  of  origin  has  no  permanent  diplomatic  or  consular 

22  

Based  on  seventeen  responses;  although  it  is  known  that  Member  States'  competent  authorities 
answering the survey have also consulted internally with their border force authorities.  

9 

 
 
 
                                                           
representation”  and  its  Annex  II  to  the  absence  of  “accessible  diplomatic  or  consular 
representation  with  the  capacity  to  issue  a  travel  document  or,  where  that  State  is  not 
otherwise  represented”.  The  wording  is  not  completely  aligned  and  could  therefore  lead  to 
situations  where  an  EU  citizen  could  invoke  certain  rights  on  the  basis  of  the  Consular 
Protection Directive but could not rely on the EU ETD Decision in the same context. 

Box 2-3: Absence of representation 

A Hungarian national was unable to get an ETD after losing his passport in the Southern 
province of  Guangdong of  the People's Republic of  China,  where Hungary does  not  have 
consular presence. Missions of Members States there either do not issue ETD at all or they 
considered the Hungarian as having a representation in China. (Report by a citizen) 

The Consular Protection Directive also does away with the need for prior agreement of the 
unrepresented  citizen's  Member  State  of  nationality  before  consular  assistance  can  be 
provided.  It  stipulates  that  the  assisting  Member  State  shall  consult  the  Member  State  of 
nationality  to  inform  it  of  the  situation  and  verify  the  identity  of  the  citizen.  The  Member 
State  of  nationality  is  obliged  to  provide  this  information  or  transfer  the  case  and  deliver 
consular assistance directly. The lack of prior agreement is not considered a legitimate reason 
for the assisting Member State to deny assistance. For its part, the EU ETD Decision imposes 
the obligation for the assisting Member State to obtain “clearance” from the Member State of 
nationality  before  providing  assistance,  and  does  not  specify  the  obligation  of  the  Member 
State of nationality to provide the requested information.  

The  Consular  Protection  Directive  stipulates  that  contacts  and  communication  between 
Member  States  concerning  consular  assistance  for  unrepresented  citizens  should  take  place 
"without delay". However, the evaluation has discovered a wide range of processing times by 
the  Member  States  for  issuing  and  providing  clearance  for  an  EU  ETD,  from  a  couple  of 
hours to several weeks. Although exceptional cases must be taken into account, there seems to 
be  a  lack  of  clear  target  deadlines  which  would  ensure  that  the  unrepresented  citizen  is 
provided with assistance in a reasonable time. 

Box 2-4: Lack of deadlines 

A  Bulgarian  citizen  was  on  holiday  with  her  17-year-old  daughter  in  Thailand  when  her 
hand bag, containing the passports, credit cards and cash, was stolen, losing.  She went to 
the police station in Bangkok, to the 'tourist police' department and requested a copy of the 
passport  from  the  hotel.  There  is  no  embassy  of  Bulgaria  in  Bangkok,  so  she  was 
recommended another EU embassy…. At the beginning the embassy denied issuing an ETD 
for  the  17-year-old  daughter  and  asked  for  her  father’s  approval.  But  after  explaining  the 
emergency situation the embassy agreed to provide her with an ETD as well. Although she 
was told it would take 3-4 business days, in reality it took 10-12 days. (Report by a citizen) 

10 

 
 
 
 
 
 
The  EU  ETD  Decision  still  provides  for  a  cumbersome  and  outdated  procedure,  which 
obliges the citizen applying for an EU ETDs to send a filled-in application and certified true 
copies to "an authority designated to that effect of the applicant's Member State of origin". In 
the Consular Protection Directive, the responsibility is not on the citizen, but on the Member 
States to communicate directly and arrange for transfer of any required information.  

Furthermore, there are financial provisions in the EU ETD Decision that are less favourable 
to citizens when compared to the Directive. According to the EU ETD Decision, a Member 
State  can  require  the  unrepresented  citizen  to  pay  the  same  fees  as  it  would  levy  its  own 
citizens for issuing an emergency passport. Under the Consular Protection Directive, and in 
line with Treaty provisions, the unrepresented citizens should undertake to repay only those 
costs that would have to be borne by nationals of the assisting Member State under the same 
conditions. This would equate to the cost of a national ETD, which normally costs less than 
an emergency passport. Similarly, the Consular Protection Directive provides for situations in 
which the citizen does not have the financial means to cover the issuance fee and regulates the 
reimbursement procedure between the assisting and the Member State of nationality. This is 
currently not adequately covered in the EU ETD Decision. 

The  evaluation  conducted  for  the  Impact  Assessment  has  also  shown  that,  in  practice,  EU 
ETDs are currently issued by the Member States in a number of situations not listed in 
the  Decision,  which  refers  to  travel  documents  being  “lost,  stolen  or  destroyed”  or 
“temporary  unavailable”.  These  cases  include  issuing  EU  ETDs  to  new-born  babies  or  in 
cases of expired passports. This discrepancy also leads to legal uncertainty. 

Another  aspect  that  could  benefit  from  enhanced  legal  clarity  relates  to  the  use  of  the  EU 
ETD outside the scope of the Decision. While the scope of the EU ETD Decision is limited 
to  consular  protection  of  unrepresented  citizens  in  third  countries,  several  Member  States 
issue  the  EU  ETD  to  unrepresented  citizens  within  the  EU  (e.g.  Austria,  Estonia,  Spain, 
Hungary, Italy, Malta, Latvia, and Sweden) and one Member State (Italy)  issues it also to its 
own citizens.  

Finally,  the  evaluation  has  revealed  problems  with  regard  to  the  acceptance  and 
recognisability of the EU ETD by third countries, and sometimes also by EU border guards 
when crossing the EU external borders. As reported by some Member States, using different 
documents (EU ETD or a national ETD) creates confusion, and if a non-national travels with 
a  national  ETD,  this  may  even  create  suspicion  regarding  the  authenticity  of  the  document. 
This is especially the case when the national ETD is not actually foreseen to be used by non-
nationals, and therefore when used in this way, the indication of nationality must be modified 
by hand. Some third countries, such as the USA, require entry visas, which currently cannot 
be  attached  to  the  EU  ETD  due  to  the  lack  of  blank  pages.  Member  State  consulates 
sometimes  have  to  provide  supporting  letters  explaining  the  EU  ETD  to  border  guards  or 
accompany the citizen to the airport. Several Member States also recommend to citizens that 
they avoid transiting through certain third countries. 

Other  third  countries  lack  adequate  specimens  that  would  allow  them  to  recognise  the  EU 
ETD format. Although specimens have been sent in the past by the EU on an ad-hoc basis, the 

11 

 
EU  ETD  Decision  does  not  specify  the  responsible  institution  for  providing  the  EU  ETD 
specimens and ensuring their recognition world-wide. 

2.2  How will the problem evolve? 

The number of citizens in need of an EU ETD are expected to increase23. In 2015, there were 
4.3 million EU citizens that were unrepresented when travelling abroad24. Precise numbers of 
unrepresented  EU  citizens  travelling  and  living  abroad  (for  professional  or  family  reasons, 
holidays, studies etc.) are hard to obtain (as statistics are seldom gathered by Member States), 
but the evaluation report noted that citizens residing abroad could range from 1.1 million to 
2.7  million,  based  on  literature  review  findings  and  consultation25.  For  citizens,  consular 
assistance through the provision of ETDs will continue to be relevant in the future, especially 
given that the number of EU citizens travelling to third countries is increasing (see Box 2-2).  

The provision of ETDs is already the most common type of consular assistance provided to 
EU  citizens  (around  65%  of  all  cases)  and  Member  States  are  expecting  this  to  remain  the 
case  for  the  foreseeable  future.  Indeed,  no  Member  State  that  participated  in  the  survey 
undertaken  for  evaluation  expected  a  fall  in  the  number  of  ETDs  required  for  their  own 
citizens26. Furthermore, a significant number of Member States also expects that there will be 
more citizens of other Member States turning to their consulates for EU ETDs.  

It should be stressed however that the EU ETD by its very nature is not a frequently issued 
document  and  therefore  any  problems  in  its  application  will  affect  a  limited  yet  increasing 
number of people directly. However, the level of impact on these citizens is significant. Being 
stranded in  a foreign, often far away country without  identity document and a possibility to 
return home is a precarious situation by any measure, producing both psychological distress 
and potentially significant economic cost 

23  

24  

25  

26  

The  Commission  has  launched  information  awareness  activities  to  better  inform  European  citizens 
about  this  right  which  is  not  sufficiently  known.  See  2017  EU  citizenship  report,  available  at: 
http://ec.europa.eu/newsroom/just/item-detail.cfm?item_id=51132 
This is based on data on the level of representation for 2017 as provided by the EEAS, but the travel 
data  are  from  the  UNWTO  and  are  based  on  2015  statistics,  as  more  recent  data  are  not  currently 
available. However, the level of representation between 2015 and 2017 has changed little. 
Numbers could not be reliably estimated. Different sources include: GHK (2011): Study on the Impact 
Assessment on Improving Financial Compensation of Consular Protection in Crisis Situations, a study 
for DG Justice (2017): 2017 Citizenship Report (EC, 2017). Consultation for the evaluation report has 
revealed significantly lower numbers.  
Evaluation report, section 5. 

12 

 
                                                           
Box 2-5: Tourism trends27 

As  the  World  Travel  Monitor®  results  for  the  first  eight  months  of  2016  made  clear, 
worldwide  outbound  travel  continues  to  grow  despite  terror  attacks  and  political  unrest. 
European outbound travel grew by 2.5%, with growth from the UK by 6% and Germany by 
4%.  

In  2016,  three  countries  moved  up  in  the  Top  10  ranking  by  international  tourist  arrivals 
(overnight  visitors),  China,  Mexico  and  Thailand.  Most  notably,  Thailand  moved  up  one 
place  in  arrivals  to  9th  position  (33  million).  Currently,  21  Member  States  have 
representation in Thailand (based on information provided by the EEAS, 2017) and seven 
Member States do not (Bulgaria, Cyprus, Estonia, Croatia, Latvia, Malta and Slovenia). 

According  to  UNWTO’s  long-term  forecast  report  Tourism  Towards  2030,  international 
tourist arrivals worldwide are expected to increase by 3.3% a year between 2010 and 2030 
to  reach  1.8  billion  by  2030.  Between  2010  and  2030,  arrivals  in  emerging  destinations 
(+4.4% a  year) are expected to  increase  at  twice the rate of those in  advanced economies 
(+2.2% a year). 

Without changes to the EU ETD Decision, the Commission will remain unable to enforce the 
specific  provisions  in  case  of  breach  of  its  content  by  Member  States.  The  Court  of  Justice 
will  have  no  competence  to  intervene.  The  inconsistencies  outlined  in  the  previous  section 
between the EU ETD Decision and the Consular Protection  Directive, which will enter into 
application shortly, may cause additional conflicts.  

The  inconsistent  security  features  in  documents  will  continue  to  raise  security  and  border 
management related issues. Without regular updating, the current format is likely to become 
more  attractive  to  forgers,  especially  as  the  security  of  other  travel  documents  is  gradually 
increased and they become harder to falsify. This situation, besides posing a security threat in 
its  own  right,  is  likely  to  lead  to  EU  Member  States  further  abandoning  the  use  of  the 
harmonised format. For the same reasons, it is likely that fewer third countries will recognise 
the format in the future. This will result in a lack of recognition and denial of entry/transit at 
borders  or  denial  of  boarding  aircrafts,  with  costs  implications  for  citizens  and,  potentially, 
insurance companies and carriers.  

This  security  threat  is  potentially  aggravated  by  the  fact  that  the  Commission  is  taking 
initiatives  in  related  areas,  such  as  to  improve  the  security  of  ID  cards  and  residence 
documents28,  which  could  leave  the  EU  ETD  as  the  "weak  link"  in  terms  of  document 
security. 

27  

28  

IPK (2017): ITB world travel trends report 2016 / 2017, prepared by IPK international on behalf of ITB 
berlin, 
https://www.itb-
berlin.de/media/itb/itb_dl_all/itb_presse_all/World_Travel_Trends_Report_2016_2017.pdf 
UNWTO (2017): Tourism highlights, available at: https://www.e-
unwto.org/doi/book/10.18111/9789284419029  
COM(2017) 30 final/2. 

13 

 
 
                                                           
Finally, without a clear role given to a single entity to provide specimens of EU ETD to third 
countries and to promote acceptance of the document, there is a real risk that this will have a 
negative impact on the acceptance of the document over time.  

3. WHY SHOULD THE EU ACT? 

3.1 

Legal basis 

The  Treaties  provide  for  the  necessary  legal  basis  for  the  initiative.  In  particular,  the  EU’s 
competence  to  adopt  legislation  on  consular  protection  for  unrepresented  EU  citizens  is 
conferred  by  Article  23(2)  of  the  Treaty  on  the  Functioning  of  the  European  Union. 
According to the Article, the Council may adopt directives establishing the coordination and 
cooperation measures necessary to facilitate protection for unrepresented EU citizens.  

3.2 

Subsidiarity: Necessity of EU action 

The EU is better placed than individual Member States to act given the following factors: 

1. 

2. 

3. 
4. 

5. 

from  adopting 

In view of the existence of a European format governing ETD, adaptions and changes 
to the common format can only be carried out at the EU level. 
In view of the new legal regime created by the Lisbon Treaty, any reform of the CFSP 
Decision can only be undertaken in the form of EU legislation based on Article 23(2) 
substantial 
TFEU.  Member  States  are  precluded 
intergovernmental measures. 
Member States have established a different interpretation of the EU ETD Decision.  
There  is  a  necessity  to  ensure  the  smooth  articulation  and  alignment  the  EU  ETD 
Decision  with  the  provisions  of  the  Consular  Protection  Directive,  which  provides  a 
general framework of coordination and cooperation measures applicable to all types of 
assistance provided by the Member States to unrepresented citizens in third countries. 
Assistance for unrepresented EU citizens entails a cross-border dimension, extending 
the rights granted by EU citizenship beyond the Union's borders. This right illustrates 
the concrete benefits connected with the status of EU citizenship.  

further 

3.3 

Subsidiarity: Added value of EU action 

A more secure EU ETD would contribute to the overall security of the EU by addressing the 
'weak link'  among  the travel  documents  allowed  for entry into the Union. These documents 
allow entering any EU border and therefore only a common action by all the Member States 
can close such 'weak links'. 

Increased  security  features  would  also  contribute  to  ending  fragmentation  among  the  EU 
Member States in the issuance of the EU ETD and increasing recognition by third countries. 
This would reduce the risk of citizens being denied access to aircraft or transit through third 
countries,  allowing  them  to  return  to  their  homes  or  other  destinations  hassle  free,  thus 
providing relief in stressful situations. This would represent to citizens a clear benefit of EU 
citizenship and solidarity among the EU's Member States.  

14 

 
 
EU  action  under  the  Lisbon  Treaty  would  also  allow  for  effective  monitoring  of 
implementation  and  facilitate  enforcement,  as  for  any  proposed  EU  legal  measures  the  full 
spectrum of enforcement mechanisms would apply (e.g. the duty to transpose a directive into 
national  law,  references  for  preliminary  rulings,  infringement  proceedings  for  failure  to 
implement requirements, etc.).  

Finally,  economies  of  scale  would  also  arise  in  relation  to  production  costs  and  awareness-
raising among citizens.  

4. OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

The overarching objectives of the action are as follows: 

o 

o 

To strengthen EU citizenship by facilitating unrepresented EU citizens’ right to equal 
treatment on consular protection in the area of emergency travel documents;  
To  improve  security  within  the  EU  and  its  borders  by  improving  the  security  of  the 
emergency travel document itself as well as the process through which it is granted.  

4.2 

Specific objectives 

The specific objectives of the action are: 

 

 

 

 

To  increase  legal  certainty  by  making  the  EU  ETD  legislation  enforceable  and  by 
aligning  it  with  the  current  acquis  on  citizenship  rights  (including  the  Consular 
Protection Directive);  
To  enhance  document  security  and  reduce  the  risk  of  document  fraud,  in  line  with 
trends and existing policies on improving document security29; 
To simplify the conditions and formalities for issuing the EU ETD, for both citizens 
and consular staff, and to improve coordination and cooperation measures between the 
Member States; 
To  improve  acceptance  of  EU  ETDs,  thus  minimising  the  risk  of  citizens  being 
refused exit from third countries or denied entry in the European Union and allowing 
them to continue travelling to their destination. 

29  

COM (2016) 790 final. 

15 

 
 
 
 
                                                           
5. WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1  What is the baseline from which options are assessed? 

The  baseline  was  described  in  the  evaluation  report.  In  a  nutshell,  the  evaluation  report 
revealed  a  plethora  of  existing  approaches  for  providing  consular  assistance  in  the  shape  of 
ETDs  and  identified  that  this  had  led  to  a  number  of  problems  that  need  addressing  (as 
explained in Section 2). The figure below sets out the intervention logic, namely the problems 
with the existing Decision, their drivers, the objectives of further intervention and the options 
for achieving these objectives. 

5.2 

Description of the policy options  

Three principal policy options are considered: 

 

 

 

Policy Option 1: Status quo; 
Policy Option 2: New legislation – EU ETD with enhanced security 
features 
Policy Option 3: New legislation – EU ETD with biometric chip 

The  policy  options  chiefly  differ  in  terms  of  the  security  features  proposed.  This 
emphasis has two reasons: Increased security is an express request of the Member States 
and  has  been  highlighted  by  the  Commission  in  its  Action  plan  to  strengthen  the 
European  response  to  travel  document  fraud.  The  Council  and  European  Parliament, 
when  calling  on  the  Commission  to  present  a  legal  initiative  on  ETDs,  placed  primary 
importance  on  increasing  the  document’s  security  features.  As  part  of  the  consultations 
for  the  Impact  Assessment,  Member  States  have  emphasised  the  security  dimension. 
Secondly,  the  need  to  properly  align  any  measure  adopted  with  the  existing  legal 
framework  of  the  Consular  Protection  Directive  limits  the  policy  options  available  in 
order to ensure consistency and legal certainty for Member States and citizens. 

The options are described in further detail below.  

Policy Option 1: Status quo  

The first policy option constitutes a baseline scenario and does not involve new actions. 
The EU ETD Decision would remain in force in the same way as it is now. This Option is 
thus only presented as a benchmark.  

The problems identified in Section 2 would continue to exist and, as discussed in Section 
3, could  be expected to  increase over time, leading to  increased fragmentation amongst 
EU Member States, security issues and legal uncertainty. 

16 

 
 
 
 
 
Figure 5-1: Intervention logic of Options (ETDs) 

17 

 
 
 
 
 
 
 
 
 
 
Policy Option 2: New legislation - EU ETD with enhanced security features 

 This Option would provide for the EU ETD Decision to be repealed and a new Directive to 
be adopted. Under this new Directive: 

 

 

 
 

 

 

 

 

The use of the harmonised EU ETD format is compulsory for unrepresented citizens 
outside the EU. The use of the EU ETD inside the EU or  for represented citizens is 
allowed and the Member States can make use of this facility; 
The new Directive will complement the Consular Protection Directive, aligning their 
content in all relevant aspects; 
The new format will have improved security features (described below) 
There  will  improvements  to  the  security  of  the  issuing  process,  including  rules 
concerning  how  to  dispose  of  the  document  once  its  holder  has  reached  their 
destination; 
A  comitology  procedure,  aligned  with  existing  ones,  will  be  established  to  specify 
necessary further technical specifications for the uniform format for EU ETDs; 
Pricing  will  be  aligned  with  the  fees  charged  by  Member  States’  to  their  own 
nationals; 
The validity of the EU ETD will be harmonised; it will be issued for a single journey 
which would not exceed 15 days (unless special circumstances would warrant longer 
validity). 
Soft measures to assist the implementation would be discussed and addressed as part 
of  the  existing  Commission  Expert  Group  on  the  right  of  unrepresented  citizens  to 
consular protection abroad (based on Article 23 TFEU and Directive 2015/637/EC). 

Legal aspects  

The  use  of  the  EU  ETD  would  be  made  compulsory  for  unrepresented  citizens  outside  the 
EU.  Member  States  would  be  obliged  to  issue  an  EU  ETD  following  a  request  from  an 
unrepresented citizen that fulfils the legal conditions30. This would end the currently observed 
fragmentation  among  EU  Member  States  in  the  provision  of  the  EU  emergency  travel 
document and thus contribute to increased acceptance of the document.  

At the same time, the new Directive would leave open the possibility for  Member States to 
decide  to  use  the  EU  ETD  also  for  their  own  citizens  or  to  issue  it  inside  the  EU  (to  both 
represented  and  unrepresented  citizens).  The  Directive  would  also  make  it  possible  for 
Member  States  to  issue  EU  ETDs  to  accompanying  family  members  of  unrepresented 
citizens, who are not themselves citizens of the Union, in accordance with the principles set 
out in the Consular Protection Directive. Whilst the Consular Protection Directive recognises 
that Member States might not be in a position to deliver emergency travel documents to third-

30  

See the conditions provided for in the Consular Protection Directive. 

18 

 
 
 
                                                           
country family members, Member States could be encouraged to do so in order to allow the 
EU citizen to benefit fully from his or her right to equal treatment on consular protection. 

In order to address observed issues of legal certainty, the new Directive would also align in 
all relevant  aspects  with the Consular Protection Directive.  In particular, this would include 
the  concepts  of  absence  of  representation  and  the  process  of  confirming  the  applicant’s 
nationality. Furthermore, it would codify present practice to include situations when passports 
have expired and cases of new-born babies. 

The Treaty principle of non-discrimination would also apply for pricing (as discussed below 
under  Pricing),  and  specific  provisions  would  regulate  the  cooperation  between  Member 
States, which would be obliged to communicate directly and act without delay when issuing 
the document (as discussed below under Cooperation and Coordination).  

The new legal instrument would equally provide for a specific role for the European External 
Action  Service  in  providing  specimens  of  the  document  to  third  countries  authorities  and 
promoting  its  acceptance.  Another  way  to  achieve  this  is  through  consular  clauses  in  EU 
cooperation  agreements  with  third  countries.  These  clauses  guarantee  that  third  countries 
recognise  the  rights  of  unrepresented  EU  citizens  to  consular  protection  by  other  Member 
States.  

The  new  legal  instrument  would  be  enforceable  and  the  Commission  would  be  able  to 
perform its role of monitoring and instigating an action against Member States for breaching 
the  rules  if  necessary.  The  Court  of  Justice  would  have  full  jurisdiction  on  the  specific 
provisions of the Directive. 

Security aspects 

Under Option 2, the security features of the EU ETD would be improved in order to address 
issues  of  acceptance  as  well  as  security  and  border  management  concerns.  These 
improvements  would  address  the  emphasis  on  greater  security  features  expressed  by  the 
Council  and  the  European  Parliament.  In  particular,  enhanced  security  is  meant  to  address 
concerns raised by some Member States concerning the current system. 

The security features proposed under Option 2 are modelled on the response of the Member 
States  to  the  survey  and  interviews  conducted  in  the  preparatory  work  for  the  Impact 
Assessment31. Table 5-2 summarises the security features proposed for this Option. 

31  

See Evaluation report, section 5, for further information. 

19 

 
 
 
                                                           
Table 5-2:  Options for EU ETD and different elements 

Element 

Comments 

Although  originally  A4  was  considered, 
this  raised  the  issue  of  proper  handling 
against normal wear and tear.  A5 format 
would  allow  for  the  document  to  be 
folded  and  carried  in  a  pocket.  Inclusion 
of  a  blank  page  would  allow  for  a 
national visa of a country in transit to be 
affixed,  as  the  evaluation  demonstrated 
this  need  (not  the  least  in  relation  to 
transit through the USA)  

It  is  recommended  to  digitally  sign  the 
ETD document. 

The  information  on  the  sticker  would 
include: 

- Issuing Member State 

- Member State of nationality of the 
citizen 

- Surname/Name 

- Date and place of Birth 

- Date of expiry 

- Date of issue 

- Registration number (equal to the 
number on the EU ETD format) 

Format 

A5, with a blank page for visas.  

Security elements 

Physical 

ETD form – The A5 ETD form 
is the carrier for the ETD sticker 
described below. This form shall 
be  made  of  a  security  substrate 
stiff enough for holding the ETD 
include 
and 
sticker 
watermark(s)/  UV  fluorescent 
fibres and reagents. The printing 
different 
combine 
should 
security printing techniques such 
as intaglio and offset, and should 
include  guilloche  patterns,  anti-
scanner  background  and  micro 
lettering.  Furthermore,  it  should 
like  UV 
use  security 
fluorescent. The ETD form shall 
be  pre  numbered 
including 
linking it to the ETD sticker. 

inks, 

ETD sticker – The ETD sticker 
will  be  affixed  onto  the  ETD 
sticker  will  be 
form.  This 
modelled  upon  the  new  uniform 
shall 
for  visas  and 
format 
security 
equivalent 
contain 
features.  It  will  consist  of  the 
visual  identification  zone  (eye 
readable)  containing  the  photo 
and  other  personal  data  of  the 

20 

 
 
 
 
 
Electronic 

bearer (see column to the right), 
and  the  machine-readable  zone 
at  the  bottom  for  automated 
reading of the biographic data. 

dimensional 

barcode, 
Two 
which 
contain 
would 
biographical and other data from 
the  sticker.  A  16x16mm2  2D 
barcode 
large 
is  considered 
enough  for  data  and  signature. 
This  digital  ‘seal’  would  be 
similar  to  the  one  left  optional 
for  the  new  uniform  format  for 
visas32. 

a 

under 

requires  a  certain 

infrastructure 
It 
operational 
controlled 
environment33. Not all EU consulates are 
equipped  with  such  infrastructure,  which 
is  the  reason  it  is  still  not  used  for  the 
new  uniform  format  for  visas.  However, 
once the infrastructure becomes available 
for  issuing  the  new  uniform  format  for 
visas,  its  use  would  be  easily  extended 
for the ETD stickers. 

Personalization/ Data entry 

Printing 
technique 

sticker  will  be 
The  ETD 
personalized 
the  consulate 
in 
using the same printers as for the 
uniform format for visas. 

EU consulates are equipped with printers 
for issuing the uniform format for visas. 

Photo 

Photos  should  be  taken  live  at 
the  consulates  and  printed  onto 
the  sticker.  Only  in  exceptional 
circumstances  (natural/  massive 
disasters;  system  breakdown) 
should photos be handed over by 
the bearer.  

in/by 

It  is  highly  recommended  to  take  live-
the  consulates.  Many 
photos 
consulates  are  equipped  with  digital 
cameras and this would increase security 
the 
the  document  and  simplify 
of 
formalities for the citizen.  

32   

33  

Annex to Regulation (EU) 2017/1370 of 4 July 2017 amending Council Regulation (EC) No 1683/95 
laying down a uniform format for visas set out the format. Available at:  http://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32017R1370&from=EN  
In  order  to  compute  the  signature,  the  consulate  or  embassy  would  connect  to  a  Public  Key 
Infrastructure (PKI) signing authority, which is a system that holds the key to compute the signature and 
publish  the  certificate.  An  internet  connection  would  therefore  need  to  be  available  to  issue  the 
document  with  the  digital  signature.  The  PKI  required  would  be  similar  to  the  one  currently  used  to 
issue ePassports and the one proposed for the Visa Schengen. 

21 

 
 
 
 
 
                                                           
The proposed new security features represent an improvement on the current format and can 
be delivered using the existing equipment already available in the Member States consulates 
(tasked  with  issuing  visas  to  third-country  nationals34).  A  notable  improvement  is  the 
introduction of an ETD sticker, modelled on the existing uniform format for visas. The ETD 
sticker  would  be  affixed  onto  the  ETD  document  instead  of  entering  the  personal  data  by 
printer and attaching a photo separately, as it is currently done. The ETD sticker would have 
the  same  format  and  equivalent  security  features  as  the  uniform  format  for  visas.  It  would 
include a printed photo  of the person, their biographic data  and a machine-readable zone at 
the bottom with the same biographic data.  

There are several advantages to such an approach. Firstly, using equivalent security features 
to the ones in the uniform format for visas would greatly increase reliability and security of 
the ETD. Secondly, the machine readability  would facilitate the checking  and processing of 
the document at the border. Thirdly, the handling of the ETD sticker would be easier for the 
consular staff that is already trained and familiar with the uniform format for visas.  

The  new  EU  ETD  sticker  would  leave  empty  space  for  the  likely  future  inclusion  of  a 
common  2D  barcode,  which  would  provide  additional  security  to  the  document.  The  2D 
barcode has not been made compulsory in the new uniform format for visas, but similarly an 
empty  space  was  left  for  its  possible  inclusion  in  the  future.  Given  that  the  number  of  EU 
ETDs issued annually is much smaller than the number of issued uniform format visas, there 
is no business case for introducing the system only for EU ETDs. However, as the consulates 
become progressively better equipped with  technology  capable of delivering this feature for 
visas, the 2D barcodes could easily be added to the EU ETDs. 

The new EU ETD format would also include a blank page for a national visa of a country in 
transit to be affixed, as the stakeholder consultation demonstrated this need (not the least in 
relation to transit through the USA). 

In order to increase security and speed of the issuing process, the photo of the citizen would 
be taken live at the consulate by digital camera or equivalent means. The same photo should 
be  transmitted  to  the  Member  State  of  nationality  for  the  confirmation  of  the  citizen's 
nationality35. Furthermore, the communication would the place directly between the assisting 
Member State and the Member state of nationality, securing and authenticating the exchanged 
information. 

Finally, there will be rules concerning how to dispose of the document once its holder has 
reached their destination (for example by obliging the holder to return it when applying for a 

34  

35  

Article  4  of  the  Visa  Code,  consolidated  version  available  at:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:02009R0810-20160412  
The  use  and  transmission  of  the  photograph  is  justified  in  this  case  as  the  person  in  question  has  no 
other available identity document (e.g., passport or ID card) to confirm their identity. The Member State 
of  nationality,  as  is  standard  practice,  uses  the  photo  of  the  person  as  one  of  the  key  elements  in 
confirming  the  citizen's  identity.  Transmission  of  the  photograph  must  be  done  through  formal  and 
secure channels and in full respect of EU and national data protection rules.   

22 

 
                                                           
regular  passport).  Proper  disposal  of  the  expired  EU  ETD  is  important  to  increase  overall 
security of the document.  

A comitology procedure, aligned with existing ones, especially the one on the visa sticker36, 
will be established to specify necessary further technical specifications for the uniform format 
for EU ETDs including enhanced anti-forgery, counterfeiting and falsification standards and 
technical standards and methods to be used for the filling in of the EU ETDs and its colours. 
For  security  reasons,  it  will  be  possible  to  keep  these  further  technical  specifications  secret 
and not to publish them. This Committee will rely on the expertise of Member States experts 
of the so-called "Article 6 Committee" in charge of technical specifications applicable to visa 
stickers. The comitology procedure will thus allow for the EU ETD document to benefit from 
other developments in increased security of other types of travel documents. 

Cooperation and coordination 

Under Option 2, and in order to ensure legal consistency, the new instrument would mainly 
rely  on  mechanisms  established  by  the  Consular  Protection  Directive  (Chapter  2)  while 
providing additional specifications where necessary. This would entail: 

 

 

 

cooperation  and  coordination  between  Member  States  using  the  Consular  On  Line 
(CoOL) website; 
local cooperation meetings; and 
crisis preparedness and cooperation. 

Citizens  would  no  longer  be  obliged  to  transmit  any  documents  to  their  Member  State  of 
nationality, but it would be up to the two Member States working on the case to communicate 
directly  among  themselves  and  transmit  any  needed  documents  electronically  through  the 
Consular On Line (CoOL) website or other formal channels. 

The  option  would  also  impose  some  deadlines  in  terms  of  exchanges  between  the  Member 
States,  specifying  the  requirement  of  the  Consular  Protection  Directive  that  communication 
between Member States concerning consular assistance for unrepresented citizens should take 
place "without delay".  

The deadlines would be: 

  Notification: the assisting Member State shall inform the Member State of nationality 
of the case of their unrepresented citizen asking for an EU ETD within 24 hours; 
  Confirmation:  36h  for  the  Member  State  of  nationality  to  confirm  the  unrepresented 

citizen’s nationality; 

  Next day issuance: the assisting Member State shall provide the unrepresented citizen 
with EU ETD at the latest the next working day following receipt of the confirmation. 

36  

Article 6 of Council Regulation (EC) No 1683/95 of 29 May 1995 laying down a uniform format for 
visas. 

23 

 
 
                                                           
The provision on deadlines would allow for exceptions in cases where longer periods for the 
treatment of the application can be justified on objective grounds. 

Pricing  

The cost of the EU ETD for the citizen would be aligned with the Treaty's principle of non-
discrimination and the Consular Protection Directive. The Directive does not harmonise the 
price  of  consular  assistance  provided  to  the  citizens,  but  stipulates  that  the  unrepresented 
citizens cannot be charged more than own nationals. Similarly, under the new legal instrument 
governing  EU  ETD,  the  Member  States  could  not  charge  more  for  an  EU  ETD  than  they 
charge to their own citizens for national ETD. 

In  cases  where  the  citizen  does  not  have  the  financial  means  to  cover  the  issuance  fee,  the 
reimbursement  procedure  from  the  Consular  Protection  Directive  would  apply.  The  citizen 
would undertake to repay the fee to their Member State of nationality, which would reimburse 
the fee to the assisting Member State. 

Validity 

Concerning period of validity, the evaluation report revealed different practices. According to 
Annex II of the Decision, EU ETDs should be made valid for barely longer than the minimum 
period required for completion of the journey for which the ETD has been issued. The study 
survey  asked  Member  States  authorities  about  the  duration  of  the  ETD,  in  days.  Although 
most Member States agree that it should not exceed 30 days, current Member States' practices 
vary on setting the validity period of the EU ETD.   

ICAO  Guidance  on  Emergency  Travel  Documents37  notes  that  issuing  Authorities  should 
restrict  validity  to  the  minimum  period  required  consistent  with  the  purpose  for  which  the 
document was issued and in line with the security of the document.  

Under Option 2, an EU ETD would be valid for a single return journey, depending on travel 
arrangements  in  place,  usually  not  exceeding  15  days.    In  exceptional  circumstances,  a 
Member State should be able to consider extending the validity to cover travel arrangements 
for the entire return journey.  

Policy Option 3: New legislation - EU ETD with biometric chip 

This Option would provide for the EU ETD Decision to be repealed and a new Directive to be 
adopted. Under this new legal instrument governing EU ETDs: 

 

37  

The use of the harmonised EU ETD format is compulsory for  unrepresented citizens 
outside the EU. The use of the EU ETD inside the EU or  for represented citizens is 
allowed and  the Member States can make use of this facility; 

Available at: 
https://www.icao.int/Security/mrtd/Downloads/Guidance%20Material/Guidance%20on%20Emergency
%20Travel%20Documents%20May%202016%20final.pdf 

24 

 
                                                           
 

 

 

 

 

 

 

The new Directive will complement the Consular Protection Directive, aligning their 
content in all relevant aspects; 
The new format will have new improved security features – biometric chip (described 
below);  
There  will  improvements  to  the  security  of  the  issuing  process,  including  rules 
concerning  how  to  dispose  of  the  document  once  its  holder  has  reached  their 
destination; 
A comitology procedure, aligned with existing ones (visa stickers, passports etc.) will 
be  established  to  specify  necessary  further  technical  specifications  for  the  uniform 
format for EU ETDs; 
Pricing  will  be  in  line  with  the  non-discrimination  clause  of  Consular  Protection 
Directive (i.e. the EU ETD cannot cost more than similar national document issued to 
an own national).; 
The validity of the EU ETD will be harmonised; it will be issued for duration of up to 
12 months, allowing for continuation of onward journey;  
Soft measures to assist the implementation would be discussed and addressed as part 
of  the  existing  Commission  Expert  Group  on  the  right  of  unrepresented  citizens  to 
consular protection abroad (based on Article 23 TFEU and Directive 2015/637/EC). 

Legal aspects and coordination and cooperation measures would be the same as under Option 
2. 

Security aspects 

This option differs primarily in introducing the highest possible level of security – biometric 
chip – in the EU ETDs. Biometrics are currently used in some travel documents, for instance 
in all Member States passports, some national identity cards38 and also in the European Union 
laissez-passer.   

Biometric  documents  have  an  embedded  electronic  microprocessor  chip  which  contains 
biometric  information  that  can  be  used  to  authenticate  the  identity  of  the  holder.  It  uses 
contactless  technology,  including  a  microprocessor  chip  (computer  chip)  and  antenna  (for 
both  power  to  the  chip  and  communication).  Public  key  infrastructure  (PKI)  is  used  to 
authenticate  the  data  stored  electronically  in  the  passport  chip,  making  it  expensive  and 
difficult to forge when all security mechanisms are fully and correctly implemented. 

Because  of  the  technical  requirement,  a  biometric  EU  ETD  would  have  to  be  issued  in  a 
booklet format rather than the current the single-sheet A4 paper. Other security features of the 

38  

E.g. Belgium, Croatia, Czech Republic, Estonia, Finland, Portugal, the Netherland, Slovenia, Spain and 
Sweden. 

25 

 
  
                                                           
booklet would correspond to  those of Member States passports,  as described in  the Council 
Regulation (EC) No 2252/200439. 

To  specify  necessary  technical  specifications,  a  comitology  procedure  similar  to  the  one 
outlined for Option 2 would be established. 

Pricing 

The  pricing  would  be  in  line  with  the  non-discrimination  clause  of  the  Consular  Protection 
Directive (i.e. the EU ETD cannot cost more than similar national document issued to an own 
national). In view of the biometric features proposed under this Option, this would correspond 
to the costs for documents with similar biometric features. 

The same similar reimbursement system as outlined under Option 2 would be established. 

Validity 

ICAO Guidance40 notes that issuing authorities should restrict validity of a document to the 
minimum period required consistent with the purpose for which it was issued and in line with 
the  security  of  the  document.  Taking  into  account  this  Guidance,  ETDs  in  booklet  form 
should be issued with an absolute maximum validity of 12 months (including any six months 
entry  and  visa  requirements)41,  whereas  a  single  sheet  ETDs  should  be  issued  with  a  single 
journey restriction (which can include transit points).  

Under  this  Option,  the  validity  of  the  EU  ETD  would  be  harmonised;  it  would,  taking  into 
account its similarity to the security measures contained in passports, be issued for a duration 
up to 12 months, allowing for continuation of onward journey.     

5.3  Options discarded at an early stage 

5.3.1  Soft measures: non legislative measures related to EU ETDs 

Consideration  was  given  to  the  option  of  introducing  soft  measures  only,  such  as  best 
practices and guidelines prepared in close cooperation with Member States experts, including 
in the framework of the Commission's expert group in charge of consular protection. 

Although  soft  measures  could  help  with  some  practical  aspects  of  implementation  (for 
example  by  clarifying  the  use  of  certain  tools  for  communication  or  awareness  raising 
measures), they could not address the main identified problems: 

  The  security  format,  related  to  the  problems  of  fragmentation  and  reduced 
acceptance,  can only be changed by an update of the Decision and not  through soft 
measures; 

39  

40  

41  

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 (OJ L 385, 29.12.2004, p. 1–6). 
Available at: 
https://www.icao.int/Security/mrtd/Downloads/Guidance%20Material/Guidance%20on%20Emergency
%20Travel%20Documents%20May%202016%20final.pdf 
In order to discourage the user from applying for an ETD rather than a standard, full validity passport. 

26 

 
                                                           
  Legal uncertainty cannot be eliminated through soft measures, as the Decision cannot 
be adapted to the Consular Protection Directive, made enforceable or legally binding 
in this way. 

Therefore, this option does not appear sufficient to meet the objectives. 

However, where possible, soft measures should be put in place to assist the implementation of 
the preferred option with a view to  supporting the smooth  implementation of the applicable 
legal text. In particular, awareness-raising activities should be conducted to inform citizens of 
the EU ETD and their entitlement to obtain one under certain conditions. 

These and other soft measures would be discussed with Member States' experts, including in 
the  framework  of  the  existing  Commission  Expert  Group  on  the  right  of  unrepresented 
citizens to consular protection abroad42. 

5.3.2  Revoking the EU ETD Decision 

An option that should be considered is the possibility for the EU ETD Decision to be revoked.  
This  option  would  effectively  see  EU  ETDs  disappear  and  replaced  entirely  by  national 
ETDs. 

The  institutions  and  main  stakeholders  (Council,  European  Parliament,  Member  States  and 
citizens)  have  expressed  the  desire  to  retain  and  improve  the  common  EU  ETD  format. 
During  consultations,  no  Member  State  stated  that  it  would  like  the  common  format  to  be 
abolished and to return to the exclusive use of national ETDs. The vast majority of Member 
States  are  using  the  EU  ETDs,  and  many  of  them  also  inside  the  EU.  One  Member  State 
(Italy) uses it also for its own citizens. Revoking the common EU ETD is likely to  increase 
fragmentation and increase the risk of form shopping (citizens would seek assistance from 
the Member State offering the cheapest and/or easiest to obtain national ETD). It would add 
difficulties for citizens travelling abroad as third country authorities and EU border authorities 
would  be  faced  with  increased  complexity.  Additional  training  would  be  necessary  to 
familiarise border  guards with  the different  national  ETDs.  Furthermore,  increased diversity 
of  national  ETDs  would  limit  the  possibility  of  saving  due  to  economies  of  scale  (joint 
training, printing of forms, etc.) 

At the same time, when seeking an emergency travel document, unrepresented citizens could 
face  a  vast  array  of  different  national  documents,  procedures  and  deadlines.  This  approach 
would make enforcement of citizens' Treaty rights difficult and would not ensure consistency 
with the Consular Protection Directive. 

42  

The Expert Group on the right of unrepresented citizens to consular protection abroad (Article 23 TFEU 
and Directive 2015/637/EC) aims at  monitoring the development of national policies and enforcement 
of Directive 2015/637 on the coordination and cooperation measures to facilitate consular protection for 
unrepresented citizens of the  Union in third countries by national authorities. It also aims to improve 
coordination  with  Member  States  and 
to  promote  exchange  of  views  and  best  practices 
(http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3355). 

27 

 
                                                           
Furthermore, the EU ETD is accepted as one of the key visible demonstrations of the practical 
benefit  of  EU  citizenship  and  in  particular  of  the  unrepresented  EU  citizens'  right  to  equal 
treatment on consular protection. From the citizens' perspective, the EU ETD with its name, 
design  and  multilingualism  represents  a  travel  document  that  clearly  identifies  them  as 
European citizens and assists them in third countries pursuant to their EU citizenship right43.  

With  national  ETDs,  this  link  is  not  clearly  established.  The  evaluation  conducted  for  this 
study  has  shown  that  problems  do  occur  for  unrepresented  citizens  when  travelling  on 
national ETDs (see box below), precisely due to the confusion that a national document issued 
for  a  citizen  of  different  nationality  may  create  for  border  authorities  and  other  concerned 
entities. 

Problems described above are likely to increase would the EU ETD be abolished. As reported 
by some Member States, using several  different  documents creates  confusion,  and if a non-
national travels with a national ETD, this may even create suspicion regarding the authenticity 
of the document. As a result of this confusion, some citizens were asked by third countries to 
travel to the Member State of their nationality, rather than to other EU destinations. Pursuing 
this  Option  could  thus  pose  particular  problems  to  EU  citizens  residing  in  another  Member 
State.  

Box 5-3: Problems encountered by citizens when travelling on a national ETD 

Having lost my passport in Thailand, and being a Spanish person residing fully in the UK 
was  very  complex  as  my  consulate  could  only  give  me  a  'Salvoconducto'.    This  is  a 
document that enabled me to travel back to Spain but the UK authorities would not accept 
even though I have lived there for 28 years.  Those type of inconsistencies and difficulties 
should really be removed. (Report by a citizen) 

Travelling on a French laissez-passer as a Polish citizen I was refused entry into China and 
Korea. I was kept in airport in China for 10 hours and airline company refused to accept 
my ticket. (Report by a citizen) 

There are other practical and financial reasons for not favouring this option. Should EU ETDs 
disappear, Member States that currently do not have single journey national ETDs, but issue 
their citizens instead with emergency passports, would have to create new national formats 
to  replace  the  EU  ETD  in  order  to  comply  with  the  legal  obligation  to  offer  consular 
protection to unrepresented EU citizens. The same is true for the one Member State that only 
uses  the  EU  ETD  format.  Other  Member  States  that  do  have  national  single  journey  ETDs 
would have to amend their formats to account for other nationalities. 

43  

Even though only few responses to the open public consultation have been received, they showed that 
the  EU  ETD  is  viewed  very  positively.  84%  of  the  respondents  believed  that  the  EU  ETD  provides 
genuine  help  to  EU  citizens  in  distress.  71%  of  the  respondents  with  an  opinion  felt  that  countries 
should always issue EU ETDs rather than national ETDs.  19% felt that it would be for the country to 
decide which ETD it wants to issue to citizens.  

28 

 
 
                                                           
 
Apart from raising issues of acceptance and recognisability by third countries and EU border 
guards, the cost of such national interventions (costs to introduce or adapt national ETDs in 
addition to the costs of non-harmonised issuing procedure) would thus also greatly outweigh 
the cost of modernisation of EU ETD. 

For the reasons stated above, this Option was discarded. 

5.3.3  Compulsory EU ETD for all citizens  

An option that should also be considered is the possibility for the new EU ETD to be made 
compulsory  for  Member  States'  own  nationals,  represented  and  unrepresented  citizens,  both 
inside  and  outside  the  EU.  This  option  would  effectively  see  national  ETDs  disappear  and 
replaced entirely by EU ETDs. 

This  Impact  Assessment  reflects  the  request  of  the  Council  to  the  Commission  to  make 
a proposal for the production of a new European Emergency Travel Document that contains 
security  features  in  line  with  current  practices,  updating  the  features  described  in  EU  ETD 
Decision. This Decision is based on the right to equal treatment on consular protection, which 
is  only  enjoyed  by  unrepresented  EU  citizens  in  third  countries.  Likewise,  the  Consular 
Protection  Directive,  which  sets  out  the  general  framework  for  the  provision  of  consular 
protection,  concerns  consular  protection  for  such  citizens.  Making  EU  ETDs  mandatory  for 
all  citizens  would  be  beyond  the  scope  of  EU  citizenship  rights  and  would  thus  have  to  be 
considered under a separate legal basis. 

As the study for this impact assessment has shown, Member States issue to their own citizens 
a  broad  range  of  national  ETDs,  which  vary  in  their  formats,  level  of  security  features, 
duration and price. Some Member States issue their citizens with temporary passports, which 
bring added value in terms of possibility to continue onward journey to third countries. 

However,  not  all  Member  States  consulates  or  other  national  agencies  have  the  necessary 
equipment and technology to allow such best practices to be implemented. Any harmonisation 
of  national  ETDs  to  a  common  EU  format  would  therefore  either  impose  a  significant 
financial burden on some Member States to meet the highest standard or would, on the other 
hand, reduce the standard provided by some Member States to their own citizens.  

For these reasons,  this Option  was not  considered appropriate and was  discarded. However, 
both Options 2 and 3 envisage that the use of EU ETD is left optional to Member States for 
their own citizens or inside the EU. 

29 

 
 
 
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The main criteria to assess the different policy options include:  

 

 

 

the effectiveness of the options in meeting the objectives, as defined in Sections 4.1 
and 4.2 (see also Figure 5-1);  

the social impacts and impacts on fundamental rights, namely the impacts on the 
right  to  equal  treatment  on  consular  protection  abroad  by  unrepresented  citizens  (in 
line with the Treaty and the provisions of the Consular Protection Directive);  

financial  and  economic  impacts  from  the  different  options,  in  particular  for 
Member  States  competent  authorities,  citizens  and,  potentially,  other  stakeholders 
such  as  travel  operators,  aircraft  carriers  and  other  businesses  (employers  and 
insurance companies).  

No direct environmental impacts are envisaged from the options44.  As a result, these are not 
considered further. 

6.1 

Impacts from Policy Option 1 

Inaction will result in the persistence and likely increase of the current problems, described in 
Section 2, as the underlying drivers will remain unaffected or become stronger. The EU ETD 
will not be as effective in providing genuine help to citizens in distress as it could be and will 
not fulfil the aim of demonstrating the practical benefits of being a citizen of the Union. 

6.2 

Impacts from Policy Option 2 

The  main  stakeholders  impacted  by  Option  2  can  be  broadly  divided  into  Member  States' 
authorities, citizens and other stakeholders.  

The  impacts  are  examined  in  greater  detail  below.  The  summary  of  impacts  presents  the 
assessment of Option 2 against the objectives identified earlier in Section 4.  

6.2.1 

Impacts on Member States' authorities  

Option  2  introduces  a  new  and  significant  improvement  in  security  features  responding  to 
concerns voiced by the Member States, but it does so at a relatively small increase in the cost 
to Member States. The modelling of the EU ETD sticker on the existing uniform format for 
visas re-purposes this already widely used tool in EU consulates to strengthen the security of 
the EU ETD. This represents a considerable saving as opposed to solutions requiring purchase 
of new equipment 

A  new  legislative  instrument  governing  EU  ETDs  adapted  to  the  Consular  Protection 
Directive  would  provide  Member  States  with  increased  legal  certainty.  Similarly,  it  would 

44  

Although,  arguably,  there  could  be  indirect  environmental  impacts  if,  for  example,  travellers  have  to 
take a different route home. However, these impacts are highly uncertain and difficult to model. 

30 

 
                                                           
clarify the coordination and cooperation measures used and deadlines for both  assisting and 
issuing Member State.  

Option 2 would explicitly allow for EU ETD to be used optionally by Member States for their 
own  citizens  and  within the  EU,  as  is  the  case  already  in  practice.  A  more  secure  EU  ETD 
format,  which  is  multilingual  and  produced  at  EU-level,  can  thus  also  represent  a  cost-
efficient alternative to Member States considering replacing any outdated national ETDs.  

6.2.1.1  

Administrative costs 

Under  this  option,  the  administrative  costs  involved  in  processing  applications  for  EU  ETD 
and verifying the applicant’s nationality are expected to either stay the same as compared to 
the  status  quo  or  to  be  reduced  due  to  the  harmonisation  and  streamlining  of  the 
administrative procedures governing EU ETDs, including the consultations between Member 
States. 

The  impact  on  the  individual  Member  State  will  largely  depend  on  that  Member  State’s 
consular network. Generally, while the processing costs for better represented Member States 
will  be  higher,  the  costs  for  verifying  an  applicant’s  nationality  will  be  smaller  as  the 
nationals of these Member States are more likely to be represented in a third country by their 
Member State. The same is true in reverse for Member States with smaller consular networks, 
which  will  have  higher  identification  and  smaller  processing  costs.  Furthermore,  given  the 
broad consular network of the UK, the burden on other Member State consulates (in particular 
of those Member States with a similarly broad network) is likely to increase in response to the 
UK's withdrawal from the European Union.  

The deadlines provided for under Option 2 derive from best practices reported by the Member 
States. Given the infrequent need for EU ETDs and their distribution across a wide network of 
countries  and  Member  State  consulates,  it  is  considered  that  their  impact  on  any  particular 
Member State consulate will be minor.  

Finally,  Member  States  would  be  entitled  to  have  their  costs  reimbursed  by  the  citizens 
requesting an EU ETD in a non-discriminative manner and in line with the provisions of the 
Consular Protection Directive. It can thus be expected that some of the arising costs will be 
passed on to the citizens benefiting from the service. 

6.2.1.2  

Transposition costs 

An implementation of the new legal instrument will not cause significant transposition costs 
for Member States. The main change would be the update of the format and alignment with 
the  Consular  Protection  Directive.  Transposition  costs  may  vary  slightly  depending  on 
whether the Member States decide to issue a new piece of legislation or amend the existing 
legislation.  

31 

 
According to a study conducted in 2009, 14 Member States (AT, BE, BG, CZ, DE, DK, EL, 
HU, LU, MT, PT, SE, SI and SK) have implemented the EU ETD Decision in their internal 
legal order while the remaining have not, assuming they could rely on its direct application45. 

In  addition,  some  Member  States  are  not  issuing  the  EU  ETD,  namely  the  UK,  France  and 
Germany. Costs will therefore be larger for these three countries than for those that already 
use the EU ETD, as some hassle costs may arise from having to make redundant their current 
framework for issuing national ETDs to unrepresented citizens. Nevertheless, these costs are 
not expected to be significant.  

There will be reporting  obligations as part of the new legal  instrument  governing EU ETD, 
but  these  could  be  timed  to  coincide  with  those  from  the  Consular  Protection  Directive, 
thereby minimising the associated costs46.  

6.2.1.3  

Training costs 

There  will  be  costs  related  to  training  consular  staff  to  complete  the  new  ETD  format. 
However,  the  training  needs  will  not  be  significant  as  consular  staff  are  already  trained  to 
issue  visas,  and  the  main  aspect  of  issuing  the  new  EU  ETD  under  this  option  will  be  the 
production of ETD sticker modelled on the visa system. 

A cheap and effective option to train staff on the new format may be the use of an e-learning 
tool.  E-learning  costs  less  than  more  traditional  methods  of  training.  Savings  stem  from  a 
variety  of  factors,  including  reduced  travel  and  accommodation  expenses,  but  also  ease  of 
adaptability and more targeted information.  

Illustrative costs for e-learning (eL) 

The cost to create e-learning can vary and depends on several factors, such as the content 
and the level of interactivity and instructional complexity. Expenses include the software 
applications used to create the online presence, establish management functions, create the 
courses, and enable their delivery. 

According to Tagoras, an hour of e-learning featuring moderate interactivity and limited 
animations requires anywhere from 90 to 240 hours to develop. If you were to assume an 
average hourly labour cost of €5247, a cost of €4,700 to €13,000 can be estimated. A mid-
estimate of €9,000 per produced hour for “moderate” level content can be assumed. 

Source: https://www.tagoras.com/cost-to-create-e-learning/ 

45  

46  

47  

European Institute of Law (2009): Member States’ Legislations and Practices in the field of Consular 
Protection.  
The Impact Assessment for the Consular Protection Directive proposed that the relevant report, coming 
after 3 to 5 years of the implementation of the Directive, should entail a specific study with emphasis on 
data collection and should examine how well cooperation and coordination arrangements are working. 
The set-up costs for the monitoring mechanism were estimated at €314,400. The same mechanism with 
minor adjustments could be used for reporting purposes of new EU ETD legislation. 
Conversion rate of $1=€0.81. 

32 

 
 
 
                                                           
Should Member States wish to conduct further training on the ETD in overseas countries, the 
costs  would  be  borne  by  the  Member  States.  The  survey  asked  Member  States'  competent 
authorities how long it currently takes them to train staff in the issuance of ETDs in a year. A 
realistic  range  was  from  1h  to  1  day  per  year,  with  an  average  of  half  a  day.  The  level  of 
training and costs will also depend on the level of representation by Member States. The costs 
given in  Table 6-2  are based  on the level  of  representation  and assume 1 hour to  a day  per 
year at  €182 daily rate. These costs exclude the  trainer’s fee and travel  and accommodation 
costs; in that sense they are an underestimate. On the other hand, this option may also entail 
cost  savings  by  combining  it  with  train-the-trainers  type  of  activities,  trainings  on  their 
national ETD and other consular activities (such as the visa system). However, as can be seen 
from the table, the costs would appear to be larger for those countries with a greater level of 
representation. 

Table 6-1:Costs of training from Option 2 based on the level of representation of 
Member States (2017 data as provided by EEAS) 

Notes 

Lower bound 
(€)  for group48 

Upper bound € 
for group48 

Level of 
represent
ation 

Member State 
(in ascending 
order) 

Low 

MT, EE, LU, 
LT, LV 

Low to 
moderate 

SL, CY, HR, 
IE 

Moderate 

SK, DK, FI, 
BG, PT, EL  

Representation in less 
than 20 countries 
(assumes 20 for 
calculation) 

Representation in over 
20 countries and 
below 40 (assumes 30 
for calculations) 

Representation in over 
40 countries (assumes 
50 for calculations) 

Moderate 
to high 

AT, HU, BE, 
PL, CZ, RO, 
SE, NL 

Representation in over 
60 countries (assumes 
75 for calculations) 

High 

ES, IT,  UK,  
DE, FR 

Representation in over 
90 countries (assumes 
160 for calculations) 

€ 2,000 

€ 18,000 

€ 3,000 

€ 22,000 

€ 7,000 

€ 55,000 

€ 14,000 

€ 109,000 

€ 19,000 

€ 146,000 

Total (rounded) 

€ 45,000 

€ 350,000 

48  

Obtained by multiplying 1 hr at €24/h by the number of Member States and countries where these are 
represented. Upper bound assumes 1 day at €182/day. Rounded to nearest €1,000. 

33 

 
                                                           
6.2.1.4  

Costs of new EU ETD  

The production cost of the new EU ETD will consist of the cost of the new blank form and the 
cost of the ETD sticker.  

The blank form would keep the same level of security features and would only see its design 
changed.  It is  estimated that this would not  change the current production cost of roughly 1 
euro per piece. 

With  regard  to  the  cost  of  the  ETD  sticker,  preliminary  investigation  with  several  mints  in 
charge of printing visa stickers revealed that a sticker with the same security features as that 
of  the  Schengen  visa  and  produced  in  low  quantities  (under  5000  annually)  would  cost 
roughly 7 euros net per piece. 

Assuming that about 1000 EU ETDs are issued each year49, the annual costs of the producing 
the EU ETD foreseen under Option 2 would thus be under €10,000 for all Member States. 

Several measures can be undertaken to further reduce the cost of production: 

 
 

Appoint through a tendering procedure a single mint for production of the stickers; 
Order  a  larger  initial  quantity  to  cover  longer  term  needs  of  all  Member  States 
consulates.  

Further economies of scale can be achieved if some Member States decide to adopt the use of 
the new format in lieu of national ETDs, as is currently the case with Italy. A more secure EU 
ETD  format,  which  is  multilingual  and  produced  at  EU-level,  can  represent  a  cost-efficient 
alternative to Member States whose national ETDs have outdated security features.   

6.2.2 

Impacts on citizens 

The  elements  considered  under  Option  2  are  expected  to  reduce  the  time  citizens  spend 
waiting to be issued an EU ETD, in particular due to improved coordination and cooperation 
procedures  between  the  Member  States  and  deadlines  applicable  to  the  exchange  of 
information and issuance of documents. 

Assuming each unpresented citizen saves, conservatively, a day in applying and receiving an 
EU ETD and that the opportunity costs of this is the average daily wage of €9350, the savings 
based on 1000 annual cases per year can be estimated at €93,000 across all citizens. 

49  

50  

The  annual  numbers  of  EU  ETDs  have  been  estimated  by  RPA  at  around  320  outside  the  EU  and 
another  250  within  the  EU.  It  is  estimated  that  another  400-500  unrepresented  citizens  are  issued 
annually national ETDs by the Member States currently not using the EU ETD. Under this Option, all 
Member States would be obliged to issue EU ETDs, which would result in the likely annual numbers 
around 1000. 
Average net daily wage in the EU 27, calculated as the average of 1/260 of the annual net earnings for a 
single  person  without  children.  Based  on  2015  Eurostat 
figures.  Statistics  available  at:  
http://ec.europa.eu/eurostat/statistics-explained/index.php/Wages_and_labour_costs#Net_earnings 

34 

 
 
                                                           
Due  to  the  improved  security  features  and  the  modernised  EU  ETD,  the  risk  for  citizens  to 
receive  sub-optimal  assistance  will  be  reduced.  Improving  security  features  as  well  as 
increased promotion of the document by the EEAS is expected to improve the acceptance of 
the EU ETD around the world (something that was considered to be “very important” by 19 
of the 25 Member States that responded to this question in the survey). Consequently, there 
will be reduced inconvenience when travelling on an EU ETD and a reduced risk of having to 
change travel itineraries and alter travel arrangements.  

Citizens  would  also  benefit  from  greater  legal  clarity  surrounding  notions  of  representation 
and  confirmation  of  nationality,  which  would  give  them  a  right  to  an  EU  ETD  in  more 
situations  than  under  the  current  EU  ETD  Decision.  The  same  applies  to  cases  of  expired 
passports and new-born babies, which would now be covered. 

Other  benefits  are  short  and  simple  deadlines  for  Member  States  processing  an  EU  ETD 
request. A citizen seeking an EU ETD would know by which date he or she could expect to be 
issued  the  document  and  could  plan  accordingly.  Citizens  would  also  profit  from  no  longer 
being required to themselves send the application to their Member State of nationality and to 
bring  a  photo  (in  cases  where  the  consulate  is  equipped  with  a  digital  camera).  These 
measures  would reduce the pressure on  citizens often already distressed  due to  the fact  that 
their travel documents were stolen or lost. 

It is important to note, however, that these benefits will accrue particularly to citizens of those 
Member  States  with  less  worldwide  representation,  namely  MT,  EE,  LY,  LT  and  LV. 
However,  nationals  of  other,  better  represented  Member  States  could  further  profit  from 
increased  acceptance  if  these  Member  States  opt  to  issue  EU  ETDs  also  to  their  own 
nationals. 

On  the  other  hand,  such  benefits  will  have  to  be  compared  with  the  additional  costs  of  a 
potentially  more  expensive  but  more  secure  EU  ETD.  However,  under  Option  2,  the 
manufacturing costs are not expected to rise significantly. 

Table 6-2:  Benefits to citizens based on the level of representation of Member States 
(2017 data as provided by EEAS) 

to 
from 

Benefits 
citizens 
improved 
ETD format 

Member 
ascending order) 

States 

(in 

Additional  notes  (out  of  a  total  195 
countries globally) 

High 

MT EE, LU, LT, LV 

Representation in less than 20 countries 

Moderate 
high  

to 

SL, CY, HR, IE 

Representation in over 20 countries.  

Moderate 

SK, DK, FI, BG, PT, EL  

Representation in over 40 countries.  

Low 
moderate 

to 

AT,  HU,  BE,  PL,  CZ,  RO, 
SE, NL 

Representation in over 60 countries.  

Low 

ES, IT,  UK,  DE, FR 

Representation in over 90 countries  

35 

 
In crisis situations, the EU ETD may be issued with the sticker  filled in by hand and at no 
charge. This is already the case today with the current format and is an accepted practice in 
crisis situations where the safety of the citizen is paramount. The variety of situations during 
crisis  and the unpredictability of their occurrence make it impossible to  quantify the impact 
accurately.  In  crisis  situations,  even  represented  citizens  may  become  unrepresented  if  their 
consulates are not in position to provide service. Therefore, estimating savings and benefits to 
citizens in crisis cases is necessarily more complex and is addressed qualitatively. However, 
one  would  expect  that  the  benefit  to  EU  citizens  from  obtaining  assistance,  or  obtaining  it 
quicker and more efficiently, could be substantially higher in crises than in everyday cases. 

6.2.3 

Impacts on other stakeholders  

Some benefits from an improved EU ETD are expected to accrue to businesses, as employees 
may be able to return to work more quickly if the EU ETD is more widely accepted and more 
quickly  issued.  With  respect  to  airline  carriers,  any  costs  related  to  denied  entry  of  citizens 
travelling on EU ETD at final destinations would diminish as a result of more widely accepted 
format.  

6.2.4 

Summary of impacts from Option 2 

The following Table summarises the main impacts from Option 2 relative to the objectives.  

Table 6-3:  Expected impacts from Option 2 

Effectiveness in 
attaining 
objectives 

1.  To  adapt  the  EU  ETD  legislation  to  the  Consular  Protection 
Directive  

A  new  legislative  instrument  governing  EU  ETDs  aligned  to  Consular 
Protection  Directive  will  bring  about  several  benefits.    The  new  legal 
instrument  will  be  enforceable  and  will  allow  the  Commission  to 
monitor  compliance  and  bring  forward  enforcement  measures  if 
necessary.    It  will  clarify  the  situation  with  regard  to  new-born  babies 
and  expired  passports,  currently  not  covered  by  EU  ETD  Decision.  
Similarly,  it  will  align  the  notions  of  absence  of  representation  and 
confirmation  of  nationality,  the  fees  charged  for  the  EU  ETD  and  the 
obligation for Member states to communicate directly and without delay 
with the Consular Protection Directive.  

2.  Simplify  the  conditions  and  formalities  for  issuing  EU  ETD  and 
improve the cooperation and coordination among Member States.  

Consular  staff  are  already  familiar  with  the  systems  and  equipment  for 
issuing  visas.  This  will  make  this  knowledge  easily  transferable  to  the 
new  ETD  sticker.  The  citizen  would  no  longer  be  obliged  to  send 
application  to  their  Member  State  of  nationality,  but  the  two  Member 
States  working  on  the  case  would  have  to  communicate  directly  and 
without delay, within proposed deadlines. Whenever possible, the photo 
of the citizen would be taken live at the consulate.  

3.  Improve  acceptance  of  EU  ETD.  The  new  security  features  will 

36 

 
alleviate  the  concerns  expressed  by  some  Member  States  currently  not 
issuing  the  document  and  therefore  contribute  to  ending  fragmentation 
amongst EU Member States in the application of the EU ETD. Improved 
security features, including adding a machine readable zone, will equally 
increase  acceptability  of  the  document  by  third  countries  and  facilitate 
its  processing  at  the  borders.  Adding  space  for  national  transit  visas 
would further facilitate travel through a number of countries requesting 
transit visa for ETDs (such as the USA). The greater role envisaged for 
the  European  External  Action  Service  in  providing  specimens  and 
facilitating  acceptance  of 
the  document  should  also  contribute 
favourably to this objective. 

4.  Enhanced  document  security  and  reduce  the  risk  of  document 
fraud.    The  new  proposed  EU  ETD  format  with  enhanced  security 
features  will  reduce  the  risk  of  document  fraud  and  contribute  to  the 
security of the EU borders.  

This  option  will  contribute  to  the  greater  value  the  EU  citizens  can 
derive  from  their  European  citizenship  right  to  equal  treatment  on 
consular protection when they are unrepresented in third countries. The 
social  impact  is  also  positive  due  to  reduced  risk  of  document  fraud, 
increased security of travel documents and EU borders. 

The  EU  ETD  will  require  some  biographical  data  and  an  obligatory 
facial  image.  This  data  is  collected  at  the  citizen's  request  and  it  is 
proportionate  to  the  information  needs  required  for  a  travel  document. 
No data other than those listed on the EU ETD might be put in machine-
readable  form.  Data  processing  involved  in  this  option  will  not 
significantly  change  as  compared  to  the  baseline.  The  Member  States 
will  be  obliged  to  exchange  data  through  formal  and  secure  channels, 
such  as  the  CoOL  website.  The  data  is  exchanged  between  Member 
States  for  the  purpose  of  confirming  the  identity  of  a  citizen  without 
other  valid  travel  documents  and  is  justified  on  those  grounds.  At  all 
times,  during  data  collection,  storage  and  transmission,  the  Member 
States  are  obliged  to  follow  the  EU's  acquis  and  fundamental  rights, 
particularly in relation to data protection.  

New security features will raise production cost, but with the application 
of  economies  of  scale  and  other  mitigating  measures  proposed,  the 
increase should not be significant.  It is uncertain whether any increase 
in the production costs would be passed on to the citizen or absorbed by 
the  Member  States 
the  non-discrimination 
provision  of  the  Treaties  and  of  the  Consular  Protection  Directive 
prohibits  charging  greater  price  for  EU  ETDs  than  for  national  ETD, 
thus  guarding  against  any  spike  in  fees.  The  costs  of  processing 
applications and confirming identity by the Member States are expected 
to  remain  the  same  as  currently  or  be  positively  affected  by  more 

themselves.  However, 

37 

impacts 

Social 
and 
fundamental 
rights 

Financial  and 
economic 
impacts 

 
efficient coordination between the Member States in accordance with the 
Consular Protection Directive. A more secure EU ETD format, which is 
multilingual and produced at EU-level, can also represent a cost-efficient 
alternative  to  Member  States  considering  replacing  their  outdated 
national  ETDs.  Better  recognition  of  the  new  format  will  accrue 
financial  savings  for  unrepresented  citizens  from  reduced  opportunity 
costs  and  other  savings,  e.g.  on  hotel  stays  and  alternative  travel 
arrangements.  

6.3 

Impacts from Policy Option 3  

6.3.1  Impacts on Member States' authorities 

The  biggest  impact  on  the  Member  States  from  this  option  would  be  the  cost  of  providing 
their consulates with the equipment necessary for personalising the biometric document on the 
spot. 

Consultations  undertaken  for  this  Impact  Assessment  on  the  EU  diplomatic  laissez-passer 
passports  have  produced  useful  comparisons.  The  cost  of  equipment  per  issuing  post  is 
estimated between 10 000 and 15 000 euros. Currently, only a minority of EU Member States' 
consulates  have  such  equipment  available,  with  many  Member  States  treating  their  requests 
for  passports  either  domestically  or  at  several  regional  centres  in  the  world.  This  in  turn 
involves  a  waiting  period  of  several  days  to  several  weeks  and  does  not  correspond  to  the 
needs  of  an  emergency  travel  document,  which  should  be  readily  available.  Equipping  all 
consulates with the required equipment on the other hand would be prohibitively expensive in 
proportion to the number of cases of EU ETDs issued every year.  

Even if certain cost-effective measures are undertaken, such as for example sharing or buying 
common  equipment  between  consulates,  the  level  of  total  investment  needed  would  remain 
significant.  At  the  same  time,  any  sharing  or  centralising  of  equipment  would  have  the 
negative effect of slowing down the issuance process.  

Besides the cost of equipment needed for personalisation, there is also the cost of the new EU 
ETD  booklet.  Although  it  is  difficult  to  the  estimate  the  exact  cost,  it  is  likely  to  be  in  the 
range  of  60-100  euros  per  printed  copy,  based  on  the  example  of  the  EU  laissez-passer 
biometric passport printed in relatively low quantities. 

The  Member  States  would  also  have  to  train  their  staff  to  use  the  new  equipment  for 
personalisation and would have to invest in maintenance of the equipment. 

The Member States’ costs of processing applications and confirming the applicant’s identity 
are expected to be largely the same as under Option 2. 

There would be some benefits to the Member States as well, but these are mainly due to some 
marginal extra security that can be derived from the biometric passport compared to Option 2. 

The Member States could also benefit from the spill-over effect of using the same equipment 
for issuing their biometric national passports at consulates. However, many Member States do 
not  have such  equipment  in  place at their  consulates for this  much bigger business  need  (in 
terms  of  number  of  cases),  which  shows  that  the  level  of  required  investment  remains 
prohibitively high. 

38 

 
 
 
6.3.2  Impacts on citizens 

Those  citizens  who  lost  their  passport  in  a  third  country,  while  planning  onward  journey, 
would stand to  benefit  most from  this option. It is  impossible to  know their exact  numbers, 
but  it  is  safe  to  assume  that  they  represent  a  minority  within  the  already  low  numbers  of 
unrepresented  citizens  requiring  an  EU  ETD.  The  benefit  of  being  able  to  continue  their 
journey would have to be weighed against a likely high cost of issuance of such a document. 
For the majority of other citizens requiring the EU ED for a single return journey home the 
costs of a biometric document would be significantly higher. 

In crisis situations, the EU ETD may be issued without the biometric data, filled in by hand 
and  at  no  charge.  This  is  already  the  case  today  with  the  current  format  and  is  an  accepted 
practice in crisis situations where the safety of the citizen is paramount. 

6.3.3  Impacts on other stakeholders 

The impacts on other stakeholders are similar to those under Option 2.  

6.3.4  Summary of impacts of Option 3  

The following Table summarises the main impacts from Option 3 relative to the objectives. 

Table 6-4:  Expected impacts from Option 3 

1.  To  adapt  the  EU  ETD  legislation  to  the  Consular  Protection 
Directive  

Same as Option 2. 

2.  Simplify  the  conditions  and  formalities  for  issuing  EU  ETD  and 
improve the cooperation and coordination among Member States.  

Most  of  the  consulates  would  have  to  be  equipped  with  the  required 
equipment for personalising biometric documents and the consular staff 
would have to be trained to use biometric equipment. Otherwise same as 
Option 2.  

3. Improve acceptance of EU ETD.  

Biometric  features  would  make  the  document  accepted  for  onward 
journeys. Otherwise same as Option 2.  

Effectiveness in 
attaining 
objectives 

4.  Enhanced  document  security  and  reduce  the  risk  of  document 
fraud.    The  biometric  EU  ETD  would  include  more  security  features 
compared to Option 2 and would equal Member States' passports.   

The citizens would benefit from longer duration EU ETD enabling them 
to continue onward journey.  

In terms of data protection, Option 3 will add the requirement to collect 

Social impacts 
and 
fundamental 

39 

 
 
 
rights 

Financial and 
economic 
impacts 

fingerprints.  As this is  currently not  done under  national  ETD schemes 
(though  for  national  passports),  more  people  will  be  affected  in  their 
rights to the protection of personal data. No data other than those listed 
on  the  EU  ETD  and  biometric  data  might  be  put  in  machine-readable 
form  or  in  the  chip.  The  biometric  features  shall  only  be  used  for 
verifying the authenticity of the document and the identity of the holder 
by  means  of  directly  available  comparable  features  when  the  EU  ETD 
are  required  to  be  produced  by  law.  The  EU  data  protection  acquis 
would  apply.  The  question  of  whether  and  how  Member  States  set  up 
their national  databases  to store biometrics is  not touched upon by this 
policy option, keeping with the principle of administrative autonomy of 
the Member States, though naturally any implementation would have to 
be  compatible  with  EU  law  and  the  fundamental  rights  it  protects  (in 
particular  the  right  to  the  protection  of  personal  data  under  Article  8 
CFEU).  
Biometric  security  features  would  require  installation  of  expensive 
equipment in many consulates. This equipment is currently not in place 
in  many  consulates  even  for  the  much  bigger  business  case  of  issuing 
national  passports.  While  some  cost-efficient  measures  can  be 
undertaken, they would still require high levels of investment and would 
cause some delays in the issuance of the EU ETD, which by very nature 
should be a readily available document.  The cost of the printed EU ETD 
booklet with biometrics is also likely to be high, given its high security 
features and low quantities in which it is produced. Any harmonisation 
of  Member  States  issuance  fees  would  likely  have  to  be  toward  the 
highest fees in order to discourage anyone from applying for an EU ETD 
with long validity period instead of national passport. 

7. HOW DO THE OPTIONS COMPARE? 

Effectiveness:  Options  2  and  3  are  both  effective  in  addressing  the  all  of  the  issues 
highlighted. They will both include a legislative proposal that will increase legal certainty in 
the  application  of  the  EU  ETD  and  improve  coordination  and  cooperation  among  Member 
States.  Both  Options  2 and 3 will increase the level  of  security  of the travel  document  and 
have  a  positive  effect  on  improving  its  acceptance  both  by  Member  States  and  around  the 
word. Option 3 goes further in increasing document security, providing a smaller number of 
citizens  requiring  onward  journeys  with  the  possibility  to  do  so.  However,  the  process  of 
issuance  may  be  slowed  down  significantly  depending  on  the  availability  of  the  necessary 
equipment. In comparison, Option 2 re-uses already available equipment in consulates, which 
allows  for  faster  processing  and  issuance.  Both  options  ensure  that  compliance  can  be 
monitored and, if necessary, enforced. 

Efficiency:  Both  Options  2  and  3  will  have  benefits  for  the  stakeholders  in  terms  of 
streamlined  and  harmonised  procedures,  higher  security,  increased  acceptance  and  faster 
processing at borders. Option 3 offers further benefits by allowing onward journeys. In terms 
of costs, the two options differ greatly. Whereas under Option 2 the cost of EU ETD remains 

40 

 
 
low  as  there  is  no  need  to  invest  in  new  equipment,  this  is  not  the  case  with  Option  3. 
Biometric  security  features  would  require  installation  of  expensive  equipment  in  many 
consulates.  The  cost  of  the  EU  ETD  to  citizens  under  Option  3  would  equally  increase 
significantly.  On  the  other  hand,  under  Option  2  the  cost  of  the  EU  ETD  to  the  citizens  is 
unlikely to increase due to low production costs. 

Coherence: Both Options 2 and 3 would be compatible with the existing EU framework and 
align  the  rules  on  issuance  of  EU  ETD  with  the  Consular  Protection  Directive.  This 
alignment would in particular include notions of absence of representation and confirmation 
of nationality, but would also align rules on coordination and fees. Both options would also 
include  situations  already  used  in  practice,  such  as  expired  passports  and  new-born  babies. 
Data  processing  under  both  options  would  follow  the  relevant  EU  and  national  legal 
provisions, ensuring full respect of fundamental rights. Both options are compliant with ICAO 
Guidance on emergency travel documents51.  

Proportionality: Option 2 raises security features of the document to the standard expected 
by the Member States and third countries and it does so using existing equipment and at a low 
cost. The citizen would benefit from a more secure document, less likely to be mistrusted and 
easier to process at the border. Option 3 will go beyond current expectations for emergency 
travel  documents  and  it  would  involve  significantly  larger  costs  for  the  Member  States 
without  achieving  considerably  higher  positive  effects.    The  costs  are  more  likely  to  be 
transferred to  citizens.  From the perspective of fundamental  rights,  and in  particular of data 
protection,  Option  2  is  more  proportionate  as  it  guarantees  the  citizen's  right  to  consular 
protection  abroad  while  only  requiring  the  collection  of  personal  data  necessary  to  achieve 
this purpose. 

Table 7-1:  Expected impacts from Option 2 and 3 

Criteria 

Option 1 - 
Baseline 

Option 2 – 
ETD sticker 

Effectiveness towards specific objectives 

Improve legal certainty 

Improve security and reduce document fraud 

Improve acceptance of EU ETD 

Simplify conditions for formalities and issuance  
Improve coordination and cooperation among 
Member States  

0 

0 

0 
0 

++ 

+ 

+ 

+ 
++ 

Option 3 
– 
biometric 
chip 

++ 

++ 

++ 

-/0 
++ 

Efficiency 

51 Available at: 

https://www.icao.int/Security/mrtd/Downloads/Guidance%20Material/Guidance%20on%20Emergency
%20Travel%20Documents%20May%202016%20final.pdf 

41 

 
 
 
                                                           
Criteria 

Option 1 - 
Baseline 

Option 2 – 
ETD sticker 

Coherence52 
Proportionality53  

Costs 
Benefits 
(COSTS VS BENEFITS) 

0 
0 
0 
0 
0 

-/0 
+ 
0/+ 
++ 
++ 

Option 3 
– 
biometric 
chip 
---/-- 
++ 
-/0 
++ 
- 

The main problems of security features and legal certainty cannot be effectively addressed by 
option 1 – baseline. Options 2 and 3 are both effective in addressing these problems, but with 
varying impacts on the stakeholders. 

The  main  difference  stems  from  the  treatment  of  the  update  of  security  features.  Option  2 
introduces  a  new  and  significant  improvement  in  security  features,  but  it  does  so  at  a 
relatively  modest  increase  in  the  cost  to  all  stakeholders.  The  modelling  of  the  EU  ETD 
sticker on the existing uniform format for visas re-purposes this already widely used tool in 
EU  consulates  to  strengthen  the  security  of  the  EU  ETD.    The  EU  and  the  Member  States 
benefit  from  increased  security,  whilst  the  citizen  benefits  from  expedient  solution  and 
increased acceptance of the document. 

The  Option  3  matches  the  security  features  of  Option  2  and  raises  them  to  the  level  of 
fingerprints  and  biometric  chip.  It  offers  some  marginal  benefits  in  return,  by  further 
increasing  document  security  and  allowing  for  onward  journeys.  However,  the  production 
cost  and  the  equipment  needed  is  prohibitively  high.  Under  Option  3,  the  vast  majority  of 
citizens who require an EU ETD to return home would also be faced with a significantly more 
expensive document than needed for their purpose. 

As a result of the comparison of the options, Option 2 is the preferred option and ranked first.  

8. PREFERRED OPTION 

Option 2 would end the current fragmentation amongst EU Member States in the application 
of EU ETD and it would bring legal certainty to unrepresented EU citizens in the exercise of 
their  right  to  equal  treatment  on  consular  protection  abroad.  Importantly,  Option  2  would 
make the issuance of EU ETD compulsory for unrepresented citizens in third countries and it 
would enable the Commission to perform its role of monitoring and taking any measures in 
this regard if necessary. 

Both the Council and the Parliament have called on the Commission to make a proposal for a 
new EU ETD containing security features in line with current practices. The preferred option 

52  
53  

Coherence in relation to the Consular Protection Directive and Fundamental Rights. 
The  proportionality test ensures that any policy  measure is limited to  what is necessary  to achieve  its 
objectives.  

42 

 
 
                                                           
 
reflects  this  assessment  and  the  views  expressed  by  Member  States  during  consultations, 
including  the  three  Member  States  with  the  biggest  consular  networks,  on  the  best  way  to 
modernise the common format.  

The  Member  States  who  currently  do  not  issue  EU  ETDs  due  to  concerns  over  security 
features, would be required to issue the document to unrepresented citizens in third countries. 
This  would  be  justified  by  the  security  improvements  to  the  document  itself  as  well  as  the 
issuing process. The proposed EU ETD sticker would have equivalent security features as the 
uniform  format  for  visas  and  can  be  issued  easily  by  consular  staff  using  the  equipment 
available in all EU consulates for issuing visas. Additional advantage of the EU ETD sticker 
is its machine readability, which will make processing time at the borders quicker. A specific 
area  would  be  added  to  the  EU  ETD  form  to  allow  for  affixing  any  transit  visa  (as  is  for 
example asked by the USA).   

A  comitology  procedure,  aligned  with  existing  ones  especially  the  one  on  the  visa  sticker, 
would  be  established  to  specify  necessary  further  technical  specifications  for  the  uniform 
format  for  EU  ETDs,  including  enhanced  anti-forgery,  counterfeiting  and  falsification 
standards and technical  standards and methods to be used for the filling in of the EU ETDs 
and  its  colours.  The  comitology  procedure  would  thus  allow  for  the  EU  ETD  document  to 
benefit from other developments in increased security of other types of travel documents. 

Importantly, the new legal instrument governing EU ETD would be aligned with the Consular 
Protection Directive. Member States and citizens would thus benefit from greater legal clarity 
and  coherence.  Concepts  such  as  absence  of  representation  and  confirmation  of  nationality 
would  be  clarified,  granting  unrepresented  citizens  a  legal  right  to  EU  ETDs  in  more 
situations  than  under  the  current  EU  ETD  Decision.  The  same  is  valid  in  cases  of  expired 
passports and new-born babies, which would now be covered. 

The benefits to the citizen would also be clearer deadlines for Member States on processing 
times  for  issuance  of  the  document,  a  cap  on  potential  fees  that  can  be  charged  for  the  EU 
ETD and the removal of the obligation for the citizen to send originals of the application to 
their Member State of nationality. Equally, the citizen would no longer be required to bring 
their photo in all cases where the consulate is equipped with a digital camera. 

The impact  on the citizens from  this option is  expected to  be positive. They  will be able to 
count  on  obtaining  the  EU  ETD  from  all  Member  States'  consulates  under  the  same 
conditions.  Increased  security 
increase  EU  ETDs'  acceptance  and 
trustworthiness  at  the  borders.    Better  recognition  of  the  new  format  will  accrue  financial 
savings for unrepresented citizens from reduced opportunity costs and other savings, e.g. on 
hotel stays and alternative travel arrangements. 

is  expected 

to 

The costs for the Member States are expected to remain low given the low production cost of 
8  euros  per  document.  Based  on  the  estimated  annual  issuance  of  1000  EU  ETDs,  the 
production costs can be estimated to be around 8000 euros annually across all Member States. 
Initial stocking purposes are likely to be somewhat bigger and could be estimated at 40 000 
euros, based on the initial order of 5000 EU ETDs.  The Member States with larger consular 
networks would have somewhat higher costs (see table 6-2 for overview of networks), both in 

43 

 
terms  of  purchase  of  new  documents  and  training  needs;  however,  total  amounts  are  not 
expected to be significant given the low numbers of these documents issued annually. 

The administrative costs involved in processing applications for EU ETD and confirming the 
applicant’s nationality are expected to either stay the same under this option as compared to 
status  quo  or  be  positively  affected  due  the  harmonisation  and  streamlining  of  the 
administrative procedures governing EU ETDs. 

It  should  also  be  noted  that  burden  sharing  between  Member  States  in  terms  of  consular 
protection  is  provided  for  in  the  Consular  Protection  Directive,  which  enables  the  Member 
States  to  establish  local  consular  cooperation  in  third  countries  through  which  they  can 
arrange  how  best  to  organise  the  provision  of  services  to  unrepresented  citizens  as  well  as 
distribute more fairly the associated burden among themselves. The assisting Member States 
are  equally  entitled  to  reimbursement  of  costs  from  the  Member  State  of  nationality  of  the 
unrepresented citizen for the consular assistance provided. 

The somewhat higher cost of production of the new EU ETD form can be justified given the 
increased security features. But this is not expected to lead to a substantially higher price for 
the citizen as the non-discrimination  provision of the Treaty  and of the  Consular  Protection 
Directive prohibits charging greater price for EU ETDs than for national ETD, thus guarding 
against any spike in fees. 

The  new  legal  instrument  governing  EU  ETD  would  be  mandatory  only  within  the  area  of 
consular protection for unrepresented citizens in third countries. However, it would explicitly 
allow for EU ETD to be used optionally by Member States for their own citizens and within 
the  EU,  as  is  the  case  already  in  practice.  A  more  secure  EU  ETD  format,  which  is 
multilingual  and  produced  at  EU-level,  can  also  represent  a  cost-efficient  alternative  to 
Member States considering replacing any outdated national ETDs. 

44 

 
 
 
1.1.  REFIT (simplification and improved efficiency) 

Table 8-1:  REFIT Costs and savings from Option 2 – Preferred Option 

Description 

Amount 

Direct benefits 

Citizens – annual costs 
savings from deadlines 
on issuance  

EUR 93,000 

Cost savings for 
accelerated document 
checks at EU external 
borders due to machine 
readability of the 
document 

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

Quicker, more reliable processing of 
citizens travelling on EU ETDs at the EU 
borders, reduced administration 

Fewer rejections of citizens 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. 

Improved security 
within the EU and at its 
borders 

Indirect benefits 
Reduction in document fraud related to 
poor document type (forgery, tampering, 
impostor, reused document blanks). 

Comments 

Opportunity costs of 
€93/day in saved time 
per case. The time 
savings based on 1000 
annual cases per year 
can be valued at €93,000 
across all citizens. 

Not quantifiable – 
border authorities do not 
collect such data 
Beneficiaries: border 
authorities, citizens 

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 – the 
precise increase in the 
level of security within 
the EU cannot be 
quantified. 
Beneficiaries: Citizens, 
public administrations, 
businesses. 

Facilitated access to the 
right to equal treatment 
on consular protection 
for unrepresented EU 
citizens  

Improved document will increase the 
acceptance and make the exercise of the 
right to  equal treatment on consular 
protection of unrepresented EU citizens 
quicker, easier and more secure. This 
will in turn have a positive effect on the 
perceived benefits of EU citizenship. 

Not quantifiable – the 
precise increase in the 
level of the perceived 
benefits of EU 
citizenship cannot be 
quantified. 
Citizens. 

45 

 
 
 
 
9. HOW  WILL  ACTUAL 

IMPACTS  BE  MONITORED  AND 

EVALUATED? 

The  preferred  option  would  be  monitored  and  evaluated  against  its  objectives,  which  are 
detailed in Section 4 above. Suggested indicators at overall and specific objective levels are 
set out in Table 9-1 below, along with potential sources of data. 

In  addition,  progress  will  be  monitored  in  5-year  periods  (due  to  the  low  annual  numbers 
currently being issued) to determine whether the option is being implemented in accordance 
with its provisions. Reporting obligations on Member States will be thus needed and could be 
thus timed together with the Consular Protection Directive. Any corrective measures can be 
taken if required. Nevertheless, taking into account the limited number of EU ETDs issued by 
Member States, it is important to adopt a realistic approach to monitoring the implementation 
of the preferred policy option and not to overburden national authorities. Consultations with 
Member States in the framework of the expert group on consular protection will take place to 
determine the most appropriate frequency of data collection and reporting. 

Periodic  reviews  of  the  implementation  of  the  option  by  the  Commission  should  be  carried 
out  accordingly  to  collect  relevant  information  and  to  analyse  implementation  by  each 
Member  State.  The  indicators  should  be  collectable  from  Member  States  (e.g.  number  of 
ETDs issued and rejected by third parties), established agencies (e.g. Frontex, Interpol, border 
force) on the level of fraud/forgery detected and/or be part of a regular Eurobarometer survey 
(level of awareness by citizens, benefits of EU citizenship and benefits from EU ETDs). 

Citizens will be asked to give feedback upon return of their EU ETD when applying for a new 
passport.  Other  stakeholders  (third  countries  via  EU  delegations,  airlines  etc.)  will  be 
consulted as appropriate. 

Monitoring  will  result  in  an  implementation  report  produced  and  submitted  by  the 
Commission  to  other  EU  institutions  five  years  after  the  entry  into  application  of  the 
legislative measure. This report will review the indicators listed in Table 9.1. 

Success of the initiative would be determined, for example, by a very low number of cases of 
fraudulent use/counterfeit EU ETDs, increased awareness among citizens, few reported issues 
of  acceptance  by  third  countries  and  related  problems,  and  increased  use  of  EU  ETDs  by 
Member States in non-mandatory situations (e.g. for their own nationals). 

46 

 
 
 
Table 9-1:  Monitoring and Evaluation indicators 

Overall Objectives 

Indicators 

To  facilitate  the  citizens’  right 
to  equal  treatment  on  consular 
protection 
for  unrepresented 
EU citizens abroad 

No.s  of  ETDs 
to 
unrepresented  EU  citizens  (by 
Member State). 

issued 

EU  citizens'  awareness  of  EU 
ETDs 

To  improve  security  within  the 
EU and its borders 

Acceptability  of  EU  ETDs  by 
third country border authorities. 

No.s  of  cases  of  fraudulent 
use/counterfeit documents. 

Specific Objectives 

Indicators 

To 
adapt 
legislation 
Protection Directive 

to 

the  EU  ETD 
the  Consular 

Issues  having  arisen  due  to 
conflicts,  overlaps  or  gaps 
between  ETD  and  Consular 
Protection legislation. 

Sources 
Information 

of 

Member States reports 

Feedback from citizens 

(general  Eurobarometer 
survey  on  citizenship 
rights) 

Consultation 
with/surveys 
Member  States 
border authorities. 

of 
and 

Sources 
Information 

of 

with 
Consultation 
Member  States 
(both 
issuing ETDs as well as 
those whose citizens are 
in receipt of them). 

Periodic 
conducted 
Commission. 

reviews 
the 

by 

To improve the cooperation and 
coordination  among  Member 
States 

To  simplify  the  conditions  and 
formalities  for  citizens  in  need 
of an EU ETD 

Average  time  taken  to  process 
ETD applications 

Member States reports 

Assessment  criteria  adopted  by 
Member States. 

Member  States 
Commission reports 

and 

Cost of an ETD application. 

Average  time  from  application 
to issuing ETD. 

No.s  of  refused  applications, 
broken  down  by  reasons  for 
refusal. 

47 

 
 
 
 
 
Table 9-1:  Monitoring and Evaluation indicators 

To  improve  acceptance  of  EU 
ETD 

To  enhance  document  security 
and reduce document fraud 

Member States reports 

rejected  by 
No.s  of  ETDs 
airlines  and  other 
transport 
operators, and/or third countries 
transit 
of 
countries  

departure 

and 

No.s  of  EU  ETDs  denied  at 
points of entry to the EU. 

Use  of  EU  ETDs 
mandatory situations. 

in  non-

Updates  in  security  features  of 
travel  documents  in  light  of 
technological developments and 
threats. 

No.s  of  cases  of  fraudulent 
use/counterfeit documents. 

Member  States 
Commission reports. 

and 

Frontex/Interpol data. 

48 

 
 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

A1.1  Lead DG, Decide Planning/CWP references 

DG JUSTICE AND CONSUMER AFFAIRS 

DECIDE PLANNING: 2017/JUST/017 

CWP 2018: REFIT initiatives: An Area of Justice and Fundamental Rights Based on Mutual 
Trust (9.ID cards and Residence Documents): Review of the Proposal for a Council Directive 
to replace the Decision on the establishment of an emergency travel document (legislative, 
incl. impact assessment, Art. 23 TFEU, Q2 2018)  

A1.2  Organisation and timing 

A Commission inter-services steering group (ISG) was established in July 2017 for preparing 
this initiative. The following DGs and services were invited to the inter-service group: 
General Secretariat (SG), Legal Service (SJ), Migration and Home Affairs (HOME), 
European External Action Service (EEAS), Humanitarian Aid & Civil Protection (ECHO), 
Budget (BUDG) , Employment, Social Affairs and Inclusion (EMPL) and Internal Market, 
Industry, Entrepreneurship and SMEs (GROW). The ISG met 4 times in the period from July 
2017 to February 2018. 

A1.3  Consultation with RSB 

The Regulatory Scrutiny Board delivered a positive opinion on 23 April 2018. The tables 
below shows how this report takes into account the main RSB comments.  

(1) The  report  discards  options  based  on 
national  ETDs  without  establishing 
why these could not deliver satisfactory 
results. 

The  report  has  been  amended  to  include  a 
better  explanation  on  why  the  option  of 
national ETDs has been discarded. Further 
evidence  of 
lack  of  support  by 
stakeholders  as  well  as  the  ineffectiveness 
of this approach has been added.  

the 

(2) The  options  only  concern  the  security-
the  proposed 
related  elements  of 
measures,  whereas 
problem 
the 
description  also  raises  issues  of  legal 
certainty, 
and 
acceptability  that  the  options  do  not 
address.  

enforceability 

to 

tackle 

The report has been updated to substantiate 
the  lack  of  choice  in  the  construction  of 
options 
legal 
the 
certainty,  enforceability  and  acceptability 
described  in  the  problem  definition.  The 
report further details how these aspects are 
covered in both Options 2 and 3. 

issues  of 

(3) The report does not adequately explain 
how  the  preferred  option  addresses 
stakeholder  concerns 
the 
terms  of 
current  system,  e.g. 
security. 

regarding 
in 

The  report  has  been  amended  to  include 
further explanation as to how the preferred 
option addresses the stakeholders' concerns 
regarding the current system. 

49 

 
 
 
 
 
A1.4  Evidence, sources and quality 

The  evidence  for  this  Impact  assessment  has  been  gathered  through  a  study  commissioned 
under the relevant framework contract to RPA and EPRD.  

To  conduct  this  study  and  gather  evidence,  a  search  for  relevant  data  and  information  was 
conducted online, covering sources from both within and outside of the EU. The Decision’s 
legal text was rigorously examined and statistical data was gathered from relevant databases 
(such  as  Eurostat).  Searches  were  conducted  in  the  official  languages  of  the  EU  by  native 
country researchers assigned according to language capabilities. A number of parallel studies 
have provided useful information to this impact assessment (and earlier evaluation). The main 
sources of data include: 

  GHK (2011): Study on the Impact Assessment on Improving Financial Compensation 

of Consular Protection in Crisis Situations, a study for DG Justice; 

  European  Institute  of  Law  (2009):    Study  on  Member  States’  Legislations  and 

Practices in the field of Consular Protection, final report to DG Justice; 
  Flash Eurobarometer, Consular Protection - Analytical Report (2006); 
  Flash Eurobarometer 430 Report, European Union citizenship, October 2015 Survey; 
  CARE  (Citizens  Consular  Assistance  Regulation  in  Europe)  project  activities  (2009-

2011); 

  GHK (2010): Study supporting the Commission in the analysis of policy options and 

the related costs, focusing on crisis situations and financial reimbursement; and 

  Matrix  Insight  (2011):    Study  providing  further  evidence,  including  via  missions  to 
third countries, evaluated Decision 95/553/EC and examined scope for improvement. 

The  methodology  consisted  of  both  a  literature  review  and  consultation  (by  means  of  a 
survey,  direct  email  consultation  and  telephone  interviews  as  described  in  Annex  2).  More 
than 200 e-mails have been sent to request information, including remainder e-mails to obtain 
responses to the survey in order to gather evidence. The approach has included quantification 
of  impacts  (to  the  extent  possible),  including  monetisation  based  on  data  obtained  from 
consultation and literature review (e.g. on number of ETDs, fees and hours spent to complete 
an individual ETD, etc.).   

Care has been taken however to interpret the evidence based on the following: 

 

Internal  validity  of  the  evidence:  i.e.  its  precision  and  reliability.  When  possible, 
general statistics have been used to quantify the impacts but there is, overall, a lack of 
official    published  data  on  key  indicators  which  are,  according  to  survey  responses,  
not  consistently  being  collected  by  all  Member  States  (e.g.  namely  the  number  of 
ETDs  issued  to  unrepresented  citizens,  ETDs  issued  to  own  nationals  and  to 
unrepresented nationals living abroad);  

  Temporal  relevance.  The  evidence  on  the  impacts  represents  the  period  since  the 
Decision’s implementation, with this taking into account the differences in the timing 
at which Member States joined the EU (including the  fact  that a Member State may 
not have been a member in the period prior to the Decision); and 
Independence  of  source:  the  most  balanced  arguments  have  been  presented  and 
attempts have been made to avoid any significant biases.  

 

50 

 
 
 
 
 The main caveats with the findings are as follows: 

  Sample  size  and  representativeness:  Limited  responses  to  the  OPC  and  the  lack  of 
representativeness  of  the  responses  in  terms  of  those  citizens  in  need  of  consular 
assistance  by  Member  States  other  than  their  own  means  that  extrapolation  of  the 
results  concerning  impacts  on  citizens  is  very  uncertain.  Examples  are  available  but 
must  be  considered  as  only  illustrative  of  the  types  of  cases  that  do  arise  in  many 
countries. These have been included at relevant points in the assessment, as they may 
set  a  precedent  but  they  should  not  be  read  as  necessarily  being  representative  or 
reflecting common issues; 

  Member States do not collect consistently and systematically statistics on the number 
of ETDs issued to their own citizens by other missions, nor on the number of ETDs 
issued  to  unrepresented  citizens.  Such  obligation  does  not  exist  under  Decision 
96/409/CFSP. Thus, the figures may be an under-representation of the real level of use 
of the EU ETD.  

  Generally,  the  findings  from  different  sources  show  some  discrepancies  that  could 
impact  on  the  robustness  of  the  findings;  in  particular  the  assumptions  made  in  the 
GHK study about the numbers of unrepresented citizens living abroad do not seem to 
match  up  easily  with  more  recent  estimates  provided  by  Member  States  authorities 
when responding to the survey. Although clarification has been sought from the latter, 
these  estimates  have  been  difficult  to  reconcile.  Thus,  it  is  recommended  that  these 
data are collected in the future to minimise uncertainty.  

Data has thus been gathered and validated across the different sources and utilised as follows: 

 

 

Information communicated by stakeholders but unsupported by desk-research are given a 
higher uncertainty rating: e.g. the estimate of people living in Third countries and being 
unrepresented is given a high uncertainty level. 

Information communicated by stakeholders and supported by desk-research. In particular 
information that has been found to be grounded and supported by other literature has been 
given greater weight (e.g. level of implementation, awareness of the EU ETD, magnitude 
of costs, etc.) so uncertainty is lower.  

It  needs  to  be  said  that  although  the  targeted  consultation  with  trade  associations  and 
companies  carried  out  for  this  evaluation  and  impact  assessment  has  been  restricted  to  a 
limited  number,  some  of  the  responses  include  the  main  players  in  the  field.  These  include 
companies like British Airways, KLM, and associations such as the European Travel Agents, 
Airlines for Europe, and the Tour Operators’ Associations.  These associations in  particular 
were able to speak on behalf of their members that include business operators in all Member 
States.      Thus,  the  responses  show  a  good  spread  of  Member  States’  coverage,  including 
associations operating at European level and representing the main players in the EU.  

Furthermore,  the  members  of  the  Expert  Group  on  the  rights  of  unrepresented  citizens  to 
consular  protection  abroad  have  also  confirmed  to  the  consultants  that  they  have  consulted 
and  gathered  data  from  their  own  missions  abroad  and  related  authorities  (such  as  border 
control). As a result of this, it is believed that the data collected from the consultation work 
are robust enough to inform the evaluation and Impact Assessment. 

51 

 
 
 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

A2.1  Summary of Consultation Strategy 

Prior to initiating the consultation, a mapping exercise of the stakeholders was undertaken by 
the  external  contractor  in  order  to  develop  an  effective  strategy  and  maximise  responses 
whilst  ensuring  that  the  evaluation  questions  were  fully  answered  and  the  objectives  of  the 
impact  assessment  were  met.  The  following  Table  summarises  the  list  of  stakeholders  and 
relevance for consultation.  

Different  methods  to  collect  data  have  included  surveys  and  interviews  by  telephone.  Two 
main surveys have been conducted on-line; one to Member States’ competent authorities and 
the other for citizens and business through Open Public Consultation (OPC). Consultation has 
been undertaken both within the EU and at international level (with Member States’ mission 
and third countries to examine aspects to do with issuance and acceptance). More information 
is provided below. The consultation carried out by the external contractor (covering both the 
evaluation and this impact assessment) involved the following: 

  Consultation with experts from the European Commission, EEAS and the Council 
Secretariat,  gathering  some  opinions  to  inform  option  development  (especially 
concerning security features); 

  Consultation  with  Member  States’  competent  authorities:  by  means  of  a  survey. 
Contacts included the members of the Commission's Expert Group on the rights of 
unrepresented citizens  to consular protection abroad, with  follow-up questions in 
e-mails to clarify outstanding issues.  Telephone interviews were also conducted at 
Member State authorities’ convenience to discuss key issues in greater depth. The 
interview  questions  were  tailored  to  the  specific  stakeholder  being  interviewed, 
and  were  thus  bespoke  (as  opposed  to  using  generic  interview  guides;  see  more 
details below);  

  Consultation  with  trade  associations,  including  tour  operators,  airline  companies 
and insurance companies. This  consultation  was undertaken by means of e-mails 
and telephone interviews with a number of questions concerning their experience 
with the EU ETD, any costs and benefits and any views on the security aspects.  

  Consultation  with  citizens  and  citizens’  groups:  this  included  an  e-mail  with 
questions  on  levels  of  awareness  of  the  EU  ETD  and  experiences  with  it.  In 
addition, an Open Consultation process was undertaken; and 

 

Interviews with Member States’ missions conducted in third countries (e.g. Peru, 
Mexico, Dominican Republic) and third countries authorities (e.g. US, Indonesia) 
to  explore  specific  aspects  with  regard  to  the  use  of  ETDs,  in  terms  of 
acceptability. 

52 

 
 
Table A2.1:  Consultation approach 

Stakeholder  

Relevance for consultation 

Specific/example questions 

Competent 
authority – CA 
(Ministries/passport 
offices) 

To collect information and data on their legislation 
and practices concerning emergency travel documents 
(common format or any other) issued both to their 
own citizens and to unrepresented EU citizens. 

EU citizens and 
citizens’ groups 

To collect information on the experiences when 
travelling on ETDs as well as perceptions and 
awareness level of right of consular protection and the 
EU ETD 

Border control 
authorities 

To collect information on the level of fraud and 
training undertaken on ETDs. 

Tour operators and 
associations 

To collect information on the interactions and 
linkages with other legislation (i.e. Package Travel 
Directive) and information on costs and benefits from 
ETDs 

Airlines companies 
& associations 

To collect information on costs and benefits from 
ETDs and training costs  

Full survey (refer below for more information) + bespoke semi-structured 
interviews 

Open Consultation (OPC) + e-mail with following questions: 
1.  Are you aware of the existence of the common format ETD? Have you got 
any experience with it?  If you do, could you please explain whether this has 
been good or bad? (with estimates of costs and benefits) 

2.  Do  you  believe  that  the  EU  ETD  provides  genuine  help  to  EU  citizens  in 

distress? 

1.  Are you familiar with the common format ETD? 
2.  Do  you  accept  ETDs  (either  national  or  common  format)  for  EU  citizens 
living in your country but national of another MS? Do you recognise ETDs 
only to travel back to the country of the issuing authority?  

3.  Can you see any advantages of having a uniform format for ETD across the 

EU?  

4.  Have  you  got  any  views  on  the  security  aspects  that  a  new,  improved 

common format ETD should have as a minimum?  

5.  Have you got any evidence or statistics on ETD fraud (both common format 

and/or national ETDs)?  

1.  Are you aware of the existence of the common format ETD? Have you got 

experience with it?  
2. 
If you do, could you please explain whether this has been good or bad? 
3.  Can you see any aspects concerning the coherence of the Decision with the 

Package Travel Directive? 

1.  Are you familiar with the common format ETD?    
2.  Can you see any advantages of having a uniform format for ETD across the 

EU?  

53 

 
 
Table A2.1:  Consultation approach 

Stakeholder  

Relevance for consultation 

Specific/example questions 

Insurance 
companies and 
associations 

To collect information on costs and benefits from 
ETDs  (reduced/increased claims for ability or lack of 
travel) 

3.  Can you highlight any costs or benefits to your organisation? 
4.  Have  you  got  any  views  on  the  security  aspects  that  a  new,  improved 

common format ETD should have as a minimum 

1.  Are  you  familiar  with  the  common  format  ETD?  Is  there  an  insurance 
covering loss or theft of documents? Does it cover the costs for issuing of an 
ETD?  Are  you  aware  of  any  estimates  of  the  costs  incurred  in  assisting 
travellers who have lost their travel documents or had them stolen (both now 
or following the transposition of the new PTD)? 

2.  Can you see any advantages of having a uniform format for ETD?  
3.  Can you highlight any costs or benefits to your organisation?  
4.  Have  you  got  any  views  on  the  security  aspects  that  a  new,  improved 

common format ETD should have as a minimum?  

5.  Can you see any aspects concerning the coherence of the Decision with the 

Package Travel Directive?  

Other 

Statistics on travel from UNWTO 
Costs of blank forms – Italian mint 
Commission services – baseline and Options 
Member States’ missions in third countries – 
practices/experience with ETDs 
Third countries – experience/acceptance of EU ETDs 

Bespoke 

54 

 
 
A2.2  Bespoke  consultation  for  the  studies  supporting  the  impact  assessment  and 
evaluation 

An  internet-based  survey  was  developed  (using  SurveyGizmo)  by  the  external  contractor 
consisting of relevant  questions for Member State Authorities, specifically  the Ministries of 
Foreign Affairs. Contact was taken with 28 Member State Authorities on 25th October 2017. 
Recipients  were  provided  with  an  initial  response  deadline  of  10th  November  2017. 
Following requests from some Members States’ Authorities and to encourage greater response 
rates, the survey deadline was extended to 8th December 2017.  

In  addition  to  the  online  survey,  telephone  interviews  were  also  carried  out  by  the  external 
contractor to  gather further information on questions  of particular interest  and to  provide to 
respondents that had not completed the online survey an opportunity to provide input into the 
study.    Member  States’  authorities  that  were  unable  to  complete  the  online  survey  and 
participate in a telephone interview were encouraged to provide information for the study via 
a streamlined set of questions sent by email.  

In  addition  to  the  survey  to  the  authorities,  over  50  companies,  a  mix  of airline  companies, 
tour operators and insurance companies, were contacted by the external  contractor to  gather 
their  views  on  the  EU  ETD  and  potential  options  for  improvement.  The  external  contractor 
also  referred  companies  to  the  OPC  carried  out  by  the  Commission(see  next  point).  Border 
police in the different Member States were also contacted to enquiry about the level of fraud 
to do with the EU ETD.  

The  following  table  summarises  the  number  of  consultation  responses  received  by  the 
contractor by stakeholder group and country and excluding the OPC.  As shown in the Table, 
a  total  of  95  responses  were  received  to  the  consultation  carried  out  for  this  evaluation.  
During the consultation  with  Member States, it became  evident that the  Ministries  from  the 
different Member States have also consulted their missions worldwide to gather evidence on 
the number of ETDs being issued.  Thus, the number below may underrepresent the total level 
of consultation undertaken. 

There was a good coverage of Member States responded to the targeted consultation, with all 
EU  Member  State  represented  by  at  least  one  stakeholder.    The  online  survey  to  Member 
States’  competent  authorities  was  answered  by  all  Member  States,  with  the  exception  of 
Germany,  Cyprus  and  Greece.  However,  all  three  countries  responded  to  our  request  for 
telephone interviews and information. Cyprus and Greece confirmed that they had not issued 
any EU ETDs to date; thus, their input to the survey was considered by them to be of limited 
added value. The full list of consultees is given below. 

55 

 
 
 
 
 
 
 
 
Table A2.2:  Research methods for data collection – Consultation responses 

CA: Competent authorities (Ministries/Passport 
offices) 
TO: Tour operator (incl. associations) 

IC: Insurance company (incl. associations) 
AC: Airline company (incl. associations) 
IC: Insurance company (incl. associations) 

Member States 

CA 

Citizens/ 
groups 

Border 
control 

TO 

AC 

IC 

Other? 
Please 
specify 

Total 

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 

EU level 

International 

Total 

1 
1 
1 
1 
1 
1 
1 
1 
1 
1 
1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

3 

1 
1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

1 

1 

1 

1 
1 

1 

1 
1 

2 

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 

1 

1 

1 

1 

1 
1 
1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

2 

1 
1c 

1a 

1 

2b 

2 
1 
5 
3 
1 
3 
3 
5 
4 
2 
5 

2 

4 

3 

3 

2 

3 

1 

4 

1 

4 

5 

4 

1 

4 

4 

1 

4 

5 

6 

95 

Notes: a: Chamber of Commerce and Industry of Slovenia; b: Gemalto, UNWTO; c: ICAO 

Responses from competent authorities include survey responses; additional queries were carried out by e-mail 
and/or phone to address specific issues or gather specific data. International includes case studies, including 
Member States representations in third countries. 

56 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
A2.3  Member States’ competent authorities 

Overall,  most  Member  States  consulted  for  this  study  believed  that  travelling  and  living 
abroad  will    continue  to  create  increasing  requests  for  ETD  in  the  future.    None  of  the 
Member States’ authorities are expecting the number of ETD needed for their own citizens to 
be reduced in the future. However, it was pointed out by stakeholders that insufficient security 
features  may  be  a  factor  in  the  level  of  uptake  by  some  Member  States  in  the  future.    The 
three  Member  States  currently  issuing  national  ETDs  to  unrepresented  citizens  have 
confirmed this (FR, DE and the UK). 

All  Member  States  responding  to  the  on-line  based  survey  consultation  conducted  with 
Member  States’  authorities  for  this  Impact  Assessment,  depicted  in  Figure  1-1,  agreed  that 
improving  security  features  is  very  important  or  somewhat  important  in  view  of  possible 
modernisation. Less important is the simplification of formalities.  

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

5 

9 

10 

7 

13 

11 

10 

4 

4 

14 

11 

3 

14 

7 

3 

16 

19 

6 

6 

Simplification
of formalities

Better
arrangements
for the
clearance of
applicants

Better
arrangements
for recording
information
(details of
application)

Agreement on
methods to
return EU
ETDs on
arrival to
destination

Modernisation
of security
features of
the EU ETD

Better
arrangements
for setting the
period of
validity of the
EU ETD

Improving the
acceptance of
the EU ETD
around the
world

Very important

Somewhat
important

Unimportant

Figure A2.3: Responses to Member States’ online survey question 36 - In view of the 
possible modernisation of the rules applicable to the issuance and format of the EU 
ETD, please assess the perceived importance for you of the following objectives 
(n=25)54 

54  

Three MS did not reply to the questionnaire (DE, CY and EL).  

57 

 
 
 
 
 
                                                           
The above would suggest that upgrading security features of the EU ETD would be supported 
by most Member States.  The border force consulted for the study agreed with suggestions to 
improve  its  security  features.  The  on-line  survey  also  questioned  Member  States  about  the 
minimum  security  features  required  for  a  modernised  EU  ETD.  Figure  2  below  highlights 
those  security  features  that  Member  States  believe  the  EU  ETD  should have  as  a  minimum 
and therefore that have been considered in the design of the options. Most of the requirements 
relate  to  security  paper  and  special  inks  and  coatings,  although  a  significant  number  of 
Member States included informational add-ons. Most survey respondents agreed that special 
paper  and  secure  information  add-ons  should  be  used.    Eighteen  of  the  21  Member  States 
authorities  that  responded  (85%  of  respondents)  indicated  that  watermarks  should  be  used.  
Additional  features  suggested  by  the  responding  authorities  are  shown  in  Box  1.  Specific 
features  mentioned  included  machine  readable  zone  and  a  barcode  which  is  now  part  of 
Option 2. Four Member States mentioned biometrics which is now part of Option 3. 

Security Paper - watermarks

Special Inks and Coatings - fluorescent inks (UV…

Security Paper - embedded threads

Complex imaging - fine line graphical backgrounds -…

Informational Add-ons - Image/photograph

Secure Appliqués - foils

Special Inks and Coatings - colour shifting

Special Inks and Coatings - copy-resistant inks

Secure Appliqués - holographic or prismatic images

Complex imaging - microprinting, e.g. INTAGLIO

Special Inks and Coatings - laminate

18 

17 

15 

14 

13 

11 

11 

10 

9 

9 

9 

Calculated or Changeable Content - check digit…

7 

Informational Add-ons - RFID chips/biometrics

4 

Calculated or Changeable Content - images that alter…

Informational Add-ons - magnetic stripes

2 

2 

0%

50%

100%

Figure A2.4: Responses to Member States’ online survey question 32 - Please tick 
from the list below the security features that the EU ETD should have as a minimum 
in your opinion (n=2155)  

Box 1: “Other” security features from Member States’ online survey question 32  

55  

Four MS did not answer this question. The remaining two did not answer the questionnaire.  

58 

 
 
 
 
 
                                                           
  Booklet form 
  Printed 2nd photo 
  Future  ETD  should  look  more  like  a  proper  passport,  also  to  avoid  complications 

when exiting the country (i.e. hard cover, booklet form) 

  Security  paper-  free  of  optical  brighteners  and  with  reagents  against  chemical 

erasure 

  Security paper- visible and invisible security fibres with fluorescent properties 
  Numbering-  the  serial  number  shell  be  printed  in  letterpress  using  ink  with  UV 

properties 

  Printing  process-  OFFSET  (background,  IRSI)  and  INTAGLIO  (latent  image, 

microprinting) 

  Personalisation process (photo and data) - inkjet technology 
  Secondary image printed on bio data page 
  Laser perforated document numbering from the geodata page through rear cover 
  Protection method for additional information about the holder on Observation page 
  Fibres or planchettes 
  Letter press number 
  Rainbow printing 
  See-through 
 
IR-split 
  Security paper - visible and invisible fibres, fluorescent in UV 
  Rainbow 
  Machine readable zone acc. to ICAO 9303 
  Digital seal (as 2D-barcode) 
  Microprinting 
  Numbering with letterpress incl. UV reaction  
  Security fibres 
  DOVID 

Guidelines56  on  consular  protection  of  EU  citizens  in  third  countries  were  issued  by  the 
Council  in  2006  and  2008.  The  2006  guidelines  make  little  reference  to  Decision 
96/409/CFSP,  and  the  main  aim  was  to  define  what  is  meant  by  "accessible  permanent 
representation"  and  "accessible  honorary  consuls  competent  for  consular  matters"  in  the 
context of further implementing Decision 95/553/EC, as well as providing quick, immediate 
and  practical  consular  assistance  to  EU  citizens  in  need  in  third  countries.  Consultation 
through  interviews  has  revealed  little  awareness  of  the  existing  guidelines  on  consular 
protection.  Hence  the  option  of  developing  further  guidelines  as  a  soft  measure  is 
questionable.  

56  

Guidelines  on  Consular  Protection  of  EU  Citizens  in  Third  Countries  (10109/2/06  Rev  2)  and 
Guidelines for further implementing a number of provisions under Decision 95/553/EC (11113/08).  It 
is noted that both sets of guidelines are legally non-binding. 

59 

 
 
 
 
 
                                                           
A2.4  Other stakeholders’ views on ETD 

Other  stakeholders  other  than  Member  States  gave  their  opinion  on  the  ETDs  although 
generally it can be said that the issue is not very contentious, and none reporting any problems 
or significant  costs with the ETDs.  Most consultees, with  a few exceptions, confirmed that 
they are familiar with the common format EU ETD, but none of them considered it to create 
significant costs and/or benefits to their organisations.  

On the specific aspects of coherence, consultation with trade associations for this study sought 
views  on  aspects  of  coherence  with  other  legislation,  in  particular  the  Package  Travel 
Directive, but none has been highlighted. Moreover, tour operators have highlighted that the 
new package travel directive puts little onus on them in terms of securing an ETD57. Thus, the 
implications  of  both  Directive  and  Decision  acting  together  on  travel  operators  are  not 
expected to be significant. 

Airlines  companies  did  not  highlight  any  particular  aspects  of  concern  with  regard  to  EU 
ETDs nor did they have strong views about their security features that could be regarded as a 
minimum. 

Citizens’ and consumer associations were quite positive about the existence of EU ETD but 
they could not provide specific estimates of costs and benefits.  Some were keen to highlight 
the lack of awareness.  

The following tables summarises some of the statements from other relevant stakeholders. 

57  

Under  Article  16  of  Directive  (EU)  2015/2302  of  the  European  Parliament  and  of  the  Council  of  25 
November  2015  on  package  travel  and  linked  travel  arrangements,  amending  Regulation  (EC)  No 
2006/2004  and  Directive  2011/83/EU  of  the  European  Parliament  and  of  the  Council  and  repealing 
Council  Directive  90/314/EEC,  the  organisers  will  provide  appropriate  information  on  consular 
assistance and will help make alternative travel arrangements, but this does not mean that the organiser 
has to arrange or pay for the ETD. 

60 

 
 
 
                                                           
Stakeholders’ views on EU ETD (examples of replies received during consultation) 

Citizens/consumer association 

ETD’s and this possibility is really great and that really helps EU citizens when traveling 
and when they are in distress.  

Many of our citizens do not know […] what ETD is and that our government should invest 
more into informing citizens and raising their awareness about that possibility. 

I had not come across this – ETD is not a consumer issue[…] 

Yes, we are aware about the document but we have no experience with it. 

[…] we are aware of the ETD and some of our members have had the benefit of using it 
[…] but in general, the EU ETD is a very helpful instrument for European citizen in 
distress. 

Airlines 

As an airline, we are familiar with ETD common format and have no doubts when 
accepting on flights passengers who are having ETDs in their hands 
[…]No additional cost till this day 

Tour operators 

Currently,  there  is  no  obligation  for  TO’s  to  provide  direct  assistance  in  case  the  client 
has lost their travel documents during their stay abroad […]We do not see the requirement 
for the organizers to secure an ETD for a traveller. It is giving information and assisting, 
if possible, to get to the body who gives the EDT. 

We never had any experience with ETDs but we generally inform our passengers they will 
need a supporting document from the police concerning the loss or theft of documents and 
after that a declaration or document from the embassy in order to travel back.“ 

In the new PTD  assistance is  required but  to  decide to  what extent the T/O needs  to  act 
must be on a case by case basis 
Insurance companies 

I know that in case of loss of passport or visa our citizen can go to our embassies where 
they  can  get  travel  document  but  not  that  there  is  some  common  format  for  these  travel 
documents. We didn’t have any experience in the company with these cases. 

61 

 
 
 
 
 
A2.5  Full list of Consultees 

Consultees’ Names 

MS 

Name 

Competent 
authority/ 

Passport offices 

Border 
control/Passport 
offices 

Ministry of Foreign Affairs (EE);  
MFA (NL) 
Danish Ministry of Foreign Affairs (DK) 
Ministry Foreign Affairs (PT) 
Ministry of Foreign Affairs and International Cooperation (IT) 
Ministry of Foreign Affairs (AT) 
MFA (PL) 
MFA (SL) 
Ministry Of Foreign And European Affairs (HR) 
Ministry de l'Europe et des affaires Estrangers (FR) 
Ministry of Foreign Affairs of the Republic of Bulgaria (BG) 
Ministry Of Foreign Affairs And Cooperation (ES) 
Ministry of Foreign and European Affairs (SK) 
Ministry Of Foreign Affairs (LV) 
Home Office/Her Majesties Passport Office (UK) 
MFA (CZ) 
Federal Public Service Foreign Affairs (BE) 
Department of Foreign Affairs and Trade IE) 
Ministry for Foreign Affairs (SE) 
Ministry for Foreign Affairs Luxembourg (LU) 
Ministry for Foreign Affairs (FI) 
MFA (RO) 
MFA (LT) 
MFA (CY) 
Frontex 
Interpol 
Passport Office, Identity (MT) 
Border Guard of Finland (2) 
BM.I (AT) 
Cypriot Police (CY) 
DGPN-DCPAF (FR) 
Police and Border Guard Board (EE) 
Border Guard Poland (PL) 
State Border Guard (LV) 
State  Border  Guard  Service  under  the  Ministry  of  Interior  of  the 
Republic of Lithuania (LT) 
Slovenian Border Police (Sl) 
Director of Serviço de Estrangeiros e Fronteiras Marina (PT) 
Greek police (EL) 
Swedish National Forensic Centre, the Swedish Police Authority (SE) 
IT Forensics, Documents (DE) 
Directorate General Border Police (BG) 
Serviço de Estrangeiros e Fronteiras Marina Portugal (PT) 
Ministry of Interior (Border Control) (HR)  

62 

 
 
 
 
 
Tour operators, 
travel agents & its 
associations 

Airline companies 
& associations 

Insurance 
companies & 
associations 

Citizens/consumer 
associations 

Other (e.g. 
consulates, EU 
services, other 
ministries, third 
countries) 

ECTAA 
Irish Tour Operator Federation (IE) 
Estonian Travel and Tourism Association (EE) 
The Association of Finnish Travel Agents (SMAL / AFTA) 
Polish Tour Operators Association 
Ltd. Impro (LV) 
Chamber of Trade of Slovenia 
Bulway (BG) 
Caravelatur (PT) 
British Airways. 
KLM 
Board of Airline Representatives in the UK Ltd (BAR UK) 
Ryanair 
Airlines for Europe 
Air Baltic (LV) 
Groupama Bulgaria (BG) 

Eurohec Insurance (HR) 

Consumer Protection Board, Estonia (EE) 
Finnish Consumer’s Union (FI) 
Consumer Association Libertas (PL) 
Consumer Association of Slovenia (Sl) 
Associação Portuguesa para a Defesa do Consumidor (PT) 
3 individual citizens (Pl, ES, BG) 
Croatian Association for Consumer Protection (HR) 
ICAO  
EEAS 
Italian mint 
Consular  Officer  |  British  Embassy  |  Santo  Domingo|  Dominican 
Republic 
Consular office of Spain in Peru, Lima 
DG Home 
State Department of Tourism Internal Administration Division (LT) 
Indonesian embassy in London 
Chamber of Commerce and Industry of Slovenia  
Gemalto 
US mission to the EU 

63 

 
 
 
 
 
A2.6  The Open Public Consultation (OPC) 

Between 12 September and 5 December 2017, the European Commission carried out an open 
public consultation (OPC) to collect views on EU Emergency Travel Documents (EU ETD). 
The  Commission  sought  views  from  EU  citizens,  their  family  members,  businesses, 
organisations,  academics  and  any  stakeholders  concerned  with  EU  citizenship  and  free 
movement.  The  results  of  this  consultation  were  intended  to  inform  the  Commission’s 
assessment of the scope for introducing specific action at EU level related to EU ETDs. 

Headline figures from OPC 

A  very  limited  number  of  replies  were  received.  23  EU  citizens,  5  administrations  and  3 
organisations from 14 Member States responded to the questionnaire.  

Respondents were very mobile, with over 65% travelling outside the EU at least once a year 
or more. 

74% of respondent citizens hold ID cards, whilst only 4% uses their ID card to travel outside 
the EU, against 96% who use their passport. 

Only 26% of the respondents were not aware of the right to seek help from the embassy or 
consulate from another EU country. Of the respondent citizens, only 4% have ever requested 
the assistance of the embassy or consulate of an EU country different than their own. 52% of 
the respondents  were  aware of the existence of  an EU ETD that embassies or consulates of 
any other EU country can issue to EU citizens in such a situation. An additional 3% was also 
aware,  but  only  after  it  had  been  provided  with  an  EU  ETD  from  an  EU  country  different 
from their one of origin. None of the respondents has ever been provided with an ETD by an 
EU country different from their own. 

The vast majority of the respondents, 84%, believed that the EU ETD provides genuine help 
to EU citizens in distress. 

Do you believe that the EU ETD provides genuine help to 
EU citizens in distress? 

No Answer

3,23% 

No

3,23% 

I do not know

9,68% 

It is neutral

0% 

I believe so

48,39% 

I strongly believe so

35,48% 

0,00% 10,00% 20,00% 30,00% 40,00% 50,00% 60,00%

64 

 
 
 
Regarding  objectives  to  improve  the  current  rules,  74%  of  the  respondents  regarded 
improving the recognition and acceptance of EU ETDs around the world to be very important. 
The  second  most  important  objective  is  simplifying  the  formalities,  which  60%  of  the 
respondents deem to be very important. These two objectives are followed by modernising the 
security features of the EU ETD (40%), and reducing costs (31%). 

Concerning  costs,  58%  of  the  respondents  would  be  inclined  to  pay  higher  fees  for  an  EU 
ETD  with  increased  security  features.  42%  of  the  respondents  were  of  the  opinion  that  a 
standard fee should be charged for an EU ETD by all EU countries worldwide, against 32% 
who felt that the fees charged should be established by the EU country itself.  

71% of the respondents with an opinion felt that EU ETD should always be issued, over that 
of  a  national  ETD.  19%  felt  that  this  would  be  a  matter  for  the  issuing  country  to  decide 
which ETD it wants to issue to the citizens.  

84%  of  the  respondents  agreed  that  EU  citizens  living  or  travelling  in  a  country  within  the 
Union should also be able to receive an EU ETD both inside and outside the EU, if their home 
country has no embassy or consulate there and their travel document is lost, stolen, destroyed 
or unavailable. 

65 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

A3.1  Practical implications of the initiative 

Member States public authorities  

The  increased  security  of  the  new  document  benefits  Member  States  through  increased 
security of EU borders and greater acceptance of the document issued to  their citizens. The 
new document would also facilitate border controls  by being  machine-readable. The cost  of 
the  use  will  remain  low,  as  no  new  equipment  is  required  and  the  new  format  is  only 
marginally more expensive to produce than the current one. The costs of training staff to use 
the new format is also considered to be low. 

The Member States could also benefit from using the new format for their own citizens and 
within  the  EU.  A  more  secure  EU  ETD  format,  which  is  multilingual  and  produced  at  EU-
level,  can represent  a cost-efficient  alternative to Member States  considering replacing their 
outdated national ETDs. 

EU citizens 

Due to this initiative, citizens will derive greater value from their status as EU citizens.  There 
would be a clear obligation to issue the EU ETD to them, in line with the relevant acquis on 
citizens' rights. Elements considered under the proposed measure are expected to reduce the 
time that citizens spend receiving assistance from consular services of other MS, in particular 
due to improved coordination and cooperation procedures between the MS and the deadlines 
applicable  to  the  exchange  of  information  and  issuance  of  documents.  Under  the  proposed 
measure,  the  assisting  MS  shall  provide  the  unrepresented  citizens  with  an  EU  ETD  at  the 
latest the next working day following the confirmation of the applicant’s nationality (although 
exceptions may apply).  

Assuming each unpresented citizen saves, conservatively, a day in applying and receiving an 
EU  ETD  and  that  the  opportunity  costs  of  this  is  the  average  daily  wage  of  €93    and,  the 
savings  based  on  the  1000  annual  cases  per  year  can  be  estimated  at  €93,000  across  all 
citizens. 

Due  to  the  improved  security  features  and  the  modernised  EU  ETD,  the  risk  for  citizens  to 
receive sub-optimal assistance will be reduced. Improving security features, as well as the role 
of the European External Action Service in promoting the document, is expected to increase 
the acceptance of the EU ETD around the world (something that was considered to be “very 
important”  by  19  of  the  25  Member  States  that  responded  to  this  question  in  the  survey). 
Consequently, there will be reduced inconvenience when travelling with an EU ETD.  

On  the  other  hand,  such  benefits  will  have  to  be  compared  with  the  additional  costs  of  a 
potentially more expensive but more secure EU ETD. However, the manufacturing costs are 
not expected to rise significantly if measures are undertaken to guarantee economies of scale 

66 

 
 
 
during the tendering process. The benefits may be larger for those citizens with lower level of 
representation around the globe. 

Impacts on other stakeholders  

Some benefits from an improved EU ETD are expected to accrue to businesses, as employees 
may be able to return to work more quickly if the EU ETD is more widely accepted and more 
quickly issued; with respect to airline carriers, compensation claims may reduce if citizens are 
able to travel without incurring additional costs.  

A3.2  Summary of costs and benefits 

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

EUR 93,000 

Amount 

Direct benefits 

Comments 

Opportunity costs of 
EUR 93/day in saved time 
per case. The time savings 
based on 1000 annual cases 
per year can be valued at 
EUR 93,000 across all 
citizens. 

Quicker, more reliable processing of 
citizens travelling on EU ETDs at the EU 
borders, reduced administration 

Not quantifiable – border 
authorities do not collect 
such data. 

Beneficiaries: border 
authorities, citizens 

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 – the precise 
increase in the level of 
security within the EU 
cannot be quantified. 
Beneficiaries: Citizens, 
public administrations, 
businesses. 

Fewer rejections of citizens 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. 

Indirect benefits 

Improved security 
within the EU and 
at its borders 

Reduction in document fraud related to 
poor document type (forgery, tampering, 
impostor, reused document blanks). 

67 

Description 

Citizens – annual 
costs savings 
from deadlines on 
issuance  

Cost savings for 
accelerated 
document checks 
at EU external 
borders due to 
machine 
readability of the 
document 

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

 
 
 
 
Facilitated access 
to the right to 
equal treatment 
on consular 
protection for 
unrepresented EU 
citizens  

Improved document will increase the 
acceptance and make the exercise of the 
right to equal treatment on consular 
protection of unrepresented citizens 
quicker, easier and more secure. This 
will in turn have a positive effect on the 
perceived benefits of EU citizenship. 

Not quantifiable – the precise 
increase in the level of the 
perceived benefits of EU 
citizenship cannot be 
quantified. 
Citizens. 

II. Overview of costs – Preferred option 

Citizens/Consumers  

Businesses 

Administrations 

One-off  Recurrent  One-off  Recurrent  One-off  Recurrent 

Transposition 
of the new 
legislative 
measure   

Direct 
costs 

Indirect 
costs 

- 

- 

Cost of new 
EU ETD   

Direct 
costs 

 0 – 8 
Euros* 

Indirect 
costs 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Negligible 

Negligible 

- 

- 

EUR 
40,000** 

EUR 
8,000*** 

EUR 
197,500 + 

Not 
quanti-
fiable++ 

*  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. 

** Based on the initial order of 5000  EU ETDs for stocking purposes 

***  Based  on  the  annual  issuance  of  1000  EU  ETDs  a  year  at  8  euro  per  piece  estimated 
production cost. In the absence of reliable data on past issuance, these costs cannot be divided 
by Member State. 

+ Based on the average training costs (see table 6-2 in Section 6 of the Impact Assessment)for 
likely distribution by Member State 

++ It is likely future trainings be integrated in regular training programme of consular staff, 
making it harder to quantify in isolation this element 

68 

 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

A4.1  Description of methodology 

The  approach  has  included  quantification  of  impacts  (to  the  extent  possible),  including 
monetisation based on data obtained from consultation and literature review (e.g. on number 
of  ETDs,  fees  and  hours  spent  to  complete  an  individual  ETD,  etc.).    The  following  table 
summarises  the  approach  to  estimate  the  costs  and  sources  of  data.  The  quantification  was 
then  based  on  the  Standard  Cost  Model  (SCM,  as  described  in  the  Better  Regulation  Tool 
#53) using the formula: 

Σ P x Q  

where P (for cost of processing one ETD) = Tariff (hourly wage rate for appropriately 
qualified personnel) x Time (number of hours spent); and 

where Q (for Quantity) = Number of ETDs processed 

The following Table summarises the type of costs and benefits considered under the Options.  

Costs/benefits 

Table A4-1: Assessing costs and benefits from the Options 
Stakeholders 
affected 
MS 
authorities 

Costs of changing 
laws/developing regulation 
Training costs 

Approach to 
measuring 
Costs of consultation  

Cost of blank forms 

Costs/benefits related to staff 
time to provide new ETDs 

Unrepresented 
Citizens  

Facilitated access to the right 
to consular protection 

New application fees 

Personnel costs/e-
Learning 
Average cost of 
buying one form by 
number of forms 
Numbers of ETDs 
issued 
Average time required 
to process application 
and value of staff time 
Greater clarity on 
rules and application 
process  
Numbers of ETDs 
issued and fees 

Impacts from changes in 
application times and issuance 

Savings from reduced risk of 
changes to travel 
arrangements/reduced problems 

Average daily wage as 
opportunity costs 
savings 
Problems reported 
when travelling 
avoided 

69 

Source of data 

Evaluation study/ 
consultation  
Literature 
review/assumptions 
Consultation  

Evaluation study, 
based on SCM. 

Evaluation study and 
consultation 

Evaluation study/ 
Consultation with 
Italian mint and 
Gemalto 
Evaluation study, 
based on SCM 

Evaluation 
study/consultation 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table A4-1: Assessing costs and benefits from the Options 
Stakeholders 
affected 

Approach to 
measuring 

Costs/benefits 

Border 
authorities  

when travelling 
Costs/savings from 
processing/verifying ETDs (for 
Third country and Member 
States) 

Average cost of 
training staff members 
in recognising/time 
validating EU-ETDs 

Source of data 

Evaluation study/ 
Consultation 

Some of the above costs and benefits have not been subject to quantification owing to the lack 
of data to facilitate such assumptions. Such costs and benefits include: 

  Cost savings for accelerated document checks at EU external borders due to machine 

readability of the document; 

  Reduced hassle costs through improved acceptance of more secure document 

(recurrent); 
Improved security within the EU and at its borders; 

 
  Facilitated access to the right to equal treatment on consular protection for 

unrepresented EU citizens. 

A4.2  Calculation of costs and benefits under Option 2  

Option 2 will involve replacing the existing EU format with a better and more secure EU ETD 
that will apply across all Member States.  

The  main  changes  will  accrue  to  Member  States  currently  issuing  national  ETDs  to 
unrepresented  citizens,  namely  France,  the  UK  and  Germany.  These  countries  may  include 
larger hassle costs and costs incurred from becoming familiar with new legislation. Training 
is expected to incur some costs although it could be minimised under e-Learning and if this is 
tailored similar to, or together with, that of the existing visa systems. The average costs based 
on SCM is estimated at €197,500. 

The  costs  of  manufacturing  the  new  forms  are,  based  on  early  consultation,  estimated  to 
amount to a maximum of €8 per piece. The one-off costs of buying a stock for Member States 
and based on a total of 5,000 are estimated at €40,000. 

Citizens will save time under Option 2. It has been assumed that the number of EU ETD to be 
issued under Option 2 is 1,00058 per year. The opportunity costs (or benefits) to citizens is the 
average  daily  wage.  Estimated  at  €93,  the  savings  are  estimated  at  around  €93,000  for  all 
citizens. The new forms will be more expensive however, although EU ETDs could be issued 
for free to citizens in crisis situations.  

58  

These  would  include  EU  ETDs  issued  by  Member  States  that  currently  issue  national  ETDs  to 
unrepresented citizens (France, Germany and the UK). 

70 

 
 
 
 
 
 
 
 
 
                                                           
A4.3 Calculation of costs and benefits under Option 3  

This option differs primarily in introducing the highest possible level of security – biometric 
chips – in the EU ETDs. 

Biometrics  are  currently  used  in  some  travel  documents,  for  instance  in  all  Member  States 
passports,  some  national  identity  cards59  and  also  in  the  European  Union  laissez-passer.  
Consultations undertaken for this Impact Assessment on the EU diplomatic laissez-passer has 
revealed that the cost of equipment per issuing post is estimated between 10 000 and 15 000 
euros (similar estimates  have been provided by  Gemalto). Currently, only  a minority of EU 
Member States' consulates have such equipment available, with many Member States treating 
their requests for passports either domestically or at several regional centres in the world. 

Besides the cost of equipment needed for personalisation, there is also the cost of the new EU 
ETD  booklet.  Although  it  is  difficult  to  the  estimate  the  exact  cost,  it  is  likely  to  be  in  the 
range of 60-100 euros per printed copy. These costs are likely to be passed on to consumers, 
who would benefit more if they continue their journeys but less so if they return to their home 
destination. 

A4.4  Limitations and robustness of findings 

The approach has included different methods of data collection. A first review of the literature 
was undertaken in the summer of 2017, knowing that undertaking consultation in the summer 
would have been difficult and also in order to avoid stakeholder fatigue. Most of this literature 
review included internet searches on ministerial websites and other national statistics. Overall, 
statistics on the number of ETDs issued was found to be very sparse. Similarly, data on the 
costs  of  issuing  the  ETDs  are  not  publicly  available.  As  a  result,  the  questionnaire  was 
developed to address such gaps and allowed for quantification of costs and benefits.  

However, the findings from  the survey have revealed significant  differences in  terms  of the 
time spent on different activities related to issuing ETDs. Consultation has suggested that the 
processing  time  from  beginning  of  the  ETD  application  process  to  its  end  can  be  anything 
from a couple of hours to five days; mostly spent on training and obtaining clearance. This is 
expected  to  represent  the  total  time  that  elapses  since  the  application  starts  and  not  active 
work  by  the  consulate.  As  a  result,  the  assumption  is  that  a  lower  bound  is  half  a  day  and 
upper bound is one day on average to issue an EU ETD (including receiving clearance from 
MS of origin). Both of the Options considered under this Impact Assessment are expected to 
reduce the amount spent on issuing an EU ETD. 

It  needs  to  be  said  that  although  the  targeted  consultation  with  trade  associations  and 
companies carried out for this evaluation has been restricted to a limited number, some of the 
responses include the main players in the field. These include companies like British Airways, 

59  

E.g. Belgium, Croatia, Czech Republic, Estonia, Finland, Portugal, the Netherland, Slovenia, Spain and 
Sweden. 

71 

 
 
 
 
                                                           
KLM, and associations such as the European Travel Agents, Airlines for Europe, and the Tour 
Operators’ Associations.  These associations in particular were able to speak on behalf of their 
members  that  include  business  operators  in  all  Member  States.  Thus,  the  responses  show  a 
good spread of Member States’ coverage, including associations operating at European level 
and representing the main players in the EU.  

Furthermore,  the  members  of  the  Expert  Group  on  the  rights  of  unrepresented  citizens  to 
consular  protection  abroad  have  also  confirmed  to  the  consultants  that  they  have  consulted 
and  gathered  data  from  their  own  missions  abroad  and  related  authorities  (such  as  border 
control). As a result of this, it is believed that the data collected from the consultation work 
are robust enough to inform the impact assessment. 

A4.5  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. 

There  are  three  different  options  (including  the  baseline)  which  are  assessed  and  compared 
against  8  different  criteria/sub-criteria.  One  option  might  be  better  than  another  option 
according to one criterion (e.g. efficiency) but worse according to another (e.g. effectiveness). 
Thus, there is no solution optimising all criteria simultaneously and therefore a compromise 
solution  has  to  be  found.  The  multi-criteria  problem  is  described  the  following  way 
(Giuseppe, 2003; Giuseppe, 2017): 

A) 

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. 

For the analysis we have assumed also the existence of 4 scenarios for the weighting: 

1.  1 neutral scenario in which the headline criteria are equally weighted  
2.  1  neutral  scenario  in  which  all  criteria/sub-criteria  are  equally  weighted  (higher 

weight is given in the aggregated effectiveness headline criterion) 

3.  1 scenario focusing on meeting security requirements with significant weight for 

the sub criterion 2  

4.  1  scenario  focusing  on  achieving  Legal  certainty  (enforceability,  plus  coherence 

with CP Directive) with significant weight for the sub criterion 1 

Taking as an example the case here, table 1 presents per scenario the impact matrix where all 
the possible options (N=3) are assessed against the criteria (M=8). The impact matrix shows i) 
the  number  of  criteria  in  favour  of  a  given  option;  ii)  the  weight  attached  to  each  single 
criterion per scenario; 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.  

𝑤𝑚

𝑀
𝑚=1

72 

 
 
 
 
Table A4-2:  Comparison of the options  
Scenario 
2 

Scenario 
1 

Criteria 

Scenario 
3 

Scenario 
4 

Option 
Baseline 

Option 1 
– ETD 
sticker 

Option 
2 – bio-
metrics 

Effectiveness towards specific objectives 
Improve legal certainty 

5% 

12.5% 

5% 

25% 

Improve security and 
reduce document fraud 
Improve acceptance of 
EU ETD 
Simplify conditions for 
formalities and issuance  
Improve cooperation 
and cooperation among 
Member States  

Efficiency 

Costs 
Benefits 
(COSTS VS 
BENEFITS) 

5% 

5% 

5% 

5% 

12.5% 

35% 

10% 

12.5% 

12.5% 

12.5% 

5% 

5% 

5% 

5% 

5% 

5% 

25% 

12.5% 

20% 

20% 

0 

0 

0 

0 

0 

0 
0 
0 

++ 

+ 

+ 

+ 

++ 

-/0 
+ 
0/+ 

Coherence60 
Proportionality61  
Note:  The evaluation is based on a scale of 13 steps (including zero) from very limited 
impact (---) to very high impact (+++) 

12.5% 
12.5% 

15% 
10% 

15% 
15% 

25% 
25% 

++ 
++ 

0 
0 

++ 

++ 

++ 

-/0 

++ 

---/-- 
++ 
-/0 

++ 
- 

"0" indicates no change (i.e. neutrality) 
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  
2.  Ranking of options in a complete pre-order  

B) 

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))

,  

60  
61  

Coherence in relation to the Consular Protection Directive and Fundamental Rights. 
The  proportionality test ensures that any policy  measure is limited to  what is necessary  to achieve its 
objectives.  

73 

 
 
 
 
 
 
 
 
 
 
 
                                                           
 
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  case,  options  are  compared  pairwise.  For  each 
comparison (e.g. OP1 versus the baseline – hereafter, abbreviated as "1B") all the weights are 
summed  for  the  criteria  where  Option  1  is  preferred  over  the  baseline  (in  case  of  option  1 
being indifferent of baseline half of the weight is given).  

Tables A4-3:  Pair-wise comparisons 

Pair-wise comparison of options [Policy Options (N) = 3; Criteria (M) = 8] scenario 1 

B 
0 
1 

1 
0 
0 

0.45  0.275 

2 
0.55 
0.725 
0 

B 
1 
2 

Pair-wise comparison of options [Policy Options (N) = 3; Criteria (M) = 8] scenario 2 

B 
0 
1 

1 
0 
0 

0.625  0.4375 

2 
0.375 
0.5625 
0 

B 
1 
2 

Pair-wise comparison of options [Policy Options (N) = 3; Criteria (M) = 8] scenario 3 

B 
0 
1 

1 
0 
0 

0.65  0.525 

2 
0.35 
0.475 
0 

B 
1 
2 

Pair-wise comparison of options [Policy Options (N) = 3; Criteria (M) = 8] scenario 4 

B 
0 
1 

1 
0 
0 

0.60  0.375 

2 
0.40 
0.625 
0 

B 
1 
2 

C) 

Ranking of options 

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., 

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

𝜑𝑠 =   ∑ 𝑒𝑗𝑘 , 

74 

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

𝒓∗ ⇔ 𝜑∗ = 𝑚𝑎𝑥 ∑ 𝑒𝑗𝑘  𝑤ℎ𝑒𝑟𝑒 𝑒𝑗𝑘 ∈ 𝑅. 

In  our  case,  policy  options  can  be  ranked  in  3!  (=6)  ways.  For  example,  the  score  for  the 
ranking "B12" is the score of B1 plus those of B2 and 12 (all ordered pairs from left to right). 
The optimal ranking is  the one with  the maximum  likelihood score. Therefore the preferred 
option is OP1. 

Table A4-4:  Ranking of Policy Options per scenario 

Ranking 

POLICY PAIRINGS 

Score  

B12 

B21 

1B2 

12B 

2B1 

21B 

B1 

B2 

1B 

12 

2B 

21 

B2 

B1 

12 

1B 

21 

2B 

12 

21 

B2 

2B 

B1 

1B 

S1  
1.275 

S2 
0.9375 

S3 
0.825 

S4 
1.025 

0.825 

0.8125 

0.875 

0.775 

2.275 

1.9375 

1.825 

2.025 

2.175 

2.1875 

2.125 

2.225 

0.725 

1.0625 

1.175 

0.975 

1.725 

2.0625 

2.175 

1.975 

From the sensitivity analysis we could summarize the followings: 

1.  Option  1  is  the  preferred  option  when  we  use  a  neutral  weighting  for  all  relevant 

criteria  (scenario 1and 2) and also for the scenario 4 

2.  Option 2 is the preferred option when the sub criterion for security is more than 35%  

Finally, when the aggregate weighting of criterion 2 and 3 (Wsecurity and fraud + Wimprove acceptance ) 
surpass  the  aggregate  weighting  of  criterion  4  ,  6  and  8    (Wsimplification+  Wefficiency+ 
Wproportionallity option 2 become favourable.  

75