COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 767/2008, (EC) No 810/2009, and (EU) No 2017/2226 of the European Parliament and of the Council, Council Regulations (EC) No 1683/95, (EC) No 333/2002, (EC) No 693/2003 and (EC) No 694/2003 and Convention implementing the Schengen Agreement, as regards the digitalisation of the visa procedure
Date: 2022-04-27
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU visa policy, Schengen Agreement, admission of aliens, border control, data processing, digitisation, exchange of information, external border of the EU, foreign national, information system

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 27.4.2022  SWD(2022) 658 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 767/2008, (EC) No 810/2009,  and (EU) No 2017/2226 of the European Parliament and of the Council, Council Regulations (EC) No 1683/95, (EC) No 333/2002, (EC) No 693/2003 and  (EC) No 694/2003 and Convention implementing the Schengen Agreement, as regards the digitalisation of the visa procedure {COM(2022) 658 final} - {SEC(2022) 202 final} - {SWD(2022) 659 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 5 

1.1.  General Background .................................................................................................................. 5 
Scope of the initiative ................................................................................................................ 6 
1.2. 

2. 

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

2.1.  What are the problems? .............................................................................................................. 7 
2.2.  What are the problem drivers? ................................................................................................. 12 
2.3.  How will the problem evolve? ................................................................................................. 15 

3.  WHY SHOULD THE EU ACT? .......................................................................................... 15 

3.1. 
3.2. 
3.3. 

Legal basis ............................................................................................................................... 15 
Subsidiarity: Necessity of EU action ....................................................................................... 15 
Subsidiarity: Added value of EU action ................................................................................... 16 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 16 

4.1.  General objective ..................................................................................................................... 16 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................... 18 

5.1.  What is the baseline from which options are assessed? ........................................................... 18 
5.2.  Description of the policy options ............................................................................................. 20 
5.3.  Options discarded at an early stage .......................................................................................... 27 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 27 

6.1. 
6.2. 
6.3. 
6.4. 

Economic impact ...................................................................................................................... 27 
Social impact ............................................................................................................................ 30 
Environmental impact .............................................................................................................. 33 
Impact on EU tourism and GDP .............................................................................................. 34 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................. 35 

Effectiveness ............................................................................................................................ 35 
7.1. 
7.2. 
Efficiency ................................................................................................................................. 37 
7.3.  Other impacts ........................................................................................................................... 40 

8. 

PREFERRED OPTION ......................................................................................................... 45 

8.1.  Why O4 is preferred policy option ........................................................................................... 45 
Sub-options .............................................................................................................................. 54 
8.2. 
8.3.  Application of the one-in-one-out approach ............................................................................ 57 
8.4. 
Sensitivity analysis on the preferred option ............................................................................. 57 
8.5.  REFIT (simplification and improved efficiency) ..................................................................... 58 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ................... 58 

ANNEX 1 – PROCEDURAL INFORMATION ........................................................................... 60 

ANNEX 2 – TARGETED AND PUBLIC CONSULTATION ..................................................... 65 

1. Stakeholder consultation .................................................................................................................. 65 
2. Analysis of the consultation with the Member States ...................................................................... 79 

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3. Questionnaires: Consultation with Member States and Public Consultation ................................... 91 

ANNEX 3 – WHO IS AFFECTED AND HOW? ....................................................................... 104 

ANNEX 4 – METHODOLOGICAL NOTE ON COSTS AND BENEFITS .............................. 109 

ANNEX 5 – GLOBAL TRENDS ON VISA PROCESS DIGITALISATION............................ 111 

ANNEX 6 – SENSITIVITY ANALYSIS ON THE PREFERRED OPTION ............................. 116 

1. 
2. 
3. 
4. 
5. 

Decrease in number of visa applications ............................................................................... 116 
Increase in number of visa applications ................................................................................ 120 
Delay in the roll-out of the application platform ................................................................... 121 
Change in time needed to intake a visa application .............................................................. 121 
Gradual realisation of administrative benefits over the 2025-2029 period ........................... 124 

ANNEX 7 – COMPARISON OF THE POLICY OPTIONS ...................................................... 126 

Option 2: Minimal EU legislative changes on the application & digital visa .................................... 126 
Option 3: Optional EU digital application platform & digital visa .................................................. 128 
Option 4: Mandatory EU digital application platform & digital visa .............................................. 131 
Option 5: Online biometric enrolment & digital visa ....................................................................... 134 

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Term or acronym 

Meaning or definition 

Glossary 

BCP 
CBA  
EBCGA  
EDPS  
EES  
ESP  
ETIAS  
EU  
eu-LISA  

FRA  
GDPR  
IT  
Member States  

MEV  

N/A  
Privacy enhancing 

Schengen evaluation 

Service fee 
SIS 

TCN  

TFEU 
VAC  

VIS  

VIS Regulation 

Border control post 
Cost-benefit analysis  
European Border and Coast Guard Authority  
European Data Protection Supervisor  
Entry-Exit System  
External Service Provider  
European Travel Information and Authorisation System  
European Union  
European Union Agency for the Operational Management of Large-Scale 
IT Systems in the Area of Freedom, Security and Justice  
Fundamental Rights Agency 
General Data Protection Regulation  
Information Technology  
EU  Member  States  applying  the  common  visa  policy  in  full  (all  EU 
Member States with the exception of Bulgaria, Croatia, Cyprus, Ireland 
and  Romania)  as  well  as  the  Schengen  associated  countries:  Iceland, 
Liechtenstein, Norway and Switzerland. As in the Visa Code, “Member 
States” in this report will designate Member States 
Multiple-entry visa (short-stay visa allowing for an unlimited number of 
entries to the Schengen area during its period of validity and respecting 
the overall maximum period of stay, i.e. 90 days in any 180-day period) 
Not available  
Privacy-enhancing computation refers to a group of various technologies 
that help to achieve the highest level of private data protection. 
periodical  evaluations  of  Member  States  on  the  application  of  the 
Schengen acquis in the field of the common visa policy, in  accordance 
with Council Regulation (EU) No 1053/2013 
Fee paid to the ESP for collecting the application and biometric identifiers 
Schengen Information System 

Third  Country  National  (i.e.  citizen  of  a  country  outside  the  Schengen 
area) 
Treaty on the Functioning of the European Union 
Visa  Application  Centre  (i.e.  the  facility  operated  by  external  service 
providers)  
Visa Information System  

Regulation (EC) No 767/2008 of the European Parliament and the Council 
of  9  July  2008  concerning  the  Visa  Information  System  (VIS)  and  the 
exchange  of  data  between  Member  States  on  short-stay  visas  (VIS 
Regulation) 

3 

 
 
 
 
Visa Code 

Visa fee 

Visa 

Regulation (EC) No 810/2009 of the European Parliament and the Council 
of 13 July 2009 establishing a Community Code on Visas (Visa Code) and 
Regulation (EU) 2019/1155 of the European Parliament and of the Council 
of 20 June 2019 amending Regulation  (EC) No  810/2009  establishing a 
Community Code on Visas (Visa Code) 

fee paid to the consulate for processing the visa application 

short-stay visa as defined in Article 2 (2)(a) of the Visa Code (authorising 
its holder to stay in the Schengen area for up to 90 days within any 180-
day period) 

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1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1.  General Background 

The  March  2018  Commission  communication1  on  visa  policy  took  on  board  the  idea  of  “e-visas” 
following earlier discussions in 2017 under the Estonian Presidency. The communication announced a 
feasibility study on digital visa procedures and the intention to assess options and promote pilot projects 
which would prepare the ground for future proposals.  

When revising the EU Visa Code in 2019, the EU co-legislators explicitly stated the aim of developing 
a  common  solution  in  the  future  to  allow  Schengen  visa  applications  to  be  lodged  online,  thereby 
making full use of the recent legal and technological developments2. The COVID-19 pandemic, which 
led to the slowing down of Schengen visa operations worldwide partly due to the difficulty of receiving 
visa applicants in consulates, prompted Member States to call upon the Commission to speed up work 
on  digitalisation  of  visa  procedures.  The  New  Pact  on  Migration  and  Asylum  proposed  by  the 
Commission on 23 September 2020 set the objective of making the visa procedure fully digitalised by 
2025, with a digital visa and the ability to submit visa applications online.  

Given the various advantages offered by digitalisation of visa procedures (increased security, reduced 
administrative  costs,  growing  trend  toward  digitalisation),  large  visas-issuing  countries,  such  as 
Australia, New Zealand, UK, India or Russia, have already implemented digital visas for short stays 
on their territories as shown in Annex 5. The majority of these digital services are however more similar 
to the European Travel Information and Authorisation System (ETIAS). They have been introduced to 
either pre-screen visa exempt travellers prior to travel (Electronic Travel Authorisations) or to facilitate 
certain foreign nationals subject to visa requirements, in quickly and easily obtaining a short stay visa 
for specific purposes. Only Australia and New Zealand have fully digitalised the visa procedures for 
all applicants, irrespective of nationality or travel purpose.  

The initiative on visa digitalisation is included in the Commission Work Programme for 2021 (Annex 
I).  The  initiative  also  fits  with  the  general  EU  approach  to  encourage  the  modernisation  and 
digitalisation of public services and the Commission communication3 on the 2030 Digital compass: 
the European way for the digital decade.  

In this context, a decision was taken by the Commission to consider the proposal for the digitalisation 
of visa procedures as a new initiative and not as a revision of the Visa Code and of the VIS regulation. 
The initiative aims at modernising and simplifying the implementation of visa policy and is part of a 
broader effort to digitalise public administrations. The study on the digitalisation of visas procedures 
carried  out  in  2019  by  the  Commission  highlighted  the  potential  benefits  of  simplified  and  more 
modern visa procedures4. To do so, the initiative will only modify certain articles of the Visa Code and 

1 COM(2078)251. 
2 Recital 20 in Regulation (EU) 2019/1155. 
3 COM(2021)118. 
4 Study on the feasibility and implications of options to digitalise visa processing, 2019, available: https://op.europa.eu/s/pgU6  

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the VIS regulation as far as it is necessary to implement this initiative and will not touch other aspects 
of the Visa code and the VIS regulation not concerned by this initiative. 

The  digitalisation  of  the  visa  application  procedure  and  the  implementation  of  a  digital  visa  would 
benefit from several major developments in the field of visa and border policy: 

  The revision of the Visa Code in 2020 made it easier for regular travellers to apply for multiple-
entry  visas,  and  allowed  electronic  visa  applications  (used  by  a  few  Member  States)  and 
electronic signature (not used by Member States so far). 

  The revised VIS Regulation agreed by the co-legislators in December 20205.  
  The  European  Travel  Information  and  Authorisation  System  (ETIAS)6  is  part  of  the  Smart 
Border and Interoperability framework and introduces an online travel authorisation for third 
country  nationals  who  are  not  visa-required.  This  travel  authorisation  differs  from  the  visa 
procedure which requires submission of the biometrics and physical presence of applicants to 
mitigate the higher security risks of visa-required third countries.  

  The Entry-Exit System (EES) will be operational in 2022. The EES will require every traveller 
visiting the Schengen area for short stays to record his/her entry and exit at the external border 
crossing points allowing to detect over-stayers7.  

However, with the exception of the VIS, the harmonised rules governing the common visa procedures 
still largely relies upon physical presence of the applicant and physical documents. In spite of partial 
digitalisation efforts by Member States, applicants still have to print and sign the form and submit it in 
paper together with the supporting documents and travel document. The physical dimension of the visa 
sticker, which has to be affixed on the holder’s travel document or on a separate sheet in case the travel 
document is not recognised by a Member State, entails another set of challenges. 

1.2. 

Scope of the initiative 

The initiative focuses  on the short-stay visas application process  and the visa sticker. Although the 
examination and decision on the visa application are an important part of the visa application process, 
they fall outside the scope of this impact assessment. 

This initiative is focused on short-stay visas, but due to the existence of a common legal basis8 on the 
format of short-stay visas and long-stay visas, this initiative will also explore the material scope, i.e. 
whether to extend the two novelty of this initiative, the application platform and the digital visa, to 
long-stay visas, which are national visas allowing to stay on the territory of the issuing Member State 

5 The revised VIS regulation will allow more thorough background checks on visa applicants, close security information gaps through better information 
exchange between Member States, broaden the Visa Information System to include long-stay visas and residence permits, and will allow combatting 
abduction and trafficking of children by lowering the fingerprinting age for minors. Together with the other new and upgraded information systems, the 
new Visa Information System should be operational and fully interoperable by the end of 2023. 
6 ETIAS legal basis : https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018R1240.  
7  EES  will  be  interoperable  with  VIS  and  the  other  EU  information  systems  so  that  all  information  is  cross-checked  (e.g.  the  systems  will  provide 
information as to whether a visa holder has already a file in EES. 
8 Council regulation (EC) 1683/95 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31995R1683.  

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for a period longer than 90 days. The possibility to include long-stay visas in the material scope of this 
initiative is analysed in section 8.2 of this impact assessment.  

2.  PROBLEM DEFINITION 

2.1.  What are the problems? 

Citizens  of  102  third  countries  are  currently  required  to  hold  a  valid  visa  in  order  to  cross  the  EU 
external  borders9.  Visas  are  issued  by  Member  States  through  a  network  of  consulates  in  third 
countries10. The figure below shows the total number of short-stay and long-stay visas applications 
submitted and issued by Member States in 2019. In the projections used in this impact assessment11, 
the number of short-stay visas would increase until 2025 and stabilise at 17.8 million visas applied per 
year. 

Table 1: Total number of visa applications 2019  

Item 

Schengen visa applications submitted  

Long-stay visa applications submitted  

Schengen visas issued (including LTVs, 
MEVs) 

Long-stay visas issued  

Figure 

16 955 541 

  2 642 538 

15 022 255 

  2 448 004 

Source: EU statistics and data collected from Member States authorities 

The amended Visa Code has created the possibility for the digital submission and processing of visa 
applications (e.g. electronic signature for applicants), but most Member States only digitalised parts of 
the Schengen visa process12 and still rely heavily on paper-based procedures. This is because the whole 
visa process as envisaged by the Visa Code remains largely paper based and the obligation to issue a 
visa sticker has also constrained digitalisation efforts of Member States. 

The figure below describes the causes, problems and effects in relation to visa procedures identified in 
the context of this impact assessment.  

9 Annex I to Regulation (EU) 2018/1806 of the European Parliament and of the Council of 14 November 2018 listing the third countries whose nationals 
must be in possession of visas when crossing the external borders and Annex II listing those whose nationals are exempt from that requirement. 
10 Member States can agree bilaterally to be represented by another Member State in a third country through representation agreements. This means that 
not all Member States have consulates in all visa-required third countries. 
11 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en.  The  number  of 
visas issued was estimated to come back in 2023 to its pre-COVID level (16.9 million), then grows until 2025 where it would stabilise at 17.5 million 
until 2029. 
12 Cf. Annex 2 on the state of play of digitalisation of the visa application process across Member States. 

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Figure 1: The causes, problems and effects  

1.1.1.  Problems identified in relation to Member States 

The main problems identified in relation to Member States authorities dealing with visa application 
and visa issuing are: 

  The lengthy process and accumulating costs for consulates to manage, process and archive 
(and eventually destroying) paper documents. This problem is linked to practices of Member 
States  which  have  not  or  have  only  partially  digitalised  their  application  procedure. 
Additionally, current short-stay visas rules at EU level still allow the use of paper documents 
and  do  not  impose  any  digitalisation  obligation  to  Member  States.  This  contributes  to  a 
fragmented use of digitalisation tools by Member States and high costs associated with handling 
paper applications that need to be archived for at least two years before they can be destroyed. 
It is estimated that Member States would spend EUR 638.5 million on administrative burden 
in the period 2025-2029 under the baseline scenario (see table 4).  

  The  dependence  of  Member  States  on  external  service  providers  (ESPs)  to  fulfil  their 
obligations relating to visa management in a context of increase of visa applications and the 
obligation for third country nationals to visit the consulate or the Visa application centre (VAC) 
each time they need to apply. On average, 90% of short-stay visas application are submitted 
through  ESPs,  which  automatically  triggers  exposure  of  personal  data  to  third  parties.  This 

8 

 
 
 
 
involves large-scale contracts and monitoring costs and additional costs for visa applicants13. 
This also means that Member States largely rely on ESPs to deal with questions from applicants 
not  only  regarding  their  application  and  its  status,  but  in  addition  answering  questions  on 
general procedures for applying, which can lead to different interpretation of the rules by ESPs 
and heterogeneous information provided to applicants.  

  The paper-based process is not threat/risk proof. The COVID-19 pandemic had a substantial 
impact on visa procedure as it requires systematic physical displacement of the applicant when 
applying for a Schengen visa. Visa holders who were already in the Schengen area during the 
outbreak of the pandemic but were not able to travel back due to worldwide travel bans, had 
difficulty obtaining an extension of their visa. Because of the pandemic control measures taken 
by Member States (lockdowns, reduction of public services, teleworking, etc.), applying for an 
extension and affixing a visa sticker in the passport was a challenge for both visa holders and 
Member  States.  This  experience  shows  the  vulnerability  of  the  current  visa  procedure  to 
unexpected events such as large-scale health crises, localised emergencies or other disruptions 
as it still relies heavily on visits of applicants to the consulate or VAC.  

  The  physical  visa  sticker  is  prone  to  falsification  and  fraud  (e.g.  forgery  and 
counterfeiting), which represents a security risk14. Since their introduction in 1995, the visa 
sticker has been counterfeited or falsified. The visa sticker is vulnerable to fraud, and this is 
substantiated by the fact that over time more security features have been introduced, the latest 
being the introduction of a signed 2D-barcode on the visa sticker which will enter into force on 
1 May 2022. In recital 2 of the Commission Implementing Decision of 30.4.2020 introducing 
a  digital  seal  on  the  uniform  format  for  visa15  it  is  expressly  mentioned  that  “The  newest 
generation of the visa sticker has already been compromised, with many counterfeits detected 
in Member States. Additional rules should therefore be laid down to enhance the security of the 
visa  sticker  and  to  prevent  further  forgery”.  Although  visa  stickers  security  features  enable 
border and police officers to check whether the sticker is authentic, there is no guarantee that 
officers will systemically detect counterfeiting. Moreover, stickers may be lost or stolen and 
reused  illegally  (washed  and  re-written).  Furthermore,  at  the  border,  the  examination  of  the 
sticker itself is a time-consuming task for border authorities. 

  Increased risk of visa shopping by applicants: While the very large majority of visa holders 
follow the rules, abuses can also take place. Visa shopping has taken different forms over the 
years. Before the implementation of VIS, visa shopping mainly involved applying for a visa 
from  several  Member  States.  Since  the  VIS  came  into  force,  this  is  no  longer  possible  as 
Member States are able to see if an applicant has also lodged an application for another Member 

13  Remuneration  of  ESPs  is  fully  ensured  by  service  fees  paid  by  applicants.  Member  States  costs  relating  to  ESPs  only  consist  in  monitoring  and 
management of contracts and in equipment/software put at the disposal of ESPs, depending on the contract specifications. 
14 The susceptibility to fraud of the visa sticker is substantiated by the Commission Implementing Decision C(2020)2672 of 30.4.2020 introducing a digital 
seal on the uniform format for visas. This implementing decision was adopted after many forgeries of the new visa sticker were discovered in Member 
States shortly after its introduction (December 2019). 
15 C(2020)2672 final. 

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State  when  they  register  it  in  the  VIS.  However,  the  differences  in  taking  and  processing 
applications  also  give rise to  visa shopping. When applying for a visa, an applicant  may be 
attracted by short waiting times or the issuing policy of a Member State (validity of a visa, e.g. 
single/multiple entry). The revised Visa Code  contains  new provisions to  further harmonise 
these  issues.  In  addition,  heterogeneity  in  the  way  an  application  can  be  submitted  can 
potentially create a risk for visa shopping as applicants may choose to lodge an application at a 
Member State with a more digitalised application procedure. For instance, applicants might be 
tempted  to  apply  for  a  visa  to  a  Member  State  that  offers  an  expeditious  or  digital  visa 
application  process  instead  of  the  Member  State  they  intend  to  travel  to,  thereby  providing 
misleading information on their destination(s) and/or first entry16. This can result in additional 
burdens on Member States where visa shopping is taking place. 

1.1.2.  Problems identified in relation to visa applicants 

  Frequent travellers need to repeat the same lengthy procedure to be able to travel to the 
Schengen area each time they apply. Repeat applicants must still visit the consulate or VAC 
to apply for a short-stay visa as application procedures are currently partially digitalised17. They 
generally  still  need  to  print  and  sign  the  application  form  as  no  Member  State  is  currently 
offering third country nationals the possibility to sign the application form using an electronic 
signature. They must submit it together with the supporting documents in paper and/or pay the 
visa  fee  at  the  consulate  or  VAC  (only  four  Member  States  offer  the  possibility  to  upload 
supporting documents online whereas only three offer the possibility to pay the visa fee online). 
In addition, applicants might be requested to provide more information by means of additional 
documents or interviews which might entail another visit to a VAC or consulate. Whereas travel 
costs  for  first-time  applicants  are  justified  by  the  enrolment  of  biometrics  in  a  controlled 
environment,  the  same  does  not  apply  to  repeat  applicants  as  their  biometrics  are  already 
enrolled in the VIS and valid for five years. In nearly all cases, applicants (first time and repeat 
applicants) have to make another visit to the consulate or VAC to collect their travel document 
with the visa sticker (or refusal) or pay courier costs to have it returned. All this is exacerbated 
by limited consular coverage requiring sometimes extensive travels by applicants. 

  The  complexity  and  the  fragmentation  of  the  application  process  can  discourage  third 
country  nationals  from  applying.  Today,  the  way  applicants  submit  their  application  differs 
across Member States, resulting in a fragmented application landscape18 with Member States 
offering the possibilities to carry out none or a few application steps online. Several travel and 
tourism operators mentioned that practical modalities sometimes differ between (a) consulates 
of different Member States in the same third country; (b) consulates of the same Member State 

16 Although this remains a potential risk, it could materialise if the fragmentation between Member States continues to increase in the coming years, with 
some Member States offering repeat applicants a fully digitalised application process whereas they would have to travel and incur costs if they apply for 
a visa to a Member States that have not or only partially digitalised the application procedure. 
17 This cost was estimated at EUR 74 per applicant or EUR 74 bn in total in the context of this impact assessment (current situation – travels for first time 
and repeat applicants). 
18 Cf. Annex 2. 

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in different third countries; and (c) consulates of the same Member State in large third countries 
(such as Russia, China, or India). According to the travel and tourism industry representatives 
consulted  in  preparation  to  the  impact  assessment,  the  Schengen  visa  process  is  often 
considered as more complex than the processes operated by other third-countries, which might 
lead operators to undersell travel to the EU19, with a potential negative economic impact for 
Member States. In addition, non-EU nationals exempted from the visa requirement will be able 
to apply for a travel authorisation to the EU through a common web portal (ETIAS) from 2023. 
These  developments  and  the  increasing  use  of  e-government  tools  and  online  payment 
worldwide will make the current Schengen visa procedure appear increasingly outdated and 
fragmented. 

  Issues  linked  to  the  physical  dimension  of  the  current  visa  sticker.  The  “physical” 

dimension of the visa sticker generates a certain number of problems for visa applicants: 
-  Visa  applicants  need  to  travel  to  the  nearest  consulate/VAC  and  leave  their  travel 
document there. The fact that the visa sticker must be affixed to the travel document still 
requires  first-time  applicants  and  repeat  applicants  to  come  to  the  consulate  or  VAC  to 
provide the travel document and collect it with the visa sticker. Although the latter group, 
according to the amended Visa Code, would not have to appear in person as their biometrics 
are already enrolled in the VIS, the current practice by Member States linked to the absence 
of or the very partially digitalised processes requires them to travel to the consulate or VAC 
to submit their travel document, pay the visa fee and sign the application form. This practice 
results  in  the  same  lengthy  procedure,  which  may  entail  costs  and  a  time-consuming 
journey, especially if the applicants live far away from the nearest consulate or VAC. For 
repeat applicants this means re-visiting a consulate/VAC to lodge an application and collect 
their travel document20. The cost of travel per person per application is estimated at EUR 
74 (see table 4).  

-  The  unavailability  of  the  travel  document  during  the  application  and  examination 
procedure.  The applicant  has to  leave his  or her travel  document at  the consulate/VAC 
during the examination procedure. This means that applicants cannot travel abroad during 
this period or even go back to their home country in case they applied in a neighbouring 
country because the Member State of destination neither has a consulate nor is represented 
by another Member State in the country of the applicant21. This problem can be especially 
critical  for  those  third  country  nationals  who  need  to  travel  regularly  for  professional 
purposes. 33% of the respondents to the public consultation mentioned this limitation to 
mobility as a key shortcoming. 

19 As pointed out by Travel and industry representatives during the consultations (see Annex 2). 
20 34% of third country nationals responding to the public consultation confirmed that they had to travel a long distance to the consulate/VAC, and 52% 
of respondents defined the process as time-consuming. In some cases, third country nationals need to travel 500 km or more (including into neighbouring 
countries) to reach the nearest consulate/VAC, which entails expensive travel, accommodation costs and opportunity costs such as for business activities 
left pending. Amongst the respondents who indicated the travel distance, 10% indicated that they needed to travel for 500 km or more. 
21 For example countries like Gambia or Sierra Leone where no EU Member State is present. See Annex 28 of the Visa Code  Handbook for the list of 
consular presence and representation. 

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-  The physical link between the visa sticker and the travel document.  When the travel 
document is stolen or lost, the visa sticker needs to be revoked in the VIS. A new application 
has to be submitted to obtain a new visa whereas an existing digital visa could be easily 
linked to a new travel document.  

  Applicants need to pay a service fee each time their application is submitted through an 
ESP. This service fee, which may not exceed half of the visa fee22, increases the overall costs 
of visa applications by up to 50% and can discourage applicants from applying for a short-stay 
visa.  In  third  countries  where  the  Member  State  of  destination  has  no  consulate  and  is  not 
represented  by  another  Member  State,  the  service  fee  may,  by  way  of  derogation  from  this 
provision, amount to a maximum of 120 EUR. This dependency makes the visa procedure more 
costly for applicants and also exposes applicants’ personal data to third parties.  

1.1.3.  Impact of the problems identified 

All the above-mentioned problems have three main negative effects on the Schengen area: 

  Higher  costs  for  Member  States  resulting  from  the  management  of  the  paper  based 

application procedure and of the visa sticker; 

  Challenges to security and trust in the Schengen area resulting from undetected forged or 
counterfeit visa stickers, the risk of identify fraud and the non-systematic check of biometric 
data against the VIS at the border; 

  Reduced attractiveness and incentive to travel to the EU as a destination, due to the time 
and  costs  linked  to  the  current  visa  application  process  for  visa  applicants,  which  result  in 
reduced mobility of potential travellers to the EU and a fragmented image of the EU to third-
country nationals.  

2.2.  What are the problem drivers? 

The root causes of the problem are: 

  The legal requirement for Member States to issue a paper visa sticker23. This requirement 
provided  for  by  Article  29  of  the  Visa  Code  applies  to  all  Member  States.  It  prevents  the 
issuance of dematerialised visas. 

  Member States reliance on in-person/paper-based practices. Current EU legislation does 
not  impose  any  digitalisation  efforts  on  Member  States  as  they  are  free  to  digitalise  some 
aspects  of  the  visa  procedure  or  not.  The  amended  Visa  Code  allows  applicants  to  sign 

22 Article 17 of the Visa Code. 
23 The paper sticker must be affixed to the holder’s travel document or on a separate sheet in case the travel document is not recognised by the Member 
State. The sticker includes a unique number that is also part of the corresponding record in the Visa Information System (VIS), and to be used to verify 
the holder’s identity by competent authorities. 

12 

 
 
 
 
 
 
                                                           
applications  electronically  if  Member  States  recognise  the  electronic  signature,  but  this 
possibility has  not  been used by Member States  so far. Such digitalisation efforts were also 
constrained  by  the  Visa  Code  provisions  relying  largely  on  paper-based  procedures  and 
consequently physical presence of the applicant  (e.g. going to the consulate/visa application 
centre). In most cases, applicants still have to put their signature on the paper application form 
and submit it together with paper copies of supporting documents. 

  Heterogeneous  levels  of  digitalisation  and  fragmented  visa  procedures  across  Member 
States. So far EU law regulating the visa application procedure has introduced the possibility 
for  Member  States  to  use  some  digital  features  (e.g.  electronic  signature)  but  has  left  the 
development of any digital tools to their discretion. Without any harmonisation, Member States 
have  digitalised  their  visa  processes  to  different  degrees,  for  various  reasons.  Firstly,  fully 
digitalising  the  visa  process  requires  substantial  investment  at  national  level.  While  some 
Member States have only digitalised some of the steps of the application procedure, none have 
digitalised the entire process (see Figure 2 below). For Member States issuing a limited number 
of visas, the incentive to digitalise is lower as the initial costs incurred are not offset by the 
number of applications processed. Additionally, as the Commission announced an initiative on 
digitalisation already in  2018, several  Member States prefer to  wait for a proposal  from  the 
Commission before investing further in it. Indeed, most Member States who have invested in 
digitalisation,  have  done  so  for  the  easiest  and  least  expensive  steps  of  the  procedure  (e.g. 
uploading  the  application  form  online)24.  Therefore,  applicants  are  confronted  with  very 
different  practices  depending  on  the  Member  State  for  which  they  apply25.  For  many  third 
country  nationals  wanting  to  travel  to  the  EU,  visa  policy  is  the  first  EU  policy  they  are 
confronted  with  and  this  fragmentation  risks  damaging  the  coherence  and  visibility  of  the 
common visa policy and has a negative impact on the image of the EU. 

Figure 2:Overview of features provided in the current online visa application portals26

Source: Member State and Member States consultation 

24 This was confirmed during the interviews carried out in the context of this impact assessment. 
25 The state of play on digitalisation of the visa process by Member States is summarised in Annex 2. 
26 This table concerns the features of the current national online visa application portals for Member States applying in full the Schengen acquis. These 
figures differ from those provided in Annex 2 (section 2), which provides the same overview for all Member States that replied to the consultation, i.e. 
including Member States that do not yet or fully apply the Schengen acquis. 

13 

 
 
 
 
 
                                                           
  Suboptimal  and  fragmented  guidance  provided  to  applicants  with  information  scattered 
across multiple sources (websites operated by different national authorities or on the websites 
operated  by  ESPs)  and  information  with  very  different  levels  of  quality  and  details  often 
without  automated  guidance  available.  This  can  lead  to  applications  having  to  be  corrected 
which has a cost for Member State and is not efficient for applicants. In addition, the image of 
the EU to travellers worldwide comes across as fragmented.  

In addition to these internal issues linked to the heavy paper-based application procedure and the legal 
requirement to issue a paper visa sticker, external factors also contribute to make these problems more 
acute:  

  The increased flows of visa-required travellers to the EU. The estimated number of short-
stay visas applications submitted is difficult to predict for the 2021-2029 period, given the 
disruption  caused  by  the  COVID-19  crisis  and  its  longstanding  impact  on  travels.  In  the 
context of this impact assessment, a conservative a cautious approach has been chosen. It is 
reflected in the table below27. After the substantial decrease due to the COVID-19 situation in 
2020-2021, the number of visa applications is expected to recover in 2023 to pre-COVID-19 
levels (16.9 million visas applied for in 2019). Afterwards, the number of visa applications 
would continue to grow slightly (+3% /year) and stabilise at 17.8 million per year from 2025.  

Table 2: Estimated numbers of short-stay visas applications 2021-2029 (baseline)  

Total short-stay visas 
(million) 

2021 

2022 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

7.5  

11.6 

16.9  

17.3  

17.8  

17.8  

17.8  

17.8  

17.8  

  The inadequacy between the current visa application procedure and the trend in public 
sector digitalisation. In its Communication 2030 Digital Compass: the European way for the 
Digital Decade28, the Commission has set the target for 2030 to provide 100% of key public 
services online for European citizens and businesses. Even if not addressed to EU citizens but 
to third country nationals, the current digitalisation of visa procedure, relying heavily on paper 
would appear more and more inadequate and lagging behind the current digitalisation trend 
in the delivery of public services, including other key tourist destinations that EU Member 
States compete with. 

  The increasing demand for a seamless traveller experience. Offering the possibility to third 
country nationals to travel without undergoing a cumbersome administrative procedure will 
contribute  to  the  attractiveness  of  the  EU  as  a  travel  destination.  The  results  of  the  public 
consultation have shown that more than 50% of respondents found that the current process for 
applying to a Schengen visa was time consuming and 29% too complicated29. Difficult and 

27 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en.   
28 https://ec.europa.eu/info/sites/default/files/communication-digital-compass-2030_en.pdf.  
29 Cf . Annex 2.1.6 Public consultation. 

14 

 
 
 
                                                           
complex procedures discourage potential travellers, especially if they come for tourism and 
have the choice between several travel destinations. 

2.3.  How will the problem evolve? 

The status-quo would have long-term macro-economic impact on the Schengen area as the promotion 
of the EU as a travel destination would be hampered by this situation. Member States would continue 
to develop (or not) their own online tools for visa application, resulting in a fragmented landscape of 
portals/tools  with  different  levels  of  digitalisation  which  could  ultimately  lead  to  increasing  visa 
shopping  by  visa  applicants30.  Depending  on  their  Member  State  of  destination  and  its  degree  of 
digitalisation of the visa application process,  third country nationals would have in some cases to 
continue  to  use  the  current  paper-based  process,  repeat  applicants  would  have  to  incur  travel  (and 
potentially accommodation) costs to reach the consulate/VAC and would most likely still be obliged 
to sign the application form on paper31. Regarding security, the lack of harmonisation across Member 
States  in  the  way  supporting  documents  are  to  be  submitted,  would  imply  that  consulates  would 
continue to work with documents of different quality and reliability. The use of paper visa stickers 
would continue to entail a certain security risk, including blank visa stickers being stolen. Despite the 
recently adopted and more secure sticker format32, visa stickers may still be subject to counterfeiting 
and not address identity fraud adequately. Regarding data protection, a status-quo would not require 
additional data or different data and would be neutral on data protection. As regards other impacts, 
the present fragmentation would continue to negatively affect the perception of the European Union as 
a single geographical entity applying a common visa policy. Third country nationals travelling to the 
consulates or VAC would continue to have an impact on the environment (CO2 emissions) and paper-
based procedures and the use of the visa sticker would still have an effect on paper consumption.  

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Article 77(2)(a) TFEU empowers the Union to develop measures concerning ‘the common policy on 
visas and other short-stay residence permits’. Article 77(2)(b) TFEU empowers the Union to develop 
measures concerning ‘the checks to which persons crossing external borders are subject’33. 

3.2. 

Subsidiarity: Necessity of EU action 

As the Schengen visa procedure is harmonised at EU level and regulated in great detail in the Visa 
Code, the VIS Regulation and the uniform format for visas Regulation, the shortcomings described 

30 Applicants may select those Member States that have digitalised a substantial part of the application process as main Member State of destination even 
if they intend to go to another Member State. 
31 For the time being, the possibility to sign the application form electronically provided for in Article 11 and 11a of Regulation (EC) 810/2009 has not 
been implemented by any Member State. 
32 Commission implementing decision C(2020) 2672 final of 30.4.2020 introducing a digital seal on the uniform format for visas. 
33 Article 79(2)(a)  TFEU empowers the Union to develop measures concerning ‘the conditions of entry and residence, and standards on the issue by 
Member States of long-term visas and residence permits’. The most suitable legal basis for measures concerning stickers for long-stay visas is a joint legal 
basis of Articles 77(2) and 79(2) TFEU. 

15 

 
 
 
                                                           
 
above are inextricably related to existing legislation. The problems elaborated in the previous sections 
are unlikely to disappear in the near future and they are directly related to the current legal provisions. 
For both aspects of the initiative (visa application procedure and format of the visa) by reason of scale, 
effects and impact of the envisaged actions, action to solve these problems can only be taken efficiently 
and systematically at EU level.  

Since the objectives of this Regulation, namely, the establishment of a European online visa application 
platform and the introduction of a digital visa builds on other initiatives aiming, on the one hand, at 
streamlining and harmonising the procedures in  the context  of the common visa policy and, on the 
other hand, at aligning the travel, entry and border policy of the Schengen Area with the new digital 
era, the amendments of the related legislation (mostly the Visa Code and the VIS regulation) are only 
possible at Union level and are part of the Schengen acquis. 

The subsequent analysis of the options will further demonstrate how non-EU action cannot sufficiently 
address the problems identified. 

3.3. 

Subsidiarity: Added value of EU action 

The initiative builds on ongoing initiatives looking, on the one hand, to streamline and harmonise as 
much as possible the procedures in the context of the common visa policy, and on the other hand, to 
align the travel, entry and borders policy of the Schengen Area with the new digital trends. As described 
below, the continuation of the baseline scenario is not going to solve the problems identified, neither 
in  relation  to  Member  State  authorities,  nor  the  visa  applicants.  Only  at  EU  level  changes  can  be 
implemented in a way that would lead to the benefits illustrated in this report. The measures that are 
described under the policy options are examined to make sure they do not go beyond what is needed 
to  achieve  the  general  and  specific  objectives,  in  order  to  respect  the  proportionality  principle  (see 
Section 7.3.3). 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objective 

The general objective of the initiative is to simplify, harmonise and reduce the administrative burden 
to apply for a Schengen visa to improve the security and safety of the Schengen area. 

1.2. General and Specific objectives 

The following general and specific of this initiative have been identified: 

General objectives 

Specific objectives 

16 

 
 
 
  To simplify, harmonise and reduce the 
administrative burden to apply for a 
Schengen visa  

  To streamline and make more efficient the 

visa application procedure for applicants and 
MS through digital means (SO1) 

  To improve the security and safety of the 

Schengen area  

  To increase the security of the Schengen area 
through the digitalisation of the visa sticker 
and digitalised application procedures (SO2) 

Simplifying, harmonising and modernising the visa application process through digital means would 
allow  addressing  the  problem  drivers  identified  in  section  2.2.  This  process  of  simplification, 
harmonisation and modernisation through digitalisation would put an end to Member States reliance 
on  in-person/paper  based  practices  and  inconsistent  levels  of  digitalisation.  The  harmonisation  of 
procedures would address the fragmentation and complexity of visa procedures across Member States 
and reduce current disparities in Member States digital visa procedures (as shown in fig. 2). Achieving 
this  objective  would  also  contribute  to  address  the  issue  of  suboptimal  and  fragmented  guidance 
provided to applicants and increased visa shopping by applicants through a harmonised, modern and 
digitalised application procedure, as visa shopping could potentially increase if ways of applying for a 
short-stay visa differ too much. Giving all third country nationals the possibility to apply online would 
decrease the reliance of Member States on ESPs and  would allow third country nationals to be less 
dependent on ESPs services and spend less time, money and efforts to apply for a short-stay visa.  

Reducing the risks of fraud, forgery and facilitating the verification process at the border through the 
digitalisation of the visa would virtually end the practice of attempting to enter or transit through the 
Schengen area with a forged or falsified visa sticker34. It would further improve the security of the visa 
whose  features  have  been  regularly  upgraded  to  fight  counterfeiting  and  forgery  (as  explained  in 
section 2.1.1 above).  It  would  also  put  an end to  the issue of  blank visa stickers  being stolen from 
consulates which is frequently reported by Member States. In addition, abolishing the visa sticker and 
consult the VIS database to check whether a visa was granted and with what validity (also available 
for carriers via read only VIS) would further enhance the security of the Schengen area and facilitate 
the verification process at the border. The number of forged visas detected at the border should be close 
to zero when the digital visa is implemented. The achievement of these two specific objectives will be 
measurable.  

In a time horizon of seven years35 following the adoption of an initiative at EU level on digitalisation 
of visas procedures, all third country nationals should have the possibility to apply for a short-stay visa 
through digital means following the same, simple, modern and easy procedure independently on the 
Member State of destination. They should be able to access easily the same updated information and 
benefit from guidance to apply. The cost incurred by third country nationals to apply should be reduced 
to the minimum and they should not be obliged to travel for a repeat application or to collect their 

34 The digital visa has no physical features and can therefore, by its very nature, not be counterfeited. It is a digital record in the VIS, linked to the applicant, 
containing information about the validity and conditions of the visa issued. 
35 Seven years as from the adoption of the Commission proposal on digitalisation is the estimated timeline to reach a full level of digitalisation for all 
Member States. 

17 

 
 
 
 
 
                                                           
travel  documents.  They  should  be  less  dependent  on  ESPs  services  for  their  applications.  All  third 
country nationals receiving a positive decision following their visa application would receive a digital 
visa. Member States should spend less resources on collecting visa applications and issuing short-stay 
visas and should be less dependent on ESPs to collect applications.  

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

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

Member States would continue to develop (or not) their own online tools for visa application, possibly 
with non-binding recommendations and support from the Commission (soft law measures), resulting 
in a fragmented landscape of portals/tools with different levels of digitalisation which could ultimately 
lead  to  increasing  visa  shopping  by  visa  applicants.  Member  States  would  still  have  to  manage 
supporting  documents  and  physical  stickers  with  associated  costs  (EUR  16.06  million  per  year  for 
managing the visa sticker for all issuing Member States). Maintaining the status-quo would have no 
impact on EU institutions.  

Third country nationals applying for a short-stay visa with little digital skills would continue to use the 
current  paper-based  process,  incur  travel  (and  potentially  accommodation)  costs  to  reach  the 
consulate/VAC, as well as other travel/courier costs needed to collect the travel document with the visa 
sticker. Applicants would incur such costs because they would have to provide their travel document 
for  the  purpose  of  affixing  the  visa  sticker.  They  would  most  likely  still  be  obliged  to  sign  the 
application  form  on  paper.  Third  country  nationals  applying  through  a  national  digital  application 
platform could benefit from its features, but it remains to be seen how many more Member States will 
digitalise their application process independently and to what extent.  

Regarding impact on security, the lack of harmonisation across Member States in the way supporting 
documents are to be submitted, would imply that consulates would continue to work with documents 
of different quality and reliability. The use of paper visa stickers would entail security risks. Despite 
the recently adopted and more secure sticker format, visa stickers may still be subject to counterfeiting 
and not address identity fraud adequately.  

The  status-quo  or  baseline  scenario  analysed  below  could  also  potentially  have  long-term  macro-
economic impact on the Schengen area. If the status-quo continued until 2029, the current trend on 
digitalisation at global level offering potential travellers the possibility to apply online and obtain a 
digital visa would increase the cost of no action at EU level. The competitive disadvantage of the EU 
compared with other third-countries in attracting travellers might increase and the promotion of the EU 
as  a  travel  destination  would  be  hampered  by  this  situation.  Loss  of  income  for  EU  companies,  in 
particular  in  the  travel  and  tourism  industry,  would  materialise  and  third  countries  who  would  be 
perceived  as  more  attractive  for  visa-required  Third-country  nationals  would  benefit  from  this 
situation. 

18 

 
 
 
Regarding data protection, no additional data or different data will be collected and processed in this 
baseline option than in the current situation in all Member States. Member States will have to comply 
with  mandatory  legislation  (GDPR  and  relevant  provisions  of  the  Schengen  acquis)  while 
implementing their own procedures and systems. From this perspective, there will be no negative or 
positive impact on data protection. Under the baseline scenario, it can be assumed that Member States 
relying on external service providers for a number of services (e.g. appointment booking, checking and 
registering applications, collection of biometrics and in some cases scanning paper applications) will 
continue to follow their own procedures, ensuring that those third parties actually comply with data 
protection obligations. This does not pose a threat to data protection as long as a thorough evaluation 
of each ESP and its compliance with the data protection requirements are frequently carried out by 
Member States authorities.  

As regards to other impacts, the present fragmentation in terms of national practices for managing the 
application process negatively affects the perception of the European Union as a single geographical 
entity applying a common visa policy. 

From an environmental point of view, although the effects may be marginal, the travels of third country 
nationals to the consulates or VAC also have an impact on CO2 emissions. The continued use of paper 
applications, paper-based supporting documents (including those produced digitally and subsequently 
printed) and visa stickers has a certain albeit limited effect on paper consumption. 

5.1.1.  Existing national application portals and features 

The  current  legal  framework36  has  recently  included  the  possibility  for  the  digital  submission  and 
processing  of  visa  applications  (e.g.  filling  in  and  signing  electronically  the  application),  but  most 
Member States only digitalised parts of the Schengen visa process. They may encourage online visa 
applications, but (a) they can only do so via national online application portals, managed individually, 
sometimes with the help of ESPs as there is no common EU online visa application platform; and (b) 
their  systems  rarely  allow  applicants  to  upload  supporting  documents  in  digital  format  and  to 
electronically sign their application which means that the applicant still needs to print and sign the form 
manually37  and  submit  the  application  on  paper38.  Member  States  will  continue  to  develop  their 
national tools in the coming years but these initiatives are likely to cover only parts of the application 
process especially if the current legislation on visa issuance is maintained, requiring the applicant to 
visit the consulate or VAC to provide his/her travel document for affixing the visa sticker. Member 
States might choose for the time being to keep the submission of supporting documents paper based as 
well.  Some  Member  States  will  not  develop  digital  application  platform  due  to  the  low  number  of 
applications they deal with versus the investments needed. See Annex 2 for more details on the levels 
of digitalisation in the Member States.  

36 Mainly Regulation (EU) 810/2009 (the ‘EU Visa Code’), Regulation (EU) 2019/1155 of 20 June 2019 amending Regulation (EU) No 810/2009 and 
Regulation (EU) 767/2008 (the ‘VIS Regulation’). 
37  No  Member  State  has  declared  to  recognise  electronic  signature  at  this  stage.  Four  Member  States  allow  applicants  to  tick  a  box  in  the  portal  to 
acknowledge the information is correct, but this does not equate to signing the application as per Article 11(1) of the Visa Code. 
38 Although the application process is still paper based from an applicant’s point of view, Member States could benefit from implementing an online form 
if it eliminates the need for manually registering the application in their national systems. 

19 

 
 
                                                           
5.1.2.  Digital visa 

Currently, a digital visa cannot be used by Member States as they are required by EU law to issue a 
paper visa sticker. Article 29 of the Visa Code provides that a valid visa shall be certified via a paper 
sticker affixed to the holder’s travel document or on a separate sheet in case the travel document is not 
recognised  by  the  Member  State.  The  sticker  includes  a  unique  number  that  is  also  part  of  the 
corresponding  record  in  the  VIS,  allowing  the  verification  of  the  holder’s  identity  by  competent 
authorities. This requirement is common for all Member States. It is important to note in this regard 
that,  while  the  security  features  of  the  visa  stickers  have  been  continuously  increased  since  it  was 
introduced, the security of the visa sticker could not be further improved through changes to the Visa 
Code.  Security  features  of  the  visa  sticker  are  specified  and  adopted  in  the  Article  6  Committee 
established by the Visa Sticker regulation39. Additionally, the revised Visa Code did not address the 
security of the visa sticker, but the responsibility regarding rules on filling in and affixing visa stickers.  

5.1.3.  Biometric enrolment  

Under the baseline scenario biometric enrolment needs to be done in person. The following biometric 
data of the applicant needs to be collected:  

  a photograph, scanned or taken at the time of application (in the future: live capture will be 

required) and; 

  10 fingerprints taken flat and collected digitally. 

Once the biometric identifiers are collected, they can be reused for any subsequent visa application 
within a period of 59 months. 

5.1.4.  Travel to consulate and/or courier charges 

In the vast majority of cases, third country nationals have to lodge the application at a consulate or 
VAC  and  -  in  case  of  first-time  travellers  or  expiry  of  biometrics  (after  59  months)  –  have  their 
biometrics collected. They also have to go to the consulate or VAC or pay courier costs (if the consulate 
or VAC arranges home delivery), to retrieve their travel document with a final decision (a visa sticker 
affixed in the passport or a refusal to issue a visa).  

5.2.  Description of the policy options 

5.2.1.  General definition and policy changes 

The Impact assessment evaluates five policy options, option 1 being the baseline situation, with varying 
levels of EU intervention in the current visa process: 

Option 1 (O1): Baseline situation: Please refer to section 5.1 

39 Council Regulation (EC) No 1683/95 of 29 May 1995 laying down a uniform format for visas (Official Journal L 164, 14/07/1995 p. 1-4 https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01995R1683-20170817  

20 

 
 
                                                           
 
Option 2 (O2):  Minimal  EU legislative  changes  and digital visa  (mandatory).  It includes some 
minimal  legislative  changes  at  European  level,  aiming  to  remove  legal  obstacles  that  limit  the 
possibility for Member States to further digitalise the visa application process. The introduction of a 
digital visa is also a crucial difference with Option 1 (the status quo). A mandatory digital visa would 
replace the paper visa sticker and a web service would be introduced to check its validity. 

Option 3 (O3): an EU visa application platform (optional) and the digital visa (mandatory). O3 
envisages the development and building of an EU visa application platform, albeit only on an opt-in 
basis. Member States could choose to participate in the EU visa application platform on a voluntary 
basis or develop/continue to use their own national portals or to not develop any digital application 
solution.  Visa holders  would  be able to  check the validity of their  digital  visa through the EU  visa 
application platform. During the consultation with Member States, 14 expressed preference for option 
3. 

Option 4 (O4): the EU visa application platform (mandatory after a transition period) and the 
digital  visa  (mandatory).  O4,  like  O3,  also  includes  the  development  of  an  EU  visa  application 
platform. Whereas participation of the Member States to the EU visa application platform  would be 
optional under O3, under O4 the EU platform would be mandatory for every Member State after a 
transitional period of e.g. five years which would begin after the two-year development period of the 
EU Visa application platform. The purpose of the transition period is to allow Member States to phase 
out smoothly and amortise their investments made in national platforms. The five-year time frame is 
considered sufficient to amortise the investment and prepare for the transition to the EU visa application 
platform. Visa holders would be able to check the validity of their digital visa through the EU visa 
application  platform  and  would  only  be  obliged  to  come  to  the  consulate  or  VAC  to  provide  their 
biometrics or when they change travel documents. During the transition period and if they apply to a 
Member State not  using the EU Visa application platform, the  applicant might  be obliged to  come 
physically  even  for  a  repeat  application,  depending  on  the  procedure  used  by  the  Member  State  to 
which he/she applies. During the consultation with Member States, 10 expressed preference for option 
4. In the stakeholder consultations, the travel and tourism industry unanimously supported option 4, 
highlighting it as the best option to facilitate the application procedure for visa applicants and increase 
the attractiveness of the EU as a travel destination. 

Option 5 (O5):  The EU visa  application platform  (mandatory, for all  Member States without 
transition period), fully digital procedure  and the digital visa (mandatory). O5 also  entails the 
development of an EU visa application platform with mandatory participation of the Member States, 
but without the transitional period envisaged under O4. In this option (full digitalisation), applicants 
are never obliged to come to the consulate or Visa Application centre as all application steps can be 
carried out online (including the provision of biometrics). The main goal of this policy option is to fully 
digitalise the application process. Unlike all other options, the applicant would be able to enrol his/her 
biometric data through a digital application, removing the need to visit the consulate/VAC in person 
which would still exist under all other options. Member States, the EDPS, data protection authorities, 
the Fundamental Rights Agency and Europol all expressed concerns regarding option 5, in particular 

21 

 
 
due to the remote collection of biometrics. The figure below gives an overview of main policy changes 
of each option.  

Figure 3: Policy options 

The following sections describe each option closely linking them to the drivers of the problems and 
the identified objectives.  

Moreover,  the  Impact  assessment  will  analyse  the  impact  on  the  preferred  policy  option  of  the 
following technical sub-options: 

  Architecture of the EU visa application platform, which may be: centralised (sub-option 

1) or hybrid (sub-option 2). 

  Material scope of the initiative with the inclusion of long-stay visas in the scope of the 

analysis.  

  The fall-back solution for the digital visa  

1.  Architecture of the EU digital platform: centralised or hybrid 

The architecture of the EU visa application platform defines what functional components are included, 
how  they  are  connected,  how  data  flows  between  them  and  where  data  are  stored.  The  feasibility 
study40 identified two different potential architectures (visualised below): 

  Sub-option 1 - A centralised architecture: all application files are stored centrally, on the EU 

visa application platform; or 

40 Study on the feasibility and implications of options to digitalise visa processing, 2019, available: https://op.europa.eu/s/pgU6.  

22 

 
 
 
                                                           
  Sub-option  2  -  A  hybrid  architecture:  all  application  files  are  stored  centrally  until  they  are 

admitted. At that point they are transferred to the relevant Member State. 

Figure 4: High-level representation of the centralised (left) and hybrid (right) architecture sub-
options  

It is important to note that these architectures do not have an influence on what the EU visa application 
platform does. In other words, end-users – be they applicants, ESPs consulate staff or administrators – 
will not  perceive the difference in  architecture.  The end-product  remains  a system  allowing for  the 
online visa application.  

These two architectures differentiate themselves in where the application files are persistently stored. 
In  the  centralised  architecture,  all  temporary  and  completed  applications  will  be  stored  in  the 
Application Management System from where Member States can access them. Access management 
controls would ensure authorities can only access those applications they should be able to access. 

The hybrid architecture on the other hand only stores applications temporarily at central level. This 
includes partial applications, saved to be completed later and applications that are not yet marked as 
admissible, i.e. they still need to be checked by an authority for quality and completion. Once marked 
as admissible, the application is sent to the respective Member State and deleted from the temporary 
storage. 

2.  Material scope: only short-stay visas or short-stay & long-stay visas 

This dimension entails assessing the costs and benefits of extending the two limbs of the initiative – 
the digital application platform and the digital visa – to long-stay visas. These visas allow the holder 
to stay on the issuing Member State’s territory for a period longer than 90 days for different purposes 
(e.g. study, work, etc.). The sub-options are the following: 

  Sub-option 1 – This would limit the initiative to short-stay visas only;  
  Sub-option 2 – This would extend the initiative to long-stay visas. 

23 

 
 
 
Extending  the  first  limb  –  EU  visa  application  platform  –  would  mean  that  third  country  nationals 
would use the platform also to apply for long-stay visa to a Member State; extending the second limb 
– digital visa – would mean that the visa sticker for long-stay visas (“D” type) would be completely 
removed, and third country nationals would be issued digital long-stay visas. 

As it is the case for the overall study, the choice of this sub-option only concerns the application process 
for  long-stay  visas  and  the  format  of  these  long-stay  visas,  and  does  not  assess  the  feasibility  or 
implications of amending the substantive requirements for issuing this type of visa, which in any case 
are mostly issued on the basis of national law. 

3.  Fall-back solution for digital visa: simple or digitally signed barcode 

This dimension entails assessing the costs and benefits of two technical sub-options to complement the 
digital visa with a fall-back solution allowing for the verification of the visa offline. The sub-options 
are the following: 

  Sub-option 1 – Visa issuance notification: The fall-back solution would consist of an electronic 
notification sent by the Member State issuing the visa to the visa holder informing the latter that 
the visa has been granted. It can be shown either on paper (print-out) or from a digital device. 
  Sub-option  2  –  Visa  issuance  notification  with  digitally  signed  2D  barcode:  The  fall-back 
solution would be the visa electronic issuance notification plus a 2D barcode containing the same 
data as the VIS record that has been encrypted with a digital seal by the Country Signing Certificate 
Authority  (CSCA)  of  the  issuing  Member  State.  This  sub-option  would  rely  on  the  current 
Commission  Implementing  Decision41  introducing  a  digitally  signed  2D  barcode  in  the  current 
version of the visa sticker as of May 2022. 

An analysis of the pros and cons of the different sub-options is provided in Section 8.2. 

5.2.2.  The legal requirement for Member States to issue a paper visa sticker  

O1 would not lead to the implementation of a digital visa and would not change the legal requirement 
for Member States to issue a visa sticker in case of a positive decision.  

Under O2, O3, O4 and O5 legislative changes would require Member States to issue a digital visa and 
to check an individual’s visa at the border through their biometrics or with a fall-back solution. As a 
result, the internal security of the Schengen Area would improve as it would no longer be possible for 
third country nationals to try entering the Schengen area holding a falsified visa sticker. During the 
stakeholders consultations that were held in context of this impact assessment, Frontex indicated that 
the introduction of a digital visa would be welcome as it will make forging visa stickers even more 
difficult  (no  more  “physical”  visa).  In  addition,  the  high  operating  costs  of  the  visa  sticker  would 
disappear.  

41 Commission implementing decision C(2020) 2672 final of 30.4.2020 introducing a digital seal on the uniform format for visas 

24 

 
 
 
                                                           
5.2.3.  Member State reliance on in-person/paper-based practices 

Under O1, it is very likely that the vast majority of applicants would still have to lodge their application 
at a consulate/VAC in person. Applicants would also have to go to a consulate/VAC, or pay courier 
costs if the consulate/VAC arranges home delivery, to get the passport with a final decision (a visa 
sticker affixed in the passport or a refusal to issue a visa). In addition, it would be mandatory to go to 
the consulate/VAC in person to provide the necessary biometrics with a first application or every 59 
months. 

Under  O2  and  O3,  the  personal  appearance  at  the  consulate  would  depend  on  the  extent  to  which 
Member States have digitalised the application process. However, it would still be mandatory in all 
cases to travel to the consulate/VAC to provide biometrics every five years and for identification in 
case the applicant will be travelling on a different travel document. Repeat applicants would no longer 
need to travel to collect their travel document as the digital visa would be implemented under these 
options. They would no longer need to travel if they apply for a visa to a Member State equipped with 
a national online application portal or through the EU visa application platform (in O3 and O4). 

Under O4 the personal appearance at the consulate/VAC would be mandatory for first time applicants 
and  applicants  who  have  acquired  a  new  travel  document  (or  every  five  years  thereafter)  for  the 
collection of biometric identifiers. Given that the EU visa application platform would be used by all 
Member  States  in  a  five-year  period,  repeat  applicants  could  apply  fully  online,  provided  that  they 
apply with the same travel document. Applicants would no longer need to travel to collect their visa as 
the digital visa would be implemented. 

Under O5 the personal appearance at the consulate/VAC would only be required for a very limited 
number of cases, e.g. when consulates want to check the authenticity of supporting documents. In all 
other cases, applicants would no longer need to visit the consulate/VAC to provide biometrics and/or 
be identified with the travel document, as part of the application process. They would be able to identify 
themselves and submit their biometrics fully online. 

As regards collection of the biometrics42, under O2, O3 and O4 there would be no changes compared 
to the status quo (O1) where physical presence of the applicant is required. Once the biometrics are 
collected, they can be reused for any subsequent visa application within a period of 59 months. 

O5  would  include  a  fully  digitalised  procedure,  including  identification  of  the  applicant  and  the 
enrolment of biometric data through a digital application, removing in principle the need to visit the 
consulate/VAC in person. 

42 The following biometric data of the applicant needs to be collected: a photograph, scanned or taken at the time of application, and his/her 10 fingerprints 
taken flat and collected digitally. 

25 

 
 
                                                           
5.2.4.  Heterogeneous levels of digitalisation and fragmented visa procedures across Member 

States 

Under O1 the development of digital tools depends on the initiative of Member States, without any 
support, framing or obligation from the EU which could result in the long run to improved digitalisation 
but  in  a  very  fragmented  manner  with  different  tools,  features  and  processes.  Even  if  the  usage  of 
national  portals  would  be  encouraged  with  non-binding  standards  under  O1,  and  with  mandatory 
minimal  standards  set  up  with  legislative  changes  under  O2,  under  these  two  options  the  potential 
development of a national visa portal by Member States would however remain fully optional. This 
would  only  partially  address  the  problem  and  related  effects  (e.g.  visa  shopping).  One  of  the 
consequences  of  these  options  is  that  applicants  might  have  to  set  up  an  account  (or  other  user 
credentials)  for  each  Member  State  for  which  they  want  to  apply  for  a  visa.  In  policy  option  O2, 
applicants will be able to check the validity of obtained visas via a common web service, but the way 
they will be notified that a visa has been refused will vary from Member State to Member State.  

Under O3 national portals would continue to be developed and used on a voluntary basis, but some 
Member States might choose to use the EU platform. This diversity, however, does not address the 
problem of fragmentation and the complexity of the application process as they also occur in O1 and 
O2. It would discourage third country nationals from applying and fragmentation would persist over 
time.  

Under O4, a mandatory EU visa application platform with transitional period (e.g. 5 years) would be 
created  and  the  national  portals  would  be  gradually  phased  out.  Under  O5  (no  transitional  period) 
national  platforms  would  no  longer  exist  after  the  EU  visa  application  platform  becomes  fully 
operational. These two options would address the main problems of fragmentation and complexity of 
the application procedure as they would offer the applicant a single environment to apply and to view 
his/her visas or refusals online, regardless of the Member State of destination. This would reduce the 
risk of visa shopping (due to automation in the EU application platform, applicants would not be able 
to decide to which consulate to address the application). It would also simplify the process for frequent 
travellers and would encourage them to apply. 

5.2.5.  Suboptimal and fragmented guidance provided to applicants 

O1 would not lead to the implementation of an EU visa application platform, but the common, however 
non-binding,  standards  set  out  by  the  EU  would  provide  a  first  step  in  the  standardisation  and 
harmonisation of digital application process between the different  Member States from both a legal 
and  operational  point  of  view.  With  O2,  legal  hindrances  such  as  the  obligation  of  signing  the 
application form submitted electronically would be removed and would make the digitalisation of the 
visa application process more straightforward. However, under these two options the process would 
remain complex and guidance provided to applicants would stay fragmented across different Member 
States as it is the case now under the baseline scenario. 

O3 would require EU Regulation to introduce provisions concerning the EU visa application platform 
(as well as for O4 and O5) and would involve the development and set-up of an EU platform, albeit 

26 

 
 
only on an opt-in basis, meaning that Member States could choose to use the EU platform, their own 
national portals or none. This means that each Member State would have to set up and maintain systems 
to  inform  the  applicant  about  Schengen  visas  and  the  application  procedures.  The  fact  that  this 
information would be found in different national portals and might vary across Member States, could 
confuse  applicants,  who  might  decide  not  to  use  portals  and  continue  using  in-person/paper-based 
practices,  leading  to  still  lengthy  processes  for  consulates  to  manage,  process  and  archive  paper 
documents.  

Under O4 the EU visa application platform is mandatory, but with transitional period. Whereas in O5, 
there  is  no  transitional  period  for  the  mandatory  EU  visa  application  platform.  These  two  options 
introduce common practice as regards digital application, which would lead to removing the issues of 
fragmented guidance that would persist under other options. 

5.3.  Options discarded at an early stage 

None of the options were discarded at an early stage  because all options were considered to have a 
potential positive impact on the policy, compared to the baseline scenario. Furthermore, although the 
different options received varying degrees of support among stakeholders, none of the options were 
fully rejected. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The impact of the different policy options was assessed across various categories, in line with the Better 
Regulation guidelines. As regards social impacts, the assessment focuses on implications for security 
and fundamental rights, as well as data protection. Detailed assessment on the quantitative impacts of 
the  different  policy  options  are  available  in  the  Study  to  assess  the  various  options  related  to  visa 
process digitalisation and to support the preparation of an impact assessment43. 

6.1.  Economic impact 

6.1.1.  Impact on EU institutions and agencies 

The economic impact of the digital visa for EU institutions and agencies are equivalent for O2, O3, 
O4 and O5. However, for O2, a web service allowing third country nationals to check information on 
their  digital  visas  would  have  to  be  built,  whether  Member  States  use  their  own  national  online 
application portal or maintain the paper process. The costs for the web service to be implemented at 
central  level  by  the  European  Union  Agency  for  the  Operational  Management  of  Large-Scale  IT 
Systems in the Area of Freedom, Security and Justice (eu-LISA), which would reuse the concept of 
the web service to be built for EES and ETIAS, are estimated at EUR 3.5 – 6.4 million for one-off costs 
related to procurement, design, development, testing, infrastructure and deployment and EUR 3.5 – 6 

43 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available;  
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en  

27 

 
 
 
                                                           
million yearly maintenance costs over the 2025-202944 period. The visas currently issued are already 
digitally stored in VIS. Therefore, digitalisation of visas would not imply any additional costs for the 
EU budget. 

In addition to the costs linked to the dematerialised visa (or digital visa) that will concern options O2, 
O3, O4 and O5, the set-up of the EU visa application platform envisaged by O3, O4 and O5 would 
trigger  costs  for  establishing  the  central  digital  application  capability.  As  estimated  in  the  EU  visa 
application platform prototype study45, the one-off cost to enable this capability would range between 
EUR 33.8 million and EUR 41.2 million for eu-LISA46 (including the managed service costs and the 
adaptations needed for VIS). In addition to the one-off technical costs, eu-LISA is expected to need to 
expect 8 additional full-time equivalents for supporting the development efforts during 2024 and 2025. 
This amounts to an additional costs of EUR 2.5 million across these two years47. Once this managed 
service is created, it also needs to be operated and maintained, leading to a yearly cost between EUR 
10.5  million  and  EUR  12.8  million  for  eu-LISA48.  Additionally,  this  would  involve  establishing  a 
design/business  team,  service  level  agreements  and  extensive  stakeholder  management,  as  well  as 
additional staff (7-10) and training costs (EUR 20 000 – 33 000) for eu-LISA.  

6.1.2.  Impact on Member States 

As regards the impact on Member States, O2,  O3, O4 and O5 would allow savings on the costs 
attached to the current visa stickers, which would no longer be required (EUR 76.6 million over 2025-
2029). The introduction of the digital visa would trigger only negligible costs for Member States that 
have not been taken into account in this impact assessment. Indeed, the tools to generate and verify a 
signed 2D barcode will already be in place to comply with the Commission’s Implementing Decision 
C(2020)2672 of 30.4.2020 introducing a digital seal on the uniform format for visas49. 

In addition, the implementation of an EU visa application platform (O3, O4, O5) is expected to reduce 
the  administrative  burden  on  consulates  both  in  terms  of  time  spent  processing  paper-based 
applications  and  time  spent  printing  and  affixing  the  visa  sticker50  with  total  savings  under  O3 
amounting to EUR 364.3 million for all Member States on the 2025-2029 period, EUR 510.9 million 
under O4 (taking into account small additional costs to capture biometrics) and EUR 521.6 million 

44 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available:  
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en  
45 A project with eu-LISA to develop and test a prototype of a future EU online visa application platform launched in September 2020 in accordance with 
a Service Level Agreement signed between DG HOME and eu-LISA on 27 July 2020. The project is to analyse the costs as well as technical and legal 
requirements of a future EU online application platform. The final report of the project to be submitted by October 2021.  
46 Please note these are the cost estimations for O4. O3 and O5 have a slightly different cost estimation. Please refer to  Table 4: Comparison of 
costs and benefits  for the details. 
47 Estimated directly by eu-LISA and DG HOME. 
48 Like before, presented costs based on O4. O3 and O5 have different cost estimations. Please refer to Table 4: Comparison of costs and 
benefits  for the details.  
49 This Implementing Decision stipulates that all Member States shall apply the digital seal at the latest two years after the notification (i.e. 1 May 2022). 
50  Study  to  assess  the  various  options  related  to  visa  process  digitalisation  and  to  support  the  preparation  of  an  impact  assessment  -  Final  Report 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en 
of 
comparison of options. 

result 

– 

28 

 
 
                                                           
under  O5.  Another  benefit  of  the  EU  visa  application  platform  is  that  all  general  information  on 
Schengen visas will be kept up to date at central level, including a guidance tool that enables third 
country nationals to check if a visa is needed and under which conditions. All this will trigger savings 
for  Member  States  up  to  576  FTEs51  (2025  –  2029)  to  reply  to  queries  from  visa  applicants.  To 
implement the new EU visa application platform, each Member State using the EU platform (even the 
ones who already have some form of online portal) needs to adapt and connect its national systems 
with  the  centrally  hosted  and  managed  platform.52  According  to  the  EU  visa  application  platform 
prototype study, this investment would roughly amount to EUR 2.8 million to EUR 3.3 million (on 
average)  per  Member  State53.  Once  the  national  systems  have  been  updated  and  connected  to  the 
managed service and sufficient storage space is provided for, these new enhanced national systems will 
need to be maintained, with an estimated cost between EUR 460 000 and EUR 570 000 per Member 
State, annually54. These expected costs, however, vary with the number of applications a Member State 
receives.  It  should  be  noted  that  Member  States  choosing  their  own  solution  for  digitalising  visa 
applications (in policy options O1, O2, O3) must also have systems in place to store these digital files. 

O5 also includes additional time saving as biometric data would no longer be collected in person at the 
consulate or at VAC. 

The benefits relating to the reduction of administrative burden for Member States, even if they also 
rely on a number of forecast visa issued, are more reliable because they have been calculated on the 
basis of an existing workload/tasks and costs that currently exist, and have been estimated with Member 
States input. These costs will partially or completely disappear with digitalisation, which is why even 
assuming  a  stable  number  of  travellers  over  the  2025-2029,  the  calculations  would  still  show  a 
significant reduction of the Member States administrative burden and associated costs. 

6.1.3.  Impact on third country nationals 

Third country nationals currently (O1) incur travel costs and sometimes accommodation costs to apply 
for a visa as they have to leave their travel document at the consulate, as well as costs to collect their 
travel documents after the application process is completed.  

Minimal improvements are expected under O2, where the costs for repeat applicants would reduce as 
they would no longer have to travel to the consulate or VAC to lodge their application. This would 
apply  if  Member  State  who  run  their  own  portals  would  allow  applicants  to  submit  supporting 
documents online. The same benefit for third country nationals would apply for options O3 and O4 as 

51  Study  to  assess  the  various  options  related  to  visa  process  digitalisation  and  to  support  the  preparation  of  an  impact  assessment  -  Final  Report 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en.  
52 In the case of O3, where it is estimated that 16 out of 25 Member States would opt in, the assessment of impacts, costs and benefits only applies to 
Member States that decide to opt in. For those that do not, the impacts are equivalent to O1. 
53 This average cost deviates from the one presented in Option 3. This is because the 16 Member States that were selected in policy Option 3 account only 
for 43% of the visa applications while accounting for roughly 64% of all Member States. This is the reason why infrastructure costs cannot be scaled 
linearly based on the number of Member States that decide to opt in. 
54 Like before, presented costs based on O4. O3 and O5 have different cost estimations. Please refer to Table 4: Comparison of costs and 
benefits  for the details. 

29 

 
 
                                                           
the third country nationals would not  need to  pick up their travel  documents  and could  lodge their 
application online55. This measure would entail a cumulated saving of up to EUR 2.7 billion56 under 
O2,  2.7  billion  under  O3  and  2.9  billion  under  O4  in  terms  of  direct  travel  costs  for  third  country 
nationals during the application process for over the 2025 - 2029 period57, as well as the associated 
opportunity costs that comes with travelling to the consulate or VAC. Besides cost savings, 89% of the 
respondents in the public consultation indicated that not going to the consulate or  VAC as a repeat 
applicant is important for them. However, costs and obstacles for first-time applicants would remain. 
Under  O4,  third  country  nationals  will  be  able  to  use  a  single  application  platform  whatever  their 
Member State of destination, using one single procedure and being able to save and reuse their data for 
a subsequent application. In addition, a single online application platform would provide in one single 
place  information  on  Member  States  application  procedures.  This  information  will  be  more  easily 
updated and maintained, significantly increasing the quality and reliability of information provided to 
third country nationals. Although difficult to quantify, this option would spare time and produce greater 
benefits  for  third  country  nationals  than  in  O3  where  they  would  still  have  to  cope  with  several 
application procedures. 

In O5, the benefits of the fully digitalised application would be even greater for third country nationals 
and would allow savings up to EUR 8.3 billion over the same 2025-2029 period.  

For visa applicants, digitalisation will decrease the travel costs associated to visa applications because 
they will not have to travel or pay a courier to pick up their passport with the visa sticker and repeat 
applicants will be able to apply fully online during five years after their first application. Even with a 
stable number of travellers, these benefits would remain substantial. 

It must be stressed that all options would have no impact on the visa fee itself. 

6.2. 

 Social impact 

6.2.1.  Security  

Under O2, Member States  would continue to  have different  degrees of  digitalisation of their visa 
procedures. Depending on which documents are requested on paper and which ones can be submitted 
online  and/or  digitally,  consulates  of  different  Member  States  may  process  documents  of  varying 
quality and reliability which would not allow improving the detection of forged documents. 

The major novelty of O5 is the possibility for first-time applicants or third country nationals to enrol 
biometrics independently by using a digital app on their smartphones to capture their facial image and 
fingerprints. O5 would decrease costs and increase time savings compared to O3 and O4; however, it 

55 Out of the EUR 74 of travel cost per applicant calculated in the baseline scenario, EUR 17 are linked to picking up the travel document with the visa 
sticker affixed and EUR 57 linked to the application itself. 25% of the applicants (repeat applicants) will therefore no longer have to incur the EUR 57 
cost, which explains that the savings are only 40% of the total travel cost. A sentence explaining this will be included in the report. 
56 This figure takes into account the fact that 3% of applicants will still apply at the consulate because of impossibility to apply online or because they will 
be required to provide original supporting documents to verify their authenticity, slightly lowering benefits expected. 
57 Assuming a 75/25 split between first time applicants and third country nationals applying within 59 months after their biometrics were enrolled. It 
should be noted that some third country nationals will be able to lodge their entire application online, but could still need to travel in order to submit a 
number of supporting documents. Nonetheless, for the 75/25 split is maintained in order to calculate the costs.  

30 

 
 
                                                           
also increases security risks. First, because the identification of the applicant is not done in a controlled 
environment  (risk  of  identity  fraud),  and  second  because  adequate  quality  of  biometrics  is  not 
guaranteed, which could cause mismatches with data stored in EU information systems. As biometrics 
only have to be submitted every 59 months, identify fraud might go undetected for the same period of 
time. Even though there are secure technologies available to provide biometrics, a first identification 
is always done by checking it against an official identity document. Persons whose identity have been 
established,  could  then  be  allowed  to  identify  themselves  online  with  the  biometric  identifiers  and 
secure  technologies.  By  enrolling  biometrics  using  a  digital  app,  there  is  no  check  if  an  applicant 
commits identity fraud using a forged travel document in combination with their own biometrics. O5 
is therefore likely to disrupt the reliability and security of Schengen visa applications. Under options 
implying the use of the EU Visa application platform, the choice of the hybrid or decentralised sub-
option for the storage of data would avoid the risk of having a single point of failure and attacks. 

As regards the security implications of maintaining the  visa  sticker vs  introducing a digital visa, 
evidence indicates that the paper visa sticker is not threat and risk-proof as it is prone to falsification 
and fraud.58 However, biometric checks against the VIS at the border should make entering and staying 
in the Schengen area with a forged sticker more difficult or rather impossible. The current Schengen 
Borders  Code  requires  a  biometric  verification  at  the  Schengen  external  border  that  the  traveller 
corresponds with the person who applied for the visa (and whose biometrics are stored in VIS). With 
the  entry  into  operation  of  the  Entry-Exit  System,  biometric  verifications  will  even  become  more 
routine as they will also apply to any third country national entering the Schengen area for a short stay 
and not falling in the exception cases. O4 will however achieve deeper harmonisation than the previous 
options because all applicants will upload their documents through the EU online application platform 
which will enforce certain formats and data quality. A digital visa embedding these security features 
will be significantly less prone to forgery. This will further reinforce the visa format security.  

Maintaining the visa sticker (O1) would not hamper the security benefits of EES and interoperability 
but may lead to inefficiencies: border guards would still be required to verify the sticker, and if check 
with  VIS  contradicts  the  data  on  the  sticker,  they  would  spend  additional  time  investigating  the 
mismatch and ascertaining that the sticker has been counterfeited. 

The replacement of the visa sticker with the digital visa (O2, O3, O4, O5) would lower security risks 
related  to  counterfeited  and  stolen  stickers,  especially  those  not  detected  by  border  and/or  police 
authorities. Furthermore, carriers will be better equipped to check if third country nationals hold a valid 
visa thereby mitigating the risk that they transport people with fraudulent visas to the Schengen area 
and alleviating the burden of checks at the Schengen borders. 

1.2.1.  Protection of personal data 

In general, as pointed out by the EDPS and national Data protection authorities, the higher degree of 
digitalisation of the options, the greater are the risks to data protection. That is why the principles of 

58 Interviews with border authorities of Member States. Despite the security features that make the sticker a reliable source of verification, cases of fraud 
could still occur as they do nowadays. Hundreds of cases of counterfeiting are detected per year according to Frontex despite the new sticker format. 

31 

 
 
                                                           
“purpose limitation” and “data minimisation” will have to be strictly respected in the context of the 
new developments triggered by digitalisation.  

As also pointed out by EDPS, data protection impacts of digitalisation would primarily stem from the 
introduction of a visa application portal (with impact on handling of personal data by external service 
providers, data security of the portal, collection of biometrics through digital means under O5 etc.). 

Under O2 mandatory standards may enhance monitoring of compliance and legal certainty, positively 
contributing to data subjects' trust in the data processing. The web service would entail data security 
implications that need to be mitigated via a “privacy enhancing” implementation.  

Under O3 the EU visa application platform would introduce uniform data processing practices, which 
would however apply only to a subset of Member States.  

Under O4 the EU platform would introduce uniform data processing practices, which would apply to 
all Member States. It would reduce exposure of personal data to ESPs as repeat travellers would be 
able to apply directly through the EU application portal.  

Under O5 the EU visa application platform would introduce uniform data processing practices, which 
would apply to all Member States and would even more reduce reliance to ESPs compared to O4 as 
first  time  and  repeat  applicants  would  be  able  to  apply  online.  Nevertheless,  under  O5,  the  online 
biometric enrolment would open up new privacy challenges compared to the other options, such as 
collection of (new) or additional data on mobile application and exposure of data to other (third) parties. 

Under O3, O4 and O5, the use of ESPs does not pose a threat to data protection as long as processes 
and technologies used by ESPs comply with data protection and privacy enhancing principles and that 
proper monitoring of each ESP is carried out by Member States authorities. EU law already provides 
that  ESPs  need  to  respect  GDPR  and  applicable  data  protection  safeguards,  which  also  applies  to 
methods of identification of applicants by ESPs when collecting their biometrics59. In addition, the use 
of a single application platform could lead to a reinforced compliance of data protection practices by 
ESPs  (same  standards/rules  applying  to  all  ESPs).  A  “privacy  enhancing”  implementation  will 
safeguard security of data stored in the EU visa application platform.  

Nevertheless  O5  presents  serious  risks  regarding  data  protection  due  to  the  self-enrolment  of 
biometrics through digital means. All other options (O2, O3 and O4) are relatively equivalent as far as 
data protection was concerned.  

In terms of the data protection implication of digital visas, currently the information about a visa is 
stored in a large-scale EU database – VIS, as well as evidenced by affixing a visa sticker in the passport. 
Hence, dematerialising the visa sticker into a purely digital visa does not change the fact that the visa 
information  is  (and will still be) stored in  a large-scale EU database. Since storage in  a centralised 

59 In accordance with Annex X of the Visa Code listing the minimum requirements when Member States cooperate with ESP, as last amended in the 2019 
revision of Visa code. 

32 

 
 
                                                           
large-scale EU database has undeniable data protection impacts, the VIS regulation already contains 
high  data  protection  safeguards  (retention  rules,  access  rules,  access  rights,  rights  to  rectification, 
completion, erasure of personal data and restriction of processing etc.). Moreover, the recently revised 
VIS Regulation has further enhanced these data protection safeguards. These enhanced data protection 
safeguards  will  continue  to  apply,  as  the  purely  digital  visas  will  continue  to  be  stored  in  VIS. 
Additionally,  the  ETIAS  Regulation,  which  introduces  digital  travel  authorisations  for  visa-free 
travellers,  is  currently  being  implemented.  This  Regulation  contains  data  protection  standards  for 
notifications  to  travellers  regarding  their  travel  authorisations.  Notifications  to  travellers  regarding 
digital visas will follow the same standards for communicating with travellers regarding their visas.  

6.2.3.  Protection of fundamental rights 

In terms of implications for the protection of fundamental rights, under O1 there would be no impact 
on the protection of fundamental rights compared to the present situation. Under O2 and even more so 
O3,  O4  and  O5,  people  with  low  IT  literacy  and  people  who  cannot  read  or  write  applying  from 
distance may need technical assistance to use online application tools, but the assistance provided by 
family  members  and  friends,  service  providers  and  consulates  would  be  sufficient  to  guarantee 
protection  and  inclusion,  according  to  the  results  of  the  consultation  with  Member  States.  Service 
providers  already  provide  assistance  and  services  to  support  applicants  today  for  paper-based  and 
online applications. Repeat applicants with reduced mobility would be able to apply with no need to 
visit a consulate/VAC. Therefore, O1 O2, O3 and O4 would ensure compliance with the EU Charter 
of Fundamental Rights with O4 providing the same supporting features to people unable to see or hear 
in all Member States. 

O5 would comply with the protection of fundamental rights. Nevertheless, under O5 consulates and 
VAC staff would normally have little to no chance to perform on-site checks to detect child abduction 
or trafficking of human beings. In particular children above the age of 6 will not be required to come 
to the consulate/ VAC to enrol their biometrics. Even if the visa procedure plays a very limited role in 
detecting child abduction and trafficking of human being, O5 might offer less possibilities than other 
options to detect such cases. 

6.3.  Environmental impact  

Under the O1 scenario, the main environmental impacts concern the continued use of (non-) renewable 
resources due to paper-based administration (applications and visa stickers) and the travel of applicants 
to  the  consulates.  The  environmental  impacts  of  these  elements  are  expected  to  increase  under  the 
baseline scenario in line with the projected increase of visa applications and issuance. Additionally, the 
vast majority of the applicants will have to travel to the consulate or VAC on average 129.76 km60 in 
order to lodge their application and/or collect their travel document. This  would produce up to 477 
million kg of CO2 for both activities combined in 202961 (i.e. 2.9 billion kg over the 2025-2029 period).  

60 This average includes the third country nationals which did not have to travel, or a distance of 0 km. 
61 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available:  
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 

33 

 
 
                                                           
As O2 entails the introduction of common standards related to developing national visa application 
platforms, as well as the removal of certain boundaries such as the necessity to sign the application 
document  in  person,  O2  would  enable  saving  38%  of  the  CO2  emitted  by  third  country  nationals 
travelling to consulates/VACs, 50% of the paper needed for visa applications, and all paper used for 
visa stickers. Under O3, O4 and O5, thanks to the digital visa and the gradual reduction of travels by 
visa applicants to pick up their travel document or to apply (in particular for repeat applicants using 
the  EU  Visa  application  platform),  the  emissions  of  CO2  linked  to  the  application  process  would 
decrease. O5 would almost save the remaining 75% of CO2 emissions and paper in the application 
process). Regardless of the number of travellers, paper consumption as well as travel of third country 
nationals for the purpose of applying for a visa will decrease, with positive impacts on the environment.  

Overall, the positive impact of all options on environment (reduction of travels for repeat applicants, 
paper  consumption)  are  certain,  regardless  of  the  number  of  travellers  whereas  additional  CO2 
emissions  triggered  by  additional  travellers  are  difficult  to  forecast.  According  to  the  calculations 
carried out in the context of this impact assessment, the slight increase in tourism to the EU due to the 
implementation  of the  EU visa  digital  application  platform for the period 2025-2029 would trigger 
additional emissions of up to 0.8 billion kg CO2 under O3, to 2.9 billion kg of CO2 under O4 and up 
to  6.2  billion  under  O562.  Nevertheless  the  estimated  increase  of  CO2  emissions  might  be 
overestimated,  as  it relies  on an additional number of travellers  triggered by  the simplification  and 
harmonisation of the application procedure that is difficult to predict. Furthermore the impact on the 
environment of these additional travels might be mitigated by carbon emission reduction measures for 
air transport. Recent initiatives aiming to reduce problematic fuel emissions in the air transport sector 
have not been taken into account in the calculation of the impact as it was not possible to produce 
reliable quantitative estimations. Because of this reason, the precise amount of extra CO2 indicated in 
the report is likely to overestimate the eventual impact. At this stage it is also not possible to assess 
whether  travel  habits  and  public-private  initiatives  will  reduce  the  environmental  footprint  of  the 
additional visa required third country nationals travelling in the coming years.  

6.4. 

Impact on EU tourism and GDP 

Given the difficulty to forecast ex-ante a) the “natural” growth of visa-required travellers and b) the 
impact of the introduction of a single EU visa application platform (precise quantitative correlation) 
on  the  number  of  travellers,  the  impact  on  tourism  and  GDP  should  be  considered  carefully  in  the 
context of this impact assessment as it is based on assumptions.  

As regards economic impacts on EU tourism and GDP, O1 and O2 are not expected to bring about 
significant benefits to international travel and consequently to EU GDP. Under the options including 
an EU visa application platform (O3, O4, O5), it has been assumed that the introduction of the EU visa 
application platform  would  have a slight positive impact on the contribution of visa-required third 
country nationals to the EU GDP due to the increase of visa required third country nationals travelling 

62 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, 
available:  https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en.  

34 

 
 
                                                           
to  the  EU  (2%  under  O3  and  O4;  4%  under  O5),  with  the  assumption  that  O5  would  generate  the 
highest increase in travel. These assumptions rely on the results of the public consultation and of the 
survey with Member States and the travel industry  that corroborated this expectation63: 86% of the 
respondents  to  the  public  consultation  think  that  higher  digitalisation  would  encourage  more  third 
country nationals to apply and travel; 11 Member States also mentioned that travel to the Schengen 
Area would benefit from a higher degree of digitalisation.  

Whereas  O3  would  already  achieve  significant  progress  towards  the  digitalisation  of  the  visa 
procedure, O4 would really mark the transition from a largely paper-based application process to a 
truly digital and largely harmonised process, which might help attract more visa-required travellers to 
the EU and therefore generating a potential higher contribution to the EU GDP, with a potential higher 
impact on the EU GDP under O5. The Schengen Area would thus benefit from a more coherent image 
vis-à-vis third countries as the traveller vetting processes would conform to the worldwide state of the 
art: along with ETIAS, the Schengen visa process would be a) relying on advanced digital technologies 
allowing for fast, secure and seamless interactions; b) applied consistently by all Member States; and 
c) based on a virtual and secure proof of clearance (digital visa).  

7.  HOW DO THE OPTIONS COMPARE? 

To determine the preferred option, the policy options have been assessed and compared in the light of 
the following criteria: 

  Effectiveness, i.e. to what extent the option meets the policy objectives; 
  Efficiency, i.e. the relative weight of the costs and benefits of the option; 
  Other impacts: 

-  Level of protection of personal data; 
-  Coherence with the Charter of Fundamental Rights of the EU;  

The table below provides an overview of the result of the options comparison for all criteria. Detailed 
results on the comparison of policy options are provided in the ‘Study to assess the various options 
related to visa process digitalisation and to support  the preparation of an impact assessment  - Final 
Report’64.  

Table 3: Comparison of options for all criteria  

Criteria  

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

To streamline and make more efficient the visa 
application procedure for applicants and MS through 
digital means (SO1) 

0 

1.25 

2 

2.6 

2.8 

63 A 2018 survey by the European Tourism Association estimated that the combined effect of the current Schengen visa process and the attractiveness of 
existing digital visa processes worldwide led 25% of Indian travellers dropping their application for a Schengen visa before submission. 
64 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, 
available:  https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en  

35 

 
 
 
                                                           
Criteria  

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

To increase the security of the Schengen area through the 
digitalisation of the visa sticker and digitalised 
application procedures (SO2) 
Impact on the environment 

Overall effectiveness 

EU-level & Member States 
Third country nationals 
Overall efficiency 
Protection of personal data 
Coherence with Charter of Fundamental Rights 

7.1.  Effectiveness 

0 

0 

0 

0 
0 
0 
0 
0 

1.75 

0.25 

1.1 

1.5 
1.5 
1.5 
0.5 
0 

2.0 

0.75 

1.6 

1.7 
1.5 
1.6 
0.75 
0 

2.5 

0.5 

1.9 

2.5 
2 
2.25 
1 
0 

-0.5 

0.25 

0.8 

1.5 
2.5 
2 
-0.5  
-0.5 

Each specific objective under effectiveness was scored from -3 to +3 (-3 indicating the most negative 
impact, +3 indicating the most positive impact) based on the assessment of the options. The impact on 
environment was also taken into account in the assessment of the effectiveness. The overall mark for 
effectiveness was then calculated based on the average of the three sub-criteria.  

In the assessment of effectiveness, all options are assessed across the sub-criterions in comparison with 
the  baseline  scenario  (policy  option  1).  In  line  with  the  Better  Regulation  Guidelines,65  O1  is 
considered as the benchmark against which all other options are assessed and scored. Therefore, the 
value of 0/nil is attributed to the baseline situation for all effectiveness criteria, whereby “0” means no 
impact compared to the baseline. A positive figure indicates an improvement of the situation in relation 
to  the  criterion  assessed  and  a  negative  one  a  deterioration  of  the  situation  created  by  the 
implementation of the option. The marks reflect the assessment of the performance of each option in 
relation  to  each  criterion.  A  high  gap  between  two  options  (i.e.  over  0.5  point)  reflect  substantial 
differences whereas lower gaps will reflect small discrepancies in the assessment of their performance 
relating to the criterion. 

Analysis of results 

  To  streamline  and  make  more  efficient  the  visa  application  procedure  for  applicants  and  MS 
through digital means (SO1) 
O1 would contribute only to a very limited extent to these objectives, while O2 would strengthen their 
achievement by a) making the EU-standards mandatory and b) enabling efficiency gains thanks to the 
digital visa. O3 to O5 would increasingly simplify and harmonise the process:  O3 would do so for 
repeat applicants in the 17 Member States expected to join the EU visa application platform66. With a 
mandatory EU visa application platform for all Member States, O4 would simplify and harmonise the 
process in all Member States; and O5 would extend the benefits of O4 to all visa applicants (first time 
and repeat applicants). 

https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-how/better-regulation-guidelines-and-

65 
toolbox_en. See in particular: Sections 2.4 and 2.5. 
66 See Annex 2. 

36 

 
 
 
 
                                                           
  To  increase  the  security  of  the  Schengen  area  through  the  digitalisation  of  the  visa  sticker  and 
digitalised application procedures (SO2) 
O1 would not contribute to these objectives. O2 to O5 would contribute to the same degree as far as 
the  digital  visa  is  concerned;  in  addition,  O3  and  O4  would  allow  Member  States  to  strengthen 
examination by re-allocating FTEs saved in the administrative process if they choose to do so (with 
larger  effects  under  O4);  while  O5  would  undermine  security  by  preventing  proper  correct  on-site 
identification of first-time applicants and repeat applicants using a different travel document. O4 would 
fully harmonise format and data quality of supporting documents with the use of a single application 
tool, guaranteeing the same level of authenticity of documents submitted for all applications which 
would not be the case under O3 as Member States would not be obliged to digitalise their application 
process. The choice of a hybrid architecture for the EU visa application platform under O4 would also 
ensure that the storage of applications in national database would avoid the risk of a single point of 
failure and attack that could jeopardise all stored applications. 

  Environmental impact  

O2  would  enable  saving  38%  of  the  CO2  emitted  by  third  country  nationals  travelling  to 
consulates/VACs, 50% of the paper needed for visa applications, and all paper used for visa stickers. 
These savings would also materialise under O3 to O5 (and O5 would save an additional 17% of CO2 
emissions  in  the  application  process).  Regarding  the  additional  emission  of  CO2  triggered  by  the 
increase  in  travellers,  the  same  considerations  as  for  the  impact  on  GDP  apply,  as  they  rely  on  an 
additional number of travellers which is difficult to estimate whereas the impact on travels of repeat 
applicants  would  materialise  for  all  repeat  applicants,  whatever  the  number  of  visas  issued.  As  the 
options would gradually result in a slightly increasing number of travellers, the effect in terms of CO2 
emissions would also increase even if they might be mitigated by the reduction of fuel emissions in the 
air transport67.  

With the implementation of the digital visa and of a mandatory single EU visa application platform, 
O4 would be the option that would endure the highest effectiveness in fulfilling the key objectives of 
the digitalisation of the visa procedures.  

7.2.  Efficiency 

The efficiency (effectiveness in relation to the cost) was scored from -3 to +3 (-3 indicating the most 
negative impact, +3 indicating the most positive impact) based on the assessment of the options.  

On the basis of the result of the calculation presented in the table  below, a separate score has been 
assigned to: a) the economic impact at EU-level and Member States; b) the economic impact on third 
country nationals. The overall efficiency score corresponds to the average of both scores. 

The table below summarises the different costs and benefits compared with the baseline-option 1 with 
a quantification for each category of impact (additional cost or benefit compared with the baseline)68. 

67 For full details on the calculations of impacts on the environment, please refer to the cost benefit analysis, Annex 2. 
68 For a detailed overview of the methodology and calculations of these costs refer to the supporting study, Annex 4. 

37 

 
 
                                                           
The calculations have been made with a very slight increase of travellers (due to a “natural” increase 
of  travels  not  linked  to  digitalisation).  The  baseline  (16.9  million  visas  applied  for  in  2023, 
corresponding to 2019 pre-COVID level) would increase to 17.3 in 2024 and would stabilise to 17.8 
million as from 2025). Beyond this “natural” growth of travellers, an additional increasing factor has 
been included to reflect a very slight increase of travellers linked to the use of the EU visa application 
platform (due to  a simplified/easier  application process)  with  + 5 % under O3 and O4 (with larger 
effects under O4 as all Member States would use the platform) and + 7% under O5. 

Given the difficulty to forecast ex-ante a) the “natural” growth of visa-required travellers and b) the 
impact of the introduction of a single EU visa application platform (precise quantitative correlation), 
an assessment of the costs and benefits has been carried out with a stable figure (16.9 million applied 
for in 2025-2029) in the sensitivity analysis (Annex X). 

Table 4: Comparison of costs and benefits69  

Economic impact  

Comparison of each option against baseline (Option 1) 

Option 1  

Option 2 

Option 3 

Option 4 

Option 5 

GDP contribution 
(over 2025-2029) 

EUR 392.3 
billion 

Benefit: 
 0 

Benefit:  
EUR 8.7 billion 

Benefit: 
EUR 19.1 billion 

Benefit:  
EUR 38.9 billion 

EU level 

No impact  

Costs 
EUR 3.5 – 6.4 
million spent on 
technical costs 
(one-off) 

Costs 
EUR 25.7 – 31.3 
million spent on 
technical costs (one-
off) 

Costs 
EUR 33.8 – 41.2 
million spent on 
technical costs (one-
off) 

Costs 
EUR 34.0 – 41.5 
million spent on 
technical costs (per 
year) 

EUR 3.5 – 6.0 
million spent on 
technical costs 
(2025- 2029) 

EUR 44.5 – 54,4 
million spent on 
technical costs (2025 
– 2029) 

EUR 52.5 – 63.9 
million spent on 
technical costs (2025 
– 2029) 

EUR 52.5 – 64.4 
million spent on 
technical costs (2025 
– 2029) 

Member States 
(aggregate numbers – 
all Member States) 

EUR 638.5 
million spent on 
admin burden 
(2025-2029) 

12 699 FTEs 
needed (2025-
2029) 

EUR 2.5 million staff 
costs for eu-LISA to 
support development 

EUR 2.5 million staff 
costs for eu-LISA to 
support development 

EUR 2.5 million staff 
costs for eu-LISA to 
support development 

Costs 
EUR 30.9 – 37.7 
million spent on 
technical costs (one-
off) 

Costs 
EUR 68.3 – 83.5 
million spent on 
technical costs (one-
off) 

Costs 
EUR 68.3 – 83.5 
million spent on 
technical costs (one-
off) 

EUR 27.5 – 33.5 
million spent on 
technical costs (2025 
– 2029) 

EUR 58.0 million – 
70.5 million spent on 
technical costs (2025 
- 2029) 

EUR 58.0 million – 
70.5 million spent on 
technical costs (2025 
- 2029) 

69 Due to rounding, some totals may not correspond exactly with the sum of the separate figures. 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Economic impact  

Comparison of each option against baseline (Option 1) 

Option 1  

Option 2 

Option 3 

Option 4 

Option 5 

Benefits 
EUR 257 million 
saved on admin 
burden & real 
estate (2025-2029) 

Benefits 
EUR 364.3 million 
saved on admin 
burden & real estate 
(2025-2029) 

Benefits 
EUR 510.9 million 
saved on admin 
burden & real estate 
(2025-2029) 

Benefits 
EUR 521.6 million 
saved on admin 
burden & real estate 
(2025-2029) 

4 014 FTEs saved 
(2025-2029) 

6 417 FTEs saved 
(2025-2029) 

9 685 FTEs Saved 
(2025-2029) 

9 936 FTEs saved 
(2025-2029) 

Third country 
nationals (aggregate 
numbers – all third 
country nationals over 
2025-2029) 

EUR 74 per 
applicant spent 
EUR 7.4 billion 
total spent for all 
applicants 

Benefits  
EUR 31 per 
applicant saved 
EUR 2.7 billion 
saved  

Benefits 
EUR 31 per 
applicant saved 
EUR 2.7 billion 
saved 70 

Benefits 
EUR 31 per 
applicant saved 
EUR 2.9 billion 
saved  

Benefits 
EUR 72 per applicant 
saved 
EUR 6.9 billion 
saved  

The  impact  on  GDP,  as  mentioned  above,  would  very  much  depend  on  the  “natural”  growth  of 
travellers and the impact of the simplification of procedures on the choice of travel destinations for 
visa-required tourists. The additional contribution to GDP figures must be carefully interpreted in the 
light of these considerations as they rely on assumptions. On the basis of World Bank data relating to 
the impact of tourism on GDP,71 option 3 would lead to 1.1 million extra travellers over the 2025-2029 
period and to EUR 8.7 billion extra benefits; option 4 would lead to 3.9 million extra travellers over 
the 2025-2029 period and to EUR 19.1 billion extra benefits; and option 5 would lead to 8.4 million 
extra-travellers over the 2025-2029 period and to EUR 38.9 billion extra benefits. 

For EU institutions and agencies, O2 would entail limited one-off costs at EU level to develop the 
web service to allow applicants having applied through national portals to check the validity of their 
visa. O3 to O5 would entail one-off and yearly costs related to developing and maintaining the EU 
digital  application platform: such costs would be slightly higher under  O4 compared with  O3;  and 
slightly higher under O5 compared to O4. Therefore, O2 would be the least costly for EU institutions 
and agencies, while O5 would be the most costly option. 

Member States would continue to spend time and incur costs due to the inefficient visa process under 
O1. O2 would not produce significant cost savings during the application process for Member States, 
which would however save all current costs and time efforts related to managing the visa sticker. The 
same cost savings would also materialise under O3 and O4. O3 to O5 would bring about an incremental 
reduction of the current administrative burden related to the application process, with savings doubling 
between options O3 and O4. At the same time, Member States would incur one-off and yearly costs to 
develop and maintain the EU digital application platform: on average for one Member State such costs 

70 The amount saved per applicant is the same for the options 2, 3 and 4 (EUR 31), but as the number of the applications increase from O2 to O4 the total 
benefit increases accordingly.  
71 The World Bank – World Development Indicators, 
https://databank.worldbank.org/reports.aspx?source=2&series=ST.INT.RCPT.CD&country=AUT,BEL,BGR,DNK,EUU.  

39 

 
 
 
 
 
 
 
 
 
 
                                                           
would be slightly lower under O3, and roughly the same under O4 and O5. O4 and O5 would require 
slightly higher investments by Member States than O3, but these investments would be very largely 
offset by much higher cost savings under these two options. Nevertheless for O5 the additional security 
risks in relation to the specific objective 2 would decrease the efficiency of this option (cost in relation 
to effectiveness). 

For third country nationals, no cost savings would materialise under O1 as they would continue to 
spend  time  and  money  on  visiting  a  consulate/VAC  to  pick  up  their  travel  document  with  the  visa 
sticker. O2 would enable repeat applicants to save travel costs during the application process and pick-
up costs (EUR 2.7 billion saved over 2025-2029). A slightly higher total cost savings would materialise 
under  O3  and  O4  due  in  part  to  a  slightly  higher  number  of  visa  applications  allowed  by  the 
introduction of a single EU application platform. In addition, the overall efficiency is expected to be 
higher for third country nationals under O4 than O3 as they will be able to use a single application 
platform whatever their Member State of destination would be. This would save them time and efforts 
to apply as they would also be able to save and reuse their data for a subsequent application. Moreover, 
under O3 some Member States might neither use national digital tools nor the EU application platform, 
which would be sub-optimal for third country nationals. Under O5 all third country nationals (including 
first-time  applicants)  would  save  these  costs,  and  it  would  be  the  most  beneficial  option  for  third 
country nationals (EUR 6.8 billion saved over the 2025-2029 period)72.  

The main benefits would appear for Member States and visa applicants. The reduction of administrative 
costs for Member States and of application costs for visa applicants would be substantial even with a 
stable  number  a  visa  issued/traveller  throughout  the  period  (16.9  million  applications  per  year,  cf. 
annex  5  sensitivity  analysis).  Even  if  the  proposal  would  not  generate  any  GDP  contribution,  the 
benefits still largely outweigh the costs. 

Table 5: Overall result for the efficiency criterion  

Criteria  

EU-level & Member States 
Third country nationals 
Overall efficiency 

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

0 
0 
0 

1.5 
1.5 
1.5 

1.7 
1.5 
1.6 

2.5 
2 
2.25 

1.5 
2.5 
2 

O4 gets the highest score with 2.25, followed by O5 (2).  

7.3.  Other impacts 

For personal data protection and coherence with EU Charter of Fundamental Rights, a score on 
a  0  to  3  scale  was  used  (3  indicating  the  maximum  protection  of  personal  data/coherence  with 
fundamental  rights,  0 indicating the lowest  protection, equalling to  minimum compliance with  data 
protection and fundamental rights law). 

72 The cost savings under O5 are higher than the costs under the baseline (EUR 8.3 bn vs EUR 7.4 bn). This is due to the higher number of applicants 
under option 5 that under the baseline due to the incentive to travel triggered by digitalisation. The savings per applicant (EUR 74) are therefore multiplied 
by a higher number of applicants than in the baseline, which result in a higher amount of cost savings. 

40 

 
 
                                                           
7.3.1.  Data protection 

As underlined by the EDPS, the higher degree of digitalisation, the greater the risks to data protection. 
This guiding idea is reflected in the scores on data protection. 

Opportunity to further standardise data protection practices 
O1 would ensure full compliance with data protection law, but no standard would be applied across 
Member States to enhance data protection practices via higher standardising. Under O2, mandatory 
standards  would  introduce  technical  and  operational  changes  that  may  enhance  data  protection  by 
enhancing security and level of compliance, and have effect of further harmonising national practices. 
O3 to O5 would significantly harmonise data processing practices across Member States thanks to the 
EU visa application platform. However, under O3 a subset of Member States would continue to apply 
their own practices subject to EU standards. O4 and O5 would allow for the greatest opportunity to 
apply improved data protection practices for visa processing in a more harmonised way. Both options 
would also offer opportunities to implement common training & practices due to the use of a single 
tool by Member States. The systematic integration of the “data protection by design” principle will 
allow mitigating data privacy and security risks associated to data protection at development stage.  

Handling of personal data by ESPs 
Under O1, the personal data of visa applicants would still be exposed to ESPs as is currently the case. 
O2 to O5 would progressively change the involvement of ESPs in relation to personal data. The new 
processing that ESPs would need to carry out to enhance identification of applicants for the consulates 
would slightly increase the handling of personal data by ESPs under O3 to O5 to prove that they have 
correctly identified the applicant. Nevertheless, under O3 to O5, repeat applicants would no longer to 
use ESPs services and therefore data exposure to third parties should decrease. 

Data security 
O2 would not significantly expose personal data of third country nationals to higher security risks than 
it is currently the case – except for the data that can be consulted via the web service in O2. Options 
O3 to O5 would lead to new data security implications due to the EU visa application platform, and 
O5 would add implications related to  biometric  data submitted digitally.  O5 would entail  the most 
significant data security implications, that could however be mitigated if implemented in a “privacy 
enhancing” way. Under options implying the use of the EU Visa application platform, the choice of 
the hybrid or decentralised sub-option for the storage of data would avoid the risk of having a single 
point of failure and attacks. 

Data protection would therefore slightly improve with the reduction of exposure of personal data to 
ESPs, with a slightly better score under O4 allowed by the standardisation of data protection practices 
with the generalisation of the EU Visa application platform. O5 would score negatively because the 
self-enrolment of biometrics would create additional risks of data exposure. 

41 

 
 
 
Table 6: Overall result for the data protection criterion  

Criteria  
Protection of personal data 

Option 1 
baseline 
0 

Option 2 

Option 3 

Option 4 

Option 5 

0.5 

0.75 

1  

-1.5  

7.3.2.  Coherence with the EU Charter of fundamental rights 

Under O1 and O2 the visa process would be mostly paper-based and visa applicants would have the 
possibility to receive on-site assistance from ESP or consulate staff. These options would therefore 
have a positive impact in terms of ensuring the equal treatment of visa applicants, including those with 
low IT literacy/access and those who are unable to see or hear. O1 will not significantly improve access 
to the procedure for persons with disabilities reducing their mobility considering that they would still 
need to visit a consulate/VAC often. 

Under O3 to O5, people with reduced mobility would increasingly benefit from the lower need to visit 
a consulate/VAC. On the other hand, these options would limit the possibility to have recourse to a 
paper-based,  in-person  process  as  a  rule,  which  can  be  more  adequate  for  certain  categories  of 
applicants. Under these options these applicants would still be able to apply at a consulate/VAC if the 
assistance provided by the EU visa application platform, by service providers and family/friends is not 
sufficient73.  

For  people  with  impaired  vision,  applying  online  will  most  likely  be  an  improvement  as  digital 
application platforms, either at EU or national level, have to comply with Accessibility Directive under 
which Member States have to ensure that ‘public sector bodies take the necessary measures to make 
their  websites  and  mobile  applications  more  accessible  by  making  them  perceivable,  operable, 
understandable  and  robust’74.  Websites  should  therefore  allow  changing  the  display  of  information 
(font size, colours, etc.) and could also offer audio assistance (reading out texts). These tools are not, 
or to a lesser extent, possible with paper applications. In addition, O4 and O5 and to a lesser extent O3 
would guarantee high accessibility to people unable to see or hear across all Member States, because 
the standards and features embedded in the EU application platform would be applied by all countries. 

In  the  same  vein,  under  O3  to  O5  people  with  low  IT  literacy/access  would  increasingly  require 
technical assistance. Nevertheless this might be partially mitigated by the increase of IT literacy all 
over the world. In the first years, the immediate transition to full digitalisation under O5 might create 
issues due to lack of IT literacy of some applicants and the reluctance of some third country nationals 
to submit their biometrics for privacy reasons. 

73 This has been factored in the calculation of costs and benefits, assuming that 3% of the applications would still be made through paper applications. 
This would concern applicants who cannot apply online or applicants that are required to provide paper supporting documents. Given the applying through 
digital means will be far easier than through paper at the consulate, the percentage will be very low. 
74 DIRECTIVE (EU) 2016/2102 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 26 October 2016 on the accessibility of the websites 
and mobile applications of public sector bodies. 

42 

 
 
 
 
                                                           
 
As to the rights of the child, the applicable legislative regime which guarantees the on-site process for 
children would remain in place. The revised VIS introduced changes aimed particularly to strengthen 
the fight against the abuse of children’s rights by lowering the fingerprinting age (from 12 to 6 years), 
but also imposing strict safeguards to biometric data of children, in particular by limiting the storage 
period of the data: fingerprints and facial images pertaining to children below the age of 12 will be 
erased  upon  the  visa  having  expired  and  the  child  having  exited  the  external  borders.  For  repeat 
applicants with children, a new repeat application will necessitate another on-site procedure in all such 
cases (relevant for O1-4). Given that O5 will not require any visit to the consulate or ESPs, it will be 
slightly less adequate in relation to the rights of child. 

Overall,  all  policy  options  comply  with  the  fundamental  rights  enshrined  in  the  EU  Charter. 
Nevertheless  O5  score  is  lower  than  the  other  options  due  to  the  absence  of  physical  visit  of  the 
applicant and his/her child to apply for a short-stay visa. 

Table 7: Overall result for fundamental rights criterion  

Criteria  

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

Coherence with Charter of Fundamental Rights 

0 

0 

0 

0 

-0.5 

7.3.3.  Political feasibility and proportionality 

Considerations on the proportionality and political feasibility are not criteria of the evaluation per se 
but are indicated as additional information on each option in the context of this impact assessment. 

  Political feasibility 

The status-quo under O1 would be feasible because no legislative amendments would be needed and 
the European Commission but could be perceived as insufficient by the Member States. While the same 
concept of standards would be adopted in  O2, the standards would be mandatory and require more 
efforts  and  discussions  to  be  agreed  upon.  In  addition,  the  digital  visa  would  require  amendments. 
However, O2 would meet more effectively the objectives and the political climate, and hence be more 
feasible. 

On the basis of targeted consultations of Member States on this initiative, it seems that it would be 
slightly easier under O3 to get a political agreement as Member States would be left the choice to join 
or not the EU application platform and some may favour they own tools already in operation over an 
EU system which only exists on paper at this point in time. However, this can be expected to evolve 
over  time  as  the  EU  system  leaves  the  drawing  board  and  becomes  reality  through  the  application 
platform prototype currently being developed by the Commission with eu-LISA to test and demonstrate 
the benefits of a single application platform. In addition, under O4 the transition period (e.g. five years) 
as well as the hybrid architecture system, allowing Member States to re-use part of the investments 
carried out for their national portals, should allow a smooth process to join the EU single application 
platform.  In addition,  it  might be expected than the European Parliament  would be supportive of  a 
single  EU  application  platform  at  EU  level  for  all  Member  States.  Under  O5  the  absence  of  a 

43 

 
 
transitional period, which would discourage some Member States and the online biometric enrolment, 
which  is  likely  to  be  endorsed  by  only  two  Member  States  could  be  disproportionate  vis-à-vis  the 
various policy objectives, because it is not per se required to make the EU more digital and to simplify 
to a large extent the current process, and because it is bound to decrease the security of the visa process. 

  Proportionality 

All options except O5 would not go beyond what is necessary to achieve the objectives.  O5 would 
achieve the objectives to a certain extent (except security objectives), but would introduce a measure 
–  the  online  biometric  enrolment  –  that  would  be  disproportionate  vis-à-vis  the  objectives  to  be 
achieved (in particular due to its impact on security, cf. 6.2.1). 

Conclusion on the comparison of options 

O1 would only partially achieve some of the objectives, and to a large extent because it would maintain 
the visa sticker. Existing problems and costs would largely persist for all stakeholders despite more 
Member States being expected to operate a national online portals in the coming years.  

O2 would perform better than O1 in all departments. It would achieve the policy objectives to a wider 
extent, although it would not simplify and harmonise the visa process to achieve the objectives of the 
initiative. In terms of efficiency, O2 would enable some cost savings and efficiency gains for Member 
States and third country nationals. Overall, given the political consensus around visa digitalisation, O2 
would be politically more feasible than O1.  

O3 would perform better than O1 and O2 in all departments, except for environmental impact. It would 
go  an  extra  step  in  simplifying  and  harmonising  the  visa  process,  although  the  optional  EU  visa 
application  platform  is  a  key  limitation  and  drawback  in  terms  of  improving  attractiveness  and 
simplification  of  procedures  for  third  country  nationals.  In  terms  of  efficiency,  O3  would  require 
substantial one-off and yearly investments from the EU and the participating Member States but would 
produce  higher  long-term  cost  savings  and  efficiency  gains  for  Member  States  and  third  country 
nationals compared to O2. Nevertheless, the costs attached to this option are underestimated as the 
costs of development of national  portals for those Member States who will not opt for the EU  visa 
application platform are not taken into account in this assessment as they are impossible to assess75. 

By extending the benefits of the EU visa application platform to the whole Schengen Area, O4 would 
perform better than O3 in terms of effectiveness as it would be the best option to achieve the objectives 
described in the intervention logic. It would significantly improve the external image of the Schengen 
Area compared to O3. In terms of efficiency, O4 would still require one-off and yearly investments 
from  the  EU  and  from  all  Member  States  but  would  also  produce  high  long-term  cost  savings  and 
efficiency gains for all Member States than O3. In addition, it would enable higher cost savings for 

75 The amount of these costs would depend on the decision of the Member State to join or not the EU visa application platform if option 3 is finally 
retained as the preferred option and the level of digitalisation of this Member State at the time of the adoption of the EU regulation. 

44 

 
 
 
                                                           
third country nationals. In relation to other impacts, O4 would be a good option from the point of view 
of data protection and compliance with the charter of fundamental rights, provided the right safeguards 
are put in place in its implementation.  

O5 would simplify/harmonise the visa process more than any other option; however, it would impact 
negatively EU security, performing worse than O1 in this area. In terms of efficiency, O5 would require 
similar investments to O4 from the EU and the Member States and would produce the highest cost 
savings for third country nationals but its efficiency for Member States would be reduced as it would 
undermine the security of the Schengen area.  

Overall, O4 is considered the preferred option as it would best achieve all the objectives set by the 
initiative.  It  would  simplify  and  harmonise  the  visa  application  procedure  and  would  reduce  the 
administrative burden and costs for visa applicants and Member States. It would also be the best option 
from a security point of view.  O4 would also be a good option with regards to data protection and 
fundamental rights. Regarding its impact on environment, O4 would reduce paper consumption and 
CO2 emissions linked to the application process. The additional amounts of CO2 linked to additional 
travellers  to  the  EU  would  very  much  on  the  additional  number  of  travellers  and  on  the  expected 
reduction of air travels carbon footprint, which are difficult to predict. 

8.  PREFERRED OPTION 

8.1. 

 Why O4 is preferred policy option  

O4 implies the development of a mandatory EU digital visa application platform for Schengen visas 
and mandates the use of the digital  visa. A transitional period  of  five  years  would be  envisaged  to 
enable  those  Member  States  using  or  developing  their  own  national  visa  portals  to  phase  out  their 
national solutions and join the EU initiative. The adhesion of Member States to the EU visa application 
platform  will  happen  gradually,  as  not  all  Member  States  are  expected  to  need  the  full  transitional 
period.  

Under  this  option,  third  country  nationals  can  apply  for  a  Schengen  visa  entirely  online,  via  the 
platform. For first  time applicants,  for repeat  applicants  every five  years, applicants  travelling with 
children and applicants who will be travelling on a different travel document than the one used for 
previous visa applications, it would still be necessary to  travel  to  the consulate or VAC to  provide 
biometrics and for identification purposes. 

The preferred option would contribute to tackle the root causes of the current problems and would 
remove  the  fragmented  and  paper-based  visa  application  process  and  harmonise  the  current 
heterogeneous levels of digitalisation.  

Although the preferred option envisages the implementation of an EU visa application platform and 
gives  third  country  nationals  the  possibility  to  lodge  their  application  and  file  their  supporting 

45 

 
 
 
documents digitally, some third country nationals might still need to go to apply in person using the 
paper process. The assumption is that each year across the Schengen Area 3% of visa applicants will 
not  utilise  the  digital  solution  even  if  it  is  available  and  will  still  apply  in  person  using  the  paper 
process.76 This has been reflected in the cost and benefit calculations. O4 also presents some relative 
weaknesses that would be nevertheless largely outweighed by its comparative advantages. Firstly, O4 
would involve relatively high costs for EU institutions linked to the implementation of the EU visa 
application platform77 in comparison with the cost of other options (O2 and O3 to a lesser extent). The 
political feasibility of O4 may be slightly lower than O1, O2 and O3, due to the obligation for Member 
States  to  phase  out  their  national  portals  at  the  end  of  the  transition  period  to  join  the  EU  visa 
application platform. Nevertheless this would be mitigated by a long transition period proposed (e.g. 5 
years) and the choice of the decentralised option for the storage of applications that would mitigate 
potential sunk costs for Member States who have already partially digitised their application process 
(see 8.2.1). In addition, it must be stressed that the impact assessment did not take into account the cost 
for Member States to develop their own national application portals in the absence or in addition to the 
EU visa application platform as this would have been impossible to assess78. Taking into account this 
parameter would have further decreased the efficiency of options O2 and O3 and would have further 
reinforced the comparative performance of O4 relating to efficiency. 

The operational objectives pursued by O4 will be the following ones: 

  To reduce the costs associated with the visa application for Member States  
  To reduce the costs associated with the visa application for third country nationals 
  To reduce the need for visa applicants to be physically present themselves at the consulate 
  To replace the visa sticker by a digital visa 
  To allow all visa-required travellers to apply through a single application tool 
  To increase the flow of visa required travellers in Europe 

8.1.2. Benefits linked to the introduction of an EU visa application platform for Member States  

The main change would be that third country nationals would now be able to use one environment - 
the EU visa application platform- to submit their visa application fully online, including supporting 
documents and travel document and to view their digital visas (or refusals), regardless of the Member 
State where they apply. This, combined with an EU visa application platform implementing a unified 
and harmonised approach to visa digitalisation, will create a set of benefits for Member States and third 
country nationals  and make the overall application process more efficient. The EU visa application 
platform would create the following benefits: 

76 This would concern applicants who cannot apply online or applicants that are required to provide paper supporting documents. 
77 Between EUR 33.8 and 41.2 million (one-off cost) and EUR 10.5 and 12.8 million (yearly cost) – Study to assess the various options related to visa 
process digitalisation and to support the preparation of an impact assessment  - Final Report, available: https://ec.europa.eu/home-affairs/study-assess-
various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 
78 This calculation would have required hypothesis on the number of Member States who would have wanted to develop their own portal under O1, O2 
and O3, a very detailed assessment of the digitalisation of their visa application process and hypothesis on the IT solutions retained to calculate their costs.  

46 

 
 
 
                                                           
1.  Reduction of the administrative burden and costs for Member States: 

  Less time answering queries by applicants for ESPs and consulates. This comes as a result of 
the platform’s interactive guidance and chatbot. The assessment estimates up to 576 FTEs79 could 
be saved across all Member States over the 2025-2029 period.  

  Reduction  of  processes  linked  to  paper  visa  applications,  i.e.  taking  in  a  paper  application, 
encoding it and collecting the visa fee, would also decrease since the consulates would no longer 
need to do this manually. The assessment estimates up to  867 FTEs80 saved across all Member 
States over the 2025-2029 period. 

  Filing  and  archiving  of  paper  applications  would  no  longer  be  needed.  The  assessment 
estimates up to 4 248 FTEs81 saved across all Member States over the 2025-2029 period. Since the 
documents no longer need to be archived for two years at the consulates, the associated costs can 
be saved. The feasibility study82, conducted in 2019, had estimated these costs up to EUR 920 000 
yearly  across  all  Member  States,  i.e.  EUR  4.6  million  over  the  2025-2029  period.  Under  O4 
Member States would only spend a small amount corresponding to the remaining storage of 3% of 
the paper applications,  i.e. a total  saving of  EUR  4.4 million  over the 2025-2029 period  for  all 
Member States. On top of that, consulates would no longer need to pay the costs to destroy the 
applications  and  supporting  documents  after  the  end  of  the  retention  period.  These  costs  were 
estimated up to EUR 5.0 million across all Member States on a yearly basis83. 

2.  Mitigation of sunk costs for Member States having already invested in digitalisation: 

The choice of the hybrid/decentralised architecture system under O4 (see point 8.2.1) would 
allow mitigating  sunk costs for Member States who  have already invested in digitalisation. 
Member States which already offer a digital application form could potentially re-use the integration 
to  upload  application  forms  in  their  national  systems  used  for  processing  applications  (e.g., 
registration in VIS) for the EU Application platform. In addition, Member States could also reuse 
some investments made in infrastructure, such as storage capacity. The transition period of years 
would also mitigate potential sunk costs of Member States. Taking into account the development 
phase of the platform (2 years) and its go live date, as from which the transition period of five years 
will start, Member States will have the time (7 years if a five-years transition period is eventually 
retained)  to  amortise  their  investments  and  prepare  the  transition  to  the  EU  Visa  application 
platform.  Additionally,  Member  States  will  be  able  to  use  EU  funds  available  under  the  Border 
Management and Visa Instrument (national programmes) to finance their investments at national 
level, facilitating the transition towards the EU Visa Application Platform. 

3.  Other benefits: 

79 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 
80 Idem. 
81 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 
82 Study on the feasibility and implications of options to digitalise visa processing, 2019, available: https://op.europa.eu/s/pgU6.  
83 Study on the feasibility and implications of options to digitalise visa processing, 2019, available: https://op.europa.eu/s/pgU6.  

47 

 
 
 
 
                                                           
  The EU visa application platform would directly reduce the cases of visa shopping. With one 
single way to apply for a short-stay visa, applicants would not be tempted to go for the easiest and 
most  expeditious  way  of  applying,  independently  of  the  Member  State(s)  where  they  intend  to 
travel. Applicants should be required to fill out a brief questionnaire after which the platform will 
automatically  redirect  the  applicant  to  the  correct  Member  State.  This,  together  with  the  cross-
referencing of these answers with the data submitted by the applicant, makes it more difficult, if 
not impossible without fraudulent information, to engage in visa shopping84. 

  A more efficient process linked to VIS pre-admission checks. Before submitting an application the 
VIS read-only database would be checked for the presence/validity of biometrics which is one of 
the admissibility criterion. An application would not be submitted if these checks show that there 
are no valid biometrics available in the VIS. 

The preferred option would harmonise and digitalise the visa process across Member States, improving 
the efficiency of the overall process. It would project outside the EU a unified and coherent image of 
the visa policy and improve visibility of the EU action in this area. Implementing a mandatory EU visa 
application platform would give significant substance to the Commission’s ambition expressed in the 
New Pact on Migration and Asylum, to have the visa procedures fully digitalised by 2025 to reinforce 
trust in the Schengen area.  

8.1.3. Benefits linked to the introduction of a digital visa for Member States  

The preferred option would remove the obligation to issue a paper visa sticker through legislation and 
would oblige Member States to issue a digital visa and to check an individual’s visa through his/her 
biometrics or with an encrypted 2D barcode. The feasibility study85 determined that the digital visa 
should  be  implemented  with  a  ‘fall-back  solution’  in  case  VIS  is  not  available,  e.g.  central  system 
failure  or  local  network  failures.  The  study  identified  an  encrypted  2D  barcode86,  received  by  the 
applicant when his/her visa is issued, to be the most secure and fraud-proof fall-back solution. As a 
result, the internal security of the Schengen Area would improve, as the visa sticker could no longer 
be falsified87.  

The biggest positive impacts of the digital visa are related to administrative burden. The introduction 
of the digital visa would considerably reduce the administrative burden on Member States central 
authorities  and  consulates.  Central  authorities  would  no  longer  have  to  spend  time  and  money  on 
manufacturing, ordering and securely transporting visa stickers to the consulates. Consulates on the 
other hand would no longer need to spend time on printing the sticker and affixing it to the passport or 
on a separate sheet in case the travel document is not recognised by the Member State. The analysis 
estimates the equivalence of nearly 4 014 FTEs could be freed up across Member States consulates 

84 The replies of the applicant to the introduction questionnaire will automatically be compared to the data he filled out in the application, e.g. when an 
applicant indicates (in the questionnaire) that he is visiting France for tourism, but then (during the application) indicates hotel reservations in Germany.  
85 Study on the feasibility and implications of options to digitalise visa processing, 2019, available: https://op.europa.eu/s/pgU6. 
86 This fall-back solution will re-use existing national solutions for printing an encrypted 2D barcode on the visa sticker, available from May 2022. 
87 Cases of visa sticker fraud were already limited and as long as every travel authorisation is checked with biometric data against VIS data, there is no 
opportunity to cross the border illegally. With the digital visa and EES, every traveller will need to be checked against the VIS with his/her biometric 
identifiers, removing any opportunity for fraudulent activities. 

48 

 
 
                                                           
over  the  2025-2029  period.  Cost  savings  related  to  the  stickers  themselves  are  estimated  at 
approximately EUR 80.3 million across all Member States over the 2025-2029 period. 

The impact assessment assumes that the systems that will generate the encrypted 2D barcodes will be 
the same as the systems currently being set up by Member States to generate a 2D barcode to be printed 
on the visa sticker, leading to no impact at the national level. The change of generating one type of 
barcode  to  another  type  of  barcode  can  be  considered  as  part  of  the  normal  system  evolutionary 
lifecycle. 

Overall,  the  costs  and  benefits  for  Member  States  linked  to  the  introduction  of  an  EU  digital  visa 
application platform and to a digital visa are summarised in the table below: 

Table 8: Summary of costs and benefits for Member States  

Costs 

Per Member 
State (average) 

All Member 
States 

Benefits 

Per Member 
State (average) 

All Member States 

One-off 
costs88  

IT 

EUR 2.8 million – 
EUR 3.3 million  

Yearly 
cost89  

IT 

EUR 460 000 – 
EUR 570 000 

EUR 68.3 
million – EUR 
83.5 million 

EUR 11.6 
million – EUR 
14.1 million 

time 

of 
Saved 
consulates 
over 
five years in FTEs 

372 FTEs  

9 685 FTEs 

EUR 19.7 million 

EUR 510.9 million 

time 

Saved 
consulates 
five 
monetary terms90 

of 
over 
in 

years 

Total IT costs 
(2025 – 2029) 

EUR 5.1 million - 
EUR 6.2 million 

EUR 126.3 
million – EUR 
154.0 million 

Costs 
saved  on 
paper  storage  and 
on visa stickers 

EUR 3 million 

EUR 79 million 

One-off 
training costs 

EUR 33 000 

EUR 858 000 

Source: Study estimates based on data provided by Member States, eu-LISA and the 2019 feasibility study. 

8.1.4. Benefits for visa applicants 

The  preferred  option  has  far-reaching  implications  for  third  country  nationals.  The  EU  visa 
application platform, offering virtually the same features and services to applicants91, and the digital 
visa would result in a saving of EUR 2.9 billion for third country nationals, mainly because the need 
to travel during the application process is considerably lowered compared to the baseline situation -O1 
and O2. Pursuing O4 would largely harmonise the currently fragmented landscape of application 
procedures in the Member States, and improve the image of the EU as a unified entity in line with 
the common visa policy.  

88 Including connection to the EU platform; adaptation of national system(s); and upgrades for data storage.  
89 Including operation and maintenance of the platform and VIS. 
90 Assuming a labour cost of EUR 25 per hour. 
91 It should be noted that this is not the case during the transitional period, in which not all Member States will be enrolled  yet. This could potentially 
increase the confusion for third country nationals. However, this period will eventually end, resulting in the permanent abolishment of the fragmented 
landscape.  

49 

 
 
 
 
 
 
 
 
 
                                                           
The possibility for repeat applicants to lodge their application, upload their supporting documents and 
pay  the  visa  fee  through  the  EU  platform,  removing  the  need  to  travel  to  the  consulate  or  VAC  in 
person would produce substantial economic benefits. In principle, under O4 the overall group of repeat 
applicants  (assumed to  be  25% of the total  number of applicants92) would no longer need to  spend 
money on travel and accommodation, resulting in a maximum net saving of EUR 260 million in 2029 
(i.e.  EUR  1.3  billion  over  the  2025-2029  period).93  In  practice,  the  benefits  are  likely  to  be  lower 
because certain applicants may not be allowed/able to submit all supporting documents via the EU visa 
application  platform94  and  the  impact  of  Multiple-Entry  Visas  (MEVs)  needs  to  be  borne  in  mind 
although it cannot be assessed in the context of this report95. 

Furthermore, the digital visa and the abolition of the paper visa sticker would end the need for third 
country nationals to travel or pay a courier to pick up the travel document after the examination process. 
Besides, applicants would no longer need to leave their travel document during the application process, 
enabling them to use it for identification purposes and to travel abroad or back to their country of origin 
if they have to apply in a neighbouring country. In the baseline scenario, the travel and courier cost for 
all  third country nationals would amount to  up to  EUR  318 million  for 2029 alone96 (i.e. EUR 1.6 
billion over the 2025-2029 period). The introduction of the digital visa under O4 would remove this 
expenditure.  This  entails  a  large  benefit  for  third  country  nationals,  as  respondents  to  the  public 
consultation indicated that travelling to the consulate or VAC is the second biggest challenge related 
to the visa application process. 92% of the respondents of the public consultation indicated that the 
implementation of digital visa would facilitate the Schengen visa application procedure. 

O4 would not affect the right of third country nationals who are family members of EU mobile citizens 
to have their applications processed via accelerated and costless procedure and to be granted with every 
facility to obtain the necessary visas. They would still be allowed to lodge their application directly at 
a Member State consulate without any cost, if they decide not to use the EU visa application platform. 
Furthermore, the applications of these third country nationals submitted through the platform would be 
processed as priority files, reflecting their privileged position enshrined in EU Law97 and they would 
be exempted from the visa fee as it is the case today.  

92 Assumption validated with eu-LISA. No official statistics are collected on the share of first-time and repeat applicants. 
93 Based on an average expenditure of EU 56.89for a TCN for travel and accommodation during the application process. This figure has been estimated 
based on the indications on travel costs provided by 246 respondents to the public consultation. It should be noted that 3% of the repeat applicants to still 
travel to the consulate to lodge their application in paper are expected. This is reflected in the estimates. 
94 This will be due to technical difficulties and/or low IT literacy, especially in the short term; and also to the risk profile of each applicant: citizens of 
countries having a low risk profile are likely to be allowed to submit all documents online; however, as certain supporting documents incorporate security 
features only on paper, Member States are still likely to require this evidence on paper from citizens of countries with a high risk profile. 
95 MEVs represent a significant share of Schengen visas and allow visa holders to enter the Schengen area multiple times over a  pre-defined period of 
time, usually up to five years. If travellers hold MEVs, they would be able to make as many trips as they wish to the Schengen area until the period of 
validity of the visa expires without having to incur the current costs of applications. Whilst MEVs are an existing tool to reduce costs for third country 
nationals, the EU platform would deliver substantial benefits on top. This is because MEVs very rarely cover the whole period before a new requirement 
to submit biometrics (i.e. 5 years), and several third country nationals are likely to travel more than once at intervals of e.g. 2-3 years, i.e. outside the usual 
period of validity of a MEV. Moreover, the implementation of the “cascade” system foreseen in the Visa Code, by which  third country nationals can 
benefit from increasingly longer MEVs the more visas they are issued, will still take a few years. 
96 Given the assumption that the amount of third country nationals that travel to obtain the travel documents and third country nationals that pay a courier 
are split evenly. This amount is based on the indicated cost of third country nationals within the public consultation, which includes 241 observations for 
third country nationals that travel and 230 observations for third country nationals that paid a courier.  
97 In accordance with Article 21 TFEU, Directive 2004/38/EC, Article 1(2)(a) of the Visa Code) and part III of the Visa handbook.  

50 

 
 
                                                           
The aforementioned cost savings resulting from an easier online application under O4 would apply to 
these  EU  citizens’  family  members  as  well  and  would  largely  outweigh  the  benefit  of  visiting  the 
official representation of Member State under the expeditious procedure currently in place. This would 
be  especially  the  case  if  the  third  country  national  lived  far  from  a  city  hosting  a  consulate  of  the 
selected  Member  State.  For  those  family  members  who  would  however  decide  to  lodge  their 
application directly at Member State consulate, there would be no change as this possibility would still 
be available and without any costs.  

Table 9: Summary of costs and benefits for third country nationals  

Costs 

Average  costs  for  one  third  country  national  during  the  application  process 
related to travel and accommodation 

Baseline 

Option 4 

Net benefits 

EUR 57 

EUR 43 

EUR 14 

Average  costs  for  one  third  country  national  related  to  obtaining  the  travel 
documents via courier/pick-up 

EUR 17 

EUR 0 

EUR 17 

Total average costs for one third country national per application in addition 
to the visa fee98 

EUR 74 

EUR 43 

EUR 31 

Total cost for all third country nationals for 2025-2029 

EUR 6.5 
billion 

EUR 4 
billion 

EUR 2.999 
billion 

Source: Study estimates based on data provided by Member States and third country nationals (open public consultation). 

8.1.5. Increased security of the Schengen area  

The transition to a visa application process handled via an EU visa application platform and relying on 
the digital visa would strengthen the security of the overall process, contribute to the security of the 
Schengen external borders, and increase trust amongst Member States.  

The digital visa would considerably reduce security risks compared to the visa sticker. This would 
be the case also in a fall-back scenario, i.e. where checks against VIS and other EU information systems 
are technically not possible. It would not be possible to steal blank visas stickers, as it is often the case 
in  Member  States  consulates  today100.  Moreover,  the  digital  visa  may  enable  Schengen  border 
authorities to save time: assuming 10 seconds to verify a visa sticker,101 border guards in the Schengen 
Area would save up to 30 FTEs per year.102 It needs to be noted that these are maximum theoretical 
benefits that may in practice be lower if currently border guards: a) spend less time to verify a sticker 
in  certain  BCPs;  and  b)  verify  the  sticker  while  performing  other  verifications  or  interviewing  the 
traveller, i.e. tasks that would remain in place under O4. O4 will harmonise formats and data quality 
of supported documents uploaded on the EU application platform which provide additional safeguards 
regarding detection of forged documents. 

98 Given the 75/25 split between first time and repeat applicants. 
99 The total cost and benefit results from the multiplication of individual costs and benefits per the number of third country nationals (i.e. 112.5 million 
under O4). 
100 Member States are obliged under the Visa Code to report to the Commission on any significant loss of blank visas stickers. (Art 37 (2). 
101 Average based on estimates provided by Schengen border authorities. 
102 Based on the estimated number of Visa holder-third country nationals travelling to the Schengen Area in 2025. Study to assess the various options 
related  to  visa  process  digitalisation  and  to  support  the  preparation  of  an  impact  assessment  -  Final  Report,  available:  https://ec.europa.eu/home-
affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en for detailed calculations. 

51 

 
 
 
 
 
 
                                                           
O4 would free potential resources for scrutinising visa application. As mentioned at point 8.1.2., 
the EU visa application platform would simplify the process for handling visa applications, enabling 
consulates to save around 1 423 FTEs per year, which, if Member States choose to do so, could be re-
allocated to examination, allowing for a more thorough risk assessment which would further strengthen 
the security of the overall process and have positive spill-over effects on the border crossing process. 

8.1.6. Benefits on the EU GDP linked to increase of travellers to the EU 

The impact of O4 on the EU GDP linked to the increase of travellers to the EU has to be considered 
carefully as it relies on an expected additional number of travellers in the 2025-2029 period which is 
difficult  to  predict.  First  the  “natural”  growth  of  travellers  is  difficult  to  anticipate.  The  estimates 
worked out in the context of this impact assessment rely on a very limited increase of travellers, with 
16.9 million of visa applied for in 2023 (corresponding to the pre-Covid level) and stabilising to 17.8 
million in 2025 with no increase until 2029. In addition the increased number of travellers linked to 
simplification of procedures through digitalisation is also difficult to predict, for reasons explained at 
section 6.4. The estimates take into account an increase of travellers of 2% under option 3 for travellers 
to Member States using the EU Visa application, with larger effect under  O4 due to the use of the 
platform by all Member States and 4% for O5. 

Table 10: Summary of benefits on EU travel on GDP  

Yearly  impact  of  EU  travel 
on GDP (per year 2025-2029) 

Baseline  

EUR 78.5 billion 

Option 4  

Net benefits 

EUR 80.0 billion (2025) 
EUR 81.6 billion (2026) 
EUR  83.3  billion  (per  year 
2027-2029) 

EUR 1.6 billion (2025) 
EUR 3.2 billion (2026) 
EUR 4.8 billion (per year 2027-
2019) 

Overall  impact  of  EU  travel 
on GDP (2025-2029) 

EUR 392.3 billion 

EUR 411.4 billion 

EUR 19.1 billion 

Source: Study estimates based on World Bank data on the contribution of international travel to the GDP. 

8.1.7. Impact of digitalisation on the role of ESPs 

The relations between ESPs and Member States are regulated by contractual relations Depending on 
the agreement between the Member State and the external service provider, the ESP might be currently 
entrusted with the performance of administrative tasks and collection of biometrics and are in no way 
responsible for adjudicating on visa applications.  

In the context of digitalisation, their role will depend on what Member States will want to assign them 
in the context of the new procedures. In the short term, ESPs might be asked to provide assistance to 
applicants (e.g. assistance to people without or with low IT literacy) and their role might increase in 
the  short  term.  However,  with  the  digitalisation  of  the  visa  application  process,  a  large  part  of 
administrative  tasks  currently  entrusted  to  ESPs,  such  as  inserting  information  from  the  physical 
application form, would disappear. In particular, the implementation of O4 is very likely to have an 
impact on ESPs (who collect 90 % of applications worldwide), as applicants will be able to apply 
directly via the online application portal, if they do not need to provide biometrics in the context of 

52 

 
 
 
 
their application (for five years after the first application). Therefore, the role of ESPs with regards to 
collection  of  applications  and  providing  assistance  to  this  category  of  applicants  should  therefore 
decrease.  

Once the digital visa is implemented consulates will no longer keep the travel document for the whole 
duration of the examination. This means that travel documents from third country nationals applying 
at VACs will not physically seen by consulates. One of the approaches envisaged could be to oblige 
ESPs to scan the travel document in three lights (infrared, ultraviolet and normal light) and make a 
video  recording  of  the  on-site  identification  and  biometric  enrolment.  If  this  solution  were  to  be 
implemented, ESPs would likely need some additional staff and resources. Other technical solutions 
could be used, for example using technologies to cross reference enrolled biometrics (facial image and 
fingerprints) with the biometric data embedded in the microprocessor chip of biometric passports. 

Therefore, the role of ESPs in the context of digitalisation would depend on which tasks Member States 
would like to outsource to them in the new digitalisation context. 

8.1.8. Other benefits 

Another advantage of O4 is that it may significantly streamline the data collection, sharing and 
data handling practices of the Member States. Presuming that the mandatory EU platform will have 
been  set  up,  taking  into  account  “privacy  by  design”  from  end-to-end,  it  may  then  contribute  to 
implementing  data  protection  requirements  in  a  more  harmonised  way.  In  addition,  given  the 
compulsory nature of the EU visa application platform for Member States, training of national staff on 
how to comply with privacy and data protection rules and practices may benefit from economies of 
scale as all national staff will receive the same type of training. 

The right to non-discrimination for people with disabilities would not be breached under O4 as 
features such as speech recognition, audio transcription, etc. would make the EU platform accessible 
to  most  third country  nationals  affected by  different  disabilities for all applicant  irrespective of the 
Member State to which they would apply.  

In principle repeat applicants with reduced mobility within five years would no longer be required to 
visit a VAC or consulate to apply. 

O4 would offer safeguard to protect the rights of the child and prevent trafficking by implementing 
IT solutions in the EU application platform to alert the responsible consulate to apply extra care and 
possibly investigate even more thoroughly the circumstances of the new application (e.g. by requiring 
the applicants to do an interview). 

With  regard  to  the  environmental  impacts,  the  preferred  option  drastically  reduces  the  amount  of 
paper  needed:103  the  visa  stickers  no  longer  need  to  be  manufactured  and  the  application  and  the 

103  If  the  status  quo  is  maintained,  all  third  country  nationals  together  would  use  one  million  kg  of  paper  alone  for  their  application  and  supporting 
documents (given the assumptions that an average application entails 10 A4 pages, based on Annex II of the EU Visa Code on the non-exhaustive list of 
supporting documents, and one A4 page weights 0.05kg), as well as an additional 75 000 kg of paper for the non-recyclable visa stickers (given the 
assumption that one visa sticker entails the use of one A4 page. 

53 

 
 
                                                           
supporting documents are lodged digitally. The travels to apply for repeat applicants and to pick up the 
visa sticker for all applicants will no longer be needed, which will have positive impact on the CO2 
emissions.  On  the  other  hand,  the  additional  CO2  emissions  triggered  by  additional  travellers  are 
hypothetical because they rely on a hypothetical number of additional travellers which is difficult to 
predict. In addition, additional emissions might be partially offset by the efforts made by the aviation 
and transport sector to reduce the carbon footprint of airlines and airports104 and by different ways of 
travelling that could have a positive impact on emissions105. 

Table 11: Option 4 - Summary of costs and benefits for the environment  

Impact category 

Baseline 

Option 4 

Net impact 

Required energy and linked CO2 emissions related 
to the storage and management of data 

The use and waste of paper for 2025-2029 

Negative impact 

Positive impact 

Positive impact 

approx. 4.9 million kg 
in paper   

Approx. 1.8 million 
kg in paper  

Approx. 3.1 million 
kg in paper saved 

CO2 emissions related to travelling during the visa 
application process for 2025-2029 

Approx. 2.4 billion kg 
CO2 

Approx. 0.9 billion kg 
CO2 

Approx. 1.5 billion kg 
CO2 saved 

The environmental impact of the uptake in tourism 
in CO2 emissions for 2025-2029 

0 kg CO2 

Approx. 2.9 billion kg 
CO2106 

Approx. 2.9 billion 
additional kg CO2 
emitted  

Source: Estimates based on data provided by a study to assess the various options related to visa process digitalisation and to support 
the preparation of an impact assessment 

8.2. 

Sub-options 

Three dimensions identified in the Inception Impact Assessment have been analysed in relation to the 
preferred option. For each dimension, two sub-options are considered.  

The main findings are presented hereunder, highlighting which sub-option has been chosen for each 
dimension and why.  

1.2.2.  Architecture of the EU digital platform: centralised or hybrid 

The  choice  of  the  centralised  or  decentralised  sub-option  has  been  analysed  in  the  context  of  the 
feasibility study on the digitalisation of visa procedures. 

Regarding the implications for data protection of the two sub options for the architecture of the 
digital application platform, it is important to underline that these sub options concern the final storage 
of visa application files (including the supporting documents uploaded by applicants): the centralised 
architecture  includes  a  centralised  application  file  storage  (by  eu-LISA),  whereas  the  hybrid 
architecture entails the storage at national (decentralised) level. This is without prejudice to the fact 

‘A 

route 

104 The airline industry is committing to decreasing its carbon footprint inter alia by increasing the efficiency of flights and the efficiency of fuel. See 
Thomas  Reynaert  et  al., 
to  net  zero  European  aviation’,  Destination  2050,  2021,  https://www.destination2050.eu/wp-
content/uploads/2021/03/Destination2050_Report.pdf, a study conducted by major airline and space industry associations estimating the potential for 
greening the airline industry until 2050. 
105 Post COVID-19, travellers are expected to spend the same amount of time in a tourist location over a longer trip rather than travelling multiple times 
to that location, see World Travel and Tourism Council (WTTC), ‘To recovery & beyond: The future of travel & tourism in the wake of COVID-19’, 
2020 p. 11 https://wttc.org/Initiatives/To-Recovery-Beyond. 
106 For the reasons explained at 6.3, these figures have to be considered carefully. 

54 

 
 
                                                           
that a specific and well-defined sub-set of data from the application file has to be subsequently stored 
in a centralised EU database – VIS, according to the current rules of VIS regulation, which will not 
change. According to the European Data Protection Supervisor (EDPS), a downside of a centralised 
database, regardless of limitations of access rights, is that there is a single point of failure and attacks. 
Therefore, such a solution is more prone to technical errors and to security breach. Data protection 
safeguards will be included in  the legislative  proposal,  as well  as  during the implementation  stage, 
using the principles of data protection by design and by default. Data stored in the EU visa application 
platform  would  be  safeguarded  using  privacy-enhancing  implementation  measures.  The  feasibility 
study therefore concluded that the centralised storage of visa application files is neither necessary, nor 
proportionate from data protection point of view. 

From  the point of view of Member States  (users  of the platform),  the feasibility Study  and the 
analysis conducted in this Impact Assessment identified a strong preference of Member States for the 
decentralised architecture for the following reasons: 

  Member States have physical ownership of the applications they need to process; 
 

It becomes easier to comply with any national regulations or other rules in place if the data is 
stored and managed by the Member State itself; 

  Member States control the governance surrounding their own infrastructure; and 
  Security and data protection principles can be more easily monitored on national infrastructure.  

The decentralised or hybrid option would also allow mitigating potential sunk costs under O4 
for Member States who have already invested on digitalisation. Member States could potentially 
re-use  the  integration  to  upload  application  forms  in  their  national  systems  used  for  processing 
applications (e.g., registration in VIS) for the EU Application platform. In addition, Member States 
could also reuse some investments made in infrastructure, such as storage capacity.  

Regarding the costs attached to each sub-option, the feasibility study carried out in 2019 has shown 
that the hybrid (or decentralised) one would be more expensive than the centralised one107. However, 
for the abovementioned reasons, the centralised sub-option was assessed as less feasible from a legal, 
technical,  security,  data  protection,  operational  and  implementation  point  of  view.  The  costs  and 
benefits of each policy option presented in this report have therefore been calculated on the basis of 
the decentralised or hybrid sub-option.  

The hybrid or decentralised option has therefore been retained to underpin the operations of the EU 
Visa application platform. 

107 According to the feasibility study on the digitalisation procedures, the hybrid option would be 25% more expensive than the centralised one with a 
total cost of EUR 75-140 million over an eight year period. Of this, EUR 13.4-25 million would be for central systems while each Schengen country’s 
national systems would incur a cost of EUR 2.2-4 million, both over the same period. The centralised option would come at a total cost of EUR 49-91 
million over an eight-year period. Of this, EUR 24.6-45.8 million would be for central systems while each Schengen country’s national systems would 
incur a cost of EUR 0.84-1.6 million, both over the same period.  

55 

 
 
                                                           
8.2.2.  Material scope: only short-stay visas or short-stay & long-stay visas 

Regarding the application procedure, Member States are currently issuing long-stay visas which are 
very different in length and nature. Applications practices and regulations applied by Member States 
to long-stay visas differ greatly as long-stay visas applications are not harmonised at EU level, unlike 
short-stay visas with the Visa Code. An additional feasibility study is therefore required to assess the 
financial, technical and legal implications of the use of the EU visa application platform for long-stay 
visa applications108. 

Regarding  the  digital  visa,  Member  States  currently  issue  long-stay  visas  on  the  same  paper  visa 
stickers  as  short-stay  visas,  in  accordance  with  the  uniform  format  laid  down  by  the  Visa  Sticker 
Regulation (Council Regulation (EC) No 1683/95)109. This Regulation also applies to Member States 
not yet fully applying the Schengen acquis. While the Visa Sticker Regulation only refers to short-stay 
visas, Regulation (EU) No 265/2010110 amended Article 18 of the Schengen Convention to the effect 
that the uniform format is also made applicable to long-stay visas. That Regulation is based on both 
Article 77(2)(b) and (c) and Article 79(2)(a) TFEU. In addition, long-stay visas issued by Schengen 
Member States will be recorded in the future revised Visa Information System (VIS) where they are 
accessible for border guards and police (for inland checks). Carriers will be able to check the validity 
of long-stay visas through the carrier gateway in a read-only copy of the VIS. In addition to this legal 
aspects, a first estimate has shown that an extension of digital visas to long-stay visas would enable the 
Member States  to  save an additional 600 FTEs in addition  to the ones saved on printing short-stay 
visas111. 

It is therefore recommended to extend the digital visa to long stay visas and for the time being not to 
extend the use of the EU Visa application platform to long-stay visas. 

1.2.3.  Fall-back solution for digital visa: simple or digitally signed barcode 

Sub-option  1  –  Visa  issuance  notification  would  consist  of  an  electronic  notification  sent  by  the 
Member State issuing the visa to the visa holder informing the latter that the visa has been granted. It 
can  be  shown  either  on  paper  (print-out)  or  from  a  digital  device.  Sub-option  2  –  Visa  issuance 
notification with digitally signed 2D barcode would be the visa electronic issuance notification plus a 
2D barcode containing the same data as the VIS record that has been encrypted with a digital seal by 
the Country Signing Certificate Authority (CSCA) of the issuing Member State. 

108 A first assessment of the costs is presented in the Study to assess the various options related to visa process digitalisation and to support the preparation 
of an impact assessment - Final Report, available: https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-
support-preparation-impact_en. 
109 Council Regulation (EC) No 1683/95 of 29 May 1995 laying down a uniform format for visas (Official Journal L 164, 14/07/1995 p. 1-4 https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01995R1683-20170817 
110 Regulation (EU) No 265/2010 of the European Parliament and of the Council of 25 March 2010 amending the Convention Implementing the Schengen 
Agreement  and  Regulation  (EC)  No  562/2006  as  regards  movement  of  persons  with  a  long-stay  visa  OJ  L  85,  31.3.2010,  p.  1–4  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265. 
111 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 

56 

 
 
                                                           
Compared to sub-option 1, sub-option 2 would ensure a higher level of security in case VIS cannot be 
reached for technical failure at central level or at the border crossing point/checkpoint.  

In particular, sub-option 2 would: 

  Provide visa holders with a reliable proof of valid visa; 
  Enable reliable border and land checks if VIS is unreachable (fall-back solution), ensuring a higher 

level of security than the visa sticker; 

  Enable checks by third-country authorities cooperating with Member States. 

The encrypted 2D barcode will be readable through mobile devices running a publicly available mobile 
application. Border crossing points and Member Sates police authorities will need to be equipped with 
appropriate smartphones for scanning and reading barcodes. 

The  main  use  case  for  including  a  fall-back  solution  is  to  fill  any  security  gaps  resulting  from  the 
temporary impossibility to access VIS in the context of border or land checks on visa holders, whereas 
authorities today can verify the paper sticker. Carriers might also have to rely on the fall back solution 
if the Read Only VIS cannot be accessed due to technical issues at central or local level. However, the 
intent of the Commission with the fall-back solution is not to introduce a new tool akin to the visa 
sticker, but as a secondary tool to be used only when necessary, and by other stakeholders insofar as 
they do not have access to VIS. 

8.3.  Application of the one-in-one-out approach  

This section describes the expected impacts of the preferred option on EU businesses and citizens.  

  Adjustment costs  

This  initiative would  not  entail  adjustments  costs for the private sector  as it  would mostly  concern 
public authorities and third-country nationals. 

  Administrative costs 

Savings on administrative costs for EU citizens and businesses would be negligible. 

  Indirect benefits 

Tourism  and  travel  sector:  although  difficult  to  quantify  (cf.  consideration  on  impact  on  EU  GDP 
section 6.4), the preferred option is expected to slightly increase the number of travellers, the demand 
for tourism and travel services including transport. This would benefit large EU-based operators and 
regional and local travel industry – i.e. travel agencies, intermediaries, local tourist consortia – and the 
whole  supply  chain  of  the  tourism  industry  –  hotels,  hostels,  restaurants,  bars,  and  their  respective 
suppliers. It will also create benefits for EU-based large companies such as airlines, cruise lines and 

57 

 
 
 
car rental operators, and for regional and local companies, such as ferry operators, bus line operators, 
etc. 

 Lower risk of visa shopping (Not quantified): by providing a single-entry point for all visa applications, 
the EU platform would oblige Third-country nationals to apply for the competent Member State. It 
would limit the input of misleading information on the Member State of entry.  

Benefits for the visa examination process (Not quantified).   If Schengen visa authorities re-allocate 
(part  of)  the  saved  staff  thanks  to  digitalisation  to  decision-making,  Member  States  may  further 
improve the examination and risk assessment of visa applicants, thereby further contributing to EU 
security. 

8.4. 

Sensitivity analysis on the preferred option 

A sensitivity analysis on the preferred option has been carried out to look at how changes in a variable 
can change the result of the impact assessment. This has been done for the following parameters; a 
change in the visa application number, in particular with a stable number of visas issued as in 2019 
(17.8 million applied for in 2025-2029), a delay in the implementation of the digital visa, a gradual 
achievement of the benefits of digitalisation as from 2025 and a lower or higher average time to process 
a visa application. The detailed results are available in Annex 6. All the analysis show that changing 
these  parameters  would  slightly  modify  the  costs  and  benefits  but  would  not  put  into  question  the 
overall assessment of the preferred option. In particular with a stable number of visa applications (16.9 
million instead of 17.8, the benefits for Member States would remain substantial (EUR 487 million 
instead of EUR 510.9 million. For visa applicants, the benefits would amount to EUR 2.7 billion instead 
of EUR 2.9 billion. 

8.5.  REFIT (simplification and improved efficiency) 

Per the Commission’s Regulatory Fitness and Performance Programme (REFIT), all initiatives aimed 
at changing existing EU legislation should aim to simplify and deliver stated policy objectives more 
efficiently (i.e. by reducing unnecessary regulatory costs). However, the proposal stemming from the 
impact assessment will be a new legislation that will modify the existing visa procedures. It will be 
implemented by amending Regulation  (EC) No  767/2008,  Regulation  (EC) No 810/2009  and other 
regulations and by repealing Regulation (EC) No 1683/95. While this initiative has not been subject to 
REFIT  initiative,  it  will significantly  reduce  the  overall  burden  on  administrative  costs  of  Member 
States as mentioned in chapter 8.  

The  digitalisation  of  visa  processes  is  considered  as  a  new  initiative,  regardless  of  the  fact  that  its 
introduction will also formally necessitate an adjustment of several existing legal acts. Introducing a 
visa application portal and digital visa is a major novelty that was not considered in the – targeted – 
amendment to the Visa Code in 2019. Therefore, even if digitalising the visa processes will amend the 
Visa Code again, it will not change any of its recently amended parts. 

58 

 
 
 
9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

It will be essential that the implementation of the preferred policy option and the achievement of the 
objectives is closely monitored. With the implementation of an EU visa application platform and the 
digital visa, the operations in the field of short-stay visas will be impacted, both for visa applicants and 
Member  States.  Monitoring  and  evaluation  should  also  focus  on  potential  risks  in  terms  of  data 
protection.  A  robust  monitoring  and  evaluation  mechanism  would  be  crucial  to  ensure  that  the 
envisaged beneficial effects of the implementation of an EU visa application platform and of the digital 
visa materialise in practice.  

Article 57 of the Visa Code and Article 50 of the revised VIS Regulation on Monitoring and Evaluation, 
that  will  be  largely  impacted  by  the  proposed  changes,  already  provide  for  the  monitoring  and 
evaluation obligations, e.g. to produce an evaluation of its application two years after all the provisions 
of the Visa Code have become applicable. This  general  principle of these articles will apply to  the 
changes stemming from the adoption of the proposal on digitalisation of visa procedures. 

Nevertheless, it is important to define some indicators that will allow measuring progress to reach the 
objectives.  Indicators  should  measure  both  outputs  and  the  impact  of  the  implementation  of 
digitalisation for the different stakeholders that are currently impacted by the current situation. 

Information  could  be  collected  via  the  Visa  Committee,  Travel  document  Committee,  Article  6 
Committee and different agencies (e.g. eu-LISA, Europol, Frontex). 

The proposed indicators will be based on the operational objectives identified for this proposal: 

  To reduce the costs associated with the visa application for Member States; 
  To reduce the costs associated with the visa application for Third-country nationals; 
  To reduce the need for visa applicants to be physically present themselves at the consulate; 
  To replace the visa sticker by a digital visa; 
  To allow all visa-required travellers to apply through a single application tool; 
  To increase the flow of visa required travellers in Europe. 

Table 12: Monitoring indicators based on the operational objectives  

Main objectives 
To reduce the costs associated 
with  the  visa  application  for 
Member States  

Data Sources 
Member States 

Monitoring indicators 
  Number  of  staff  working  on 
collecting/checking 
visa 
applications  
reduced  by  40% 
compared  with  2021 
scenario) 

in  2030112 
(baseline 

112 2030 has been chosen because it would be seven years after the adoption of the legislation by the co-legislators (expected in 2024) i.e. two years 
development and five years transition period. 

59 

 
 
 
                                                           
To reduce the cost associated 
with  the  visa  applicant  for 
third-country nationals 

To replace the visa sticker by 
a digital visa 

  100% of applicants able to receive 
their visa without having to travel in 
2026 
  100% of repeat applicants able to 
fully apply online in 2030 
  100% of digital visas issued out of 
the  total  number  of  visas  issued  in 
2026 

To  allow  all  visa-required 
travellers  to  apply  through  a 
single application tool 
To  increase  the  flow  of  visa 
required travellers in Europe 

  95% of visa applications received 
through  the  EU  Visa  application 
platform in 2030 
  Increase  of 
the  visa-required 
travellers to  Europe  in  2030  by 5% 
compared with 2023 

Member States – eu LISA 

eu-LISA 

Visa  statistics  provided 
yearly  by  Member  States 
(Article 46 - Visa Code) 

Ad-hoc  questionnaires  to 
Member States 
eu-LISA 

Visa  statistics  provided 
yearly  by  Member  States 
(Article 46 - Visa Code) 

Eurostat 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 1 – PROCEDURAL INFORMATION 

1.  Identification of the lead DG  

DG Migration and Home Affairs (HOME) 

2.  Political guidance, Agenda planning and Work Programme 

The Communication for the New Pact on Migration and Asylum of 23 September 2020113 identifies 
clearly the need for full implementation of the recently revised visa code and indicates that additional 
efforts  on  visa  facilitation  will  bring  more  consistency  and  should  encourage  bona  fide  short-term 
mobility. The Pact envisages that by 2025, the visa procedure should be fully digitalised, by introducing 
a digital visa in passports and making it possible to submit visa applications online. In this context, the 
proposed initiative is fully aligned with the objectives of the new Pact on Migration and Asylum.  

Additionally,  the  2021  Commission  Work  Programme  announced  on  19  October  2020  that  further 
work was to be done in order to “preserve and improve a functioning Schengen area”114. The legislative 
proposal  for  the  digitalisation  of  visa  procedures  is  included  in  the  Commission  Work  Programme 
(Annex I), under the Commission priority “Promoting our European Way of Life” and in the context 
of the Schengen package.115  

The initiative also fits with the general EU approach to encourage the modernisation and digitalisation 
of public services and the Commission communication116 on the 2030 Digital compass: the European 
way for the digital decade.  

For DG HOME's Agenda Planning purpose the initiative is titled ‘Proposal  for a Regulation  of the 
European  Parliament  and  of  the  Council  on  digitalisation  of  the  visa  procedures  by  amending 
Regulation (EC) No 767/2008, Regulation (EC) No 810/2009 and other regulations and by repealing 
Regulation (EC) No 1683/95’ with reference PLAN/2020/8747. 

3.  Organisation and timing 

The impact assessment is based on a number of studies, reports and consultations. In Q1 and Q2 2021, 
the  Commission  has  consulted  stakeholders,  organised  meetings  with  experts  and  other  interested 
parties in order to identify problems and develop options for possible action. The internal and external 
meetings organised in order to support the review are listed below. 

113  COM  (2020)  609  final,  Communication  from  the  Commission  on  a  New  Pact  on  Migration  and  Asylum,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1601287338054&uri=COM%3A2020%3A609%3AFIN  
114  COM(2020)  690 
lex.europa.eu/resource.html?uri=cellar%3A91ce5c0f-12b6-11eb-9a54-01aa75ed71a1.0001.02/DOC_1&format=PDF  
115 COM(2020) 690 final, Annexes to the Commission Work Programme 2021, p. 4,  https://eur-lex.europa.eu/resource.html?uri=cellar%3A91ce5c0f-
12b6-11eb-9a54-01aa75ed71a1.0001.02/DOC_2&format=PDF  
116  COM(2021)118  final,  Communication  from  the  Commission,  2030  Digital  Compass:  the  European  way  for  the  Digital  Decade,  https://eur-
lex.europa.eu/resource.html?uri=cellar:12e835e2-81af-11eb-9ac9-01aa75ed71a1.0001.02/DOC_1&format=PDF  

final,  Commission  Work  Programme  2021,  A  Union  of  vitality 

fragility,  p.6,  https://eur-

in  a  world  of 

61 

 
 
 
                                                           
Inter-Service Steering Group  

An Inter-Service Steering Group on the ‘digitalisation of visa procedures’ initiative was set up to which 
the  following  services  were  invited:  DG  HOME,  DG  CNECT,  DG  DIGIT,  DG  EAC,  EEAS,  DG 
INTPA, DG JUST, DG GROW, DG MARE, DG MOVE, DG NEAR, DG RTD, DG TRADE. The 
meetings were chaired by the SG. 

Four meetings took place on 24 November, 6 May, 3 June and 25 June. The first meeting117 introduced 
the context and background of the initiative and presented the draft inception impact assessment as 
well  as  the  terms  of  reference  for  the  cost-benefit  analysis.  At  the  second  meeting118  the  external 
contractor presented the interim report of the impact assessment study and DG HOME provided an 
update on the platform prototype. At the third meeting119 the draft final report was presented to the 
inter-service group. At the fourth meeting120, the draft impact assessment report was distributed and 
presented.  After  each  meeting,  the  members  of  the  Inter-Service  Steering  Group  were  given  the 
opportunity to comment in writing on a draft version of the impact assessment report and its annexes. 
Furthermore several bilateral meetings have taken place with other Commission services in 2021 to 
address specific issues of interest, in particular with DG JUST and the Legal Service.  

Stakeholder meetings and consultations 

  8  March:  Meeting  with  Member  States  (Working  Group  of  the  Visa  Committee  on 

Digitalisation), 

  11 March: Meeting with travel and tourism industry, 
  23 March: Meeting with the EU Fundamental Rights Agency, 
  23 March: Meeting with Frontex, 
  23 March: Meeting with Europol, 
  1 June: Meeting with European Data Protection Supervisor. 

For a precise breakdown of and details on the stakeholder consultation, see Annex 2. 

External contractor 

An external contractor (Deloitte) has assisted DG HOME by conducting a study including a detailed 
cost-benefit  analysis  of  the  different  policy  options  to  support  the  work  on  the  Impact  Assessment 
report. The call for the study was launched in December 2020, following which two substantive bids 
were evaluated, leading to the award decision at the end of January 2021. 

The kick-off meeting for the study took place in February 2021, an inception report was delivered in 
March, an interim report in April, and a final report in June. The reports were designed to feed into the 

117 List participant DGs: DG HOME, DG CNECT, DG DIGIT, DG EAC, EEAS, DG INTPA, DG JUST, DG GROW, DG MOVE, DG NEAR, DG RTD, 
SG 
118 List participant DGs: DG HOME, DG CNECT, DG DIGIT, DG EAC, EEAS, DG JUST, DG GROW, DG MOVE, DG NEAR, DG RTD, SG 
119 List participant DGs: DG HOME, DG DIGIT, EEAS, DG INTPA, DG JUST, DG GROW, DG MOVE, DG NEAR, SG, Legal Service 
120 List participant DGs: DG EAC, DG GROW, DG HOME, DG INTPA, DG JUST, DG NEAR, DG RTD, SG, Legal Service 

62 

 
 
 
                                                           
 
impact  assessment  work  of  the  Commission.  Several  meetings  were  organised  by  the  contractor  to 
discuss the problem definition and to develop and evaluate the policy options. 

4.  Consultation of the Regulatory Scrutiny Board  

to 

the 

the 

simplify 

Feedback provided by the RSB 
The report should be clearer on the objectives to be 
achieved. It should focus on the main problems, i.e. 
burdensome  procedures  and  security  (including 
cybersecurity)  rather  than  tourism.  The  tourism 
related aspects seem uncertain and less obvious (see 
initiative  presents  a  clear 
below),  while 
administrative 
contribution 
procedures  (in  a  wider  context  of  digitalisation  of 
public administrations) and to reinforce security. For 
the latter, the report should strengthen the evidence 
the  paper  visa  sticker  –  despite  recent 
that 
improvements – remains vulnerable to fraud. 
The  sub-options  on  the  architecture  of  the  digital 
platform  (now  in  annex)  should  be  integrated  into 
the policy options of the main report. For example, 
the  report  could  present  two  versions  of  the 
mandatory EU visa application platform option, one 
with a centralised digital architecture and one with a 
hybrid  architecture.  The  report  should  pay  more 
attention to investment in national digital platforms 
already undertaken by Member States and show how 
a hybrid architecture could avoid possible sunk costs 
being wasted. The latter also presents advantages in 
terms  of  cybersecurity  and  protection  of  personal 
data 
The impact analysis should be strengthened with a 
transparent  presentation  of 
the  assumptions 
particularly those underlying the (optimistic) travel 
projections. The sensitivity analysis should test the 
results against a weaker impact of the policy options 
on travel. Caveats should be clearly identified. 

The  report  should  explain  how  the  scores  and  the 
weights  in  the  final  score  are  determined  when 
comparing  options.  The  weight  given  to  the 

63 

Modifications introduced  
The  report  has  clarified  and  simplified  both  the 
general  and  specific  objectives,  accompanying 
them with measurable targets (see sections 4 and 
9);  

The  report  has  provided  additional  evidence 
regarding  the  vulnerability  of  the  visa  sticker  in 
the problem definition (section 2.1). 

The description and analysis of the different sub-
options have been incorporated in the body of the 
report (section 8.2).  

The  tourism-related  aspects  have  been  nuanced 
throughout the report and the related projections 
and estimates have been modified, in particular by 
lowering the average number of visa applications 
per year from 20 to 17.8 million, and lowering the 
impact  of  the  visa  application  platform  on  the 
increase  in  travel  to  the  EU  from  5%  to  2%  in 
options 3 and 4 and from 7% to 4% in option 5; 

A  sensitivity  analysis  with  a  stable  number  of 
travellers has also been included in the report.  
The weight of the environmental impacts has been 
modified in the comparison of policy options and 
moved  under  the  effectiveness  criterion,  in 

 
 
 
 
 
 
environmental impacts should not be reduced in the 
final  score.  Moreover,  the  environmental  impact 
should  be  considered  under 
the  criterion  of 
effectiveness rather than efficiency. 
The report should clarify the data protection issues, 
in  particular by integrating more information  from 
the European Data Protection Supervisor and from 
the  national  data  protection  authorities  from  the 
annexes into the main report. 

accordance  with  the  feedback  provided  by  the 
Board. 

The views of the different stakeholders have been 
better reflected throughout the report, in particular 
those of the European Data Protection Supervisor 
and national data protection authorities. 

64 

 
 
 
 
 
5.  Evidence, sources and quality 

Sources 

In  order  to  gather  quantitative  and  qualitative  evidence  for  the  legislative  proposal,  the  Impact 
Assessment relied on the following sources: 

  a  study  assessing  the  feasibility  and  implications  of  options  to  digitalise  visa  processing, 

providing an initial body of evidence for this initiative, concluded in September 2019;  

  a study conducted by an external contractor (Deloitte) assessing the various options related to 
the digitalisation of the visa process and to support the preparation of the impact assessment;  
  a project with eu-LISA to develop and test a prototype of a future EU online visa application 
platform launched in September 2020, together with an analysis of the costs as well as technical 
and legal requirements of a future EU online application platform, as well as 

  consultation of all relevant stakeholders, which took place over the course of Q1 and Q2 2021.  

Methodology  

The  feasibility  study  assessed  the  costs  and  benefits  associated  with  rolling  out  an  EU  online 
application  platform,  based  on  both  quantitative  and  qualitative  data.  The  cost-benefit  analysis 
considers current costs associated with current national platforms and their future evolution, the costs 
where  no  Schengen  online  application  platform  is  set  up,  and  the  costs  involved  in  setting  up  a 
Schengen-wide  online  application  platform.  The  analysis  considers  both  a  centralised  system 
architecture  and  the  hybrid  system  architecture.  Additionally,  the  costs  are  estimated  in  three  time 
period,  the  current  context,  the  implementation  period,  and  a  future  stable  situation  where 
implementation  is  complete.  Additionally,  the  results  are  based  on  multiple  questionnaires  and 
interviews  with  stakeholders  and  Member  States.  Furthermore,  studies  conducted  previously  and 
public reports on Schengen (visa) operations were taken into account over the course of the cost-benefit 
analysis. Finally, as the online application process contains many similarities to the ETIAS application 
process, these similarities were leveraged in order to refine the estimations. 

The study supporting the preparation of the impact assessment analysed the impact, costs & benefits 
of the different options to digitalise the visa process. In terms of tools, the study applied a combination 
of  multi-criteria  analysis,  cost-benefits  analysis  and  a  Standard  Cost  Model,  under  the  European 
Commission’s Better Regulation  Guidelines. The assessment of impacts  covered a  five-year period 
and  considered  the  complete  visa  cycle  -  application,  examination,  decision,  and  verification.  Data 
analysis  started  during  the  data  collection  phase,  combining  qualitative  and  quantitative  methods. 
Following  the  analysis  of  all  qualitative  and  quantitative  data  collected,  using  a  combination  of 
methodologies, the evidence was systematically crosschecked and triangulated, in order to ensure the 
internal coherence of the study. First, the impacts of the options were assessed, including costs and 
benefits. Then, the results of the impact assessment fed the comparison of the policy options via multi-
criteria  analysis.  Finally,  the  preferred  policy  option  was  elaborated  in  more  detail  with  sub-policy 
options. 

65 

 
 
 
ANNEX 2 – TARGETED AND PUBLIC CONSULTATION 

1. Stakeholder consultation  

As outlined in the consultation strategy, a public consultation and targeted consultations were carried 
out in March 2021, in addition to a study on the feasibility and implications of options to digitalise visa 
processing  and  several  other  activities  previously  carried  out  in  preparation  for  the  impact 
assessment121. 

The main stakeholders consulted include:  

 
third country nationals, in particular those with experience of applying for a Schengen visa; 
  member State authorities in charge of visa issuing (Ministries of Foreign Affairs or national 
migration authorities) and in charge of border controls and law enforcement checks (Ministries 
of Interior); 

  stakeholders in the travel and tourism industry; 
 

relevant EU agencies: Europol, Frontex – for border management/law enforcement aspects, eu-
LISA – for technical and data security aspects; 
fundamental rights stakeholders: FRA, in particular for digital accessibility; 

 
  data  protection  stakeholders  (European  Data  Protection  Supervisor,  national  data  protection 

authorities); 

  wider  public:  citizens  or  NGOs  with  an  interest  in  the  initiative  (through  the  public 

consultation). 

The aim of the targeted and public consultations was to obtain the views of citizens and stakeholders 
on  the  envisaged  initiative,  in  particular  on  the  usefulness  of  an  online  application  process  and 
EU/national application platforms, as well as the replacement of a visa sticker with a digital visa. More 
specifically,  the  consultations  gathered  the  views  of  stakeholders  on  the  impact  of  different  policy 
options, as well as on the legal, economic and practical aspects of the possible digitalisation of the visa 
procedures. This allowed stakeholders to contribute to the impact assessment, and in particular, to the 
development of policy options addressing the problems identified.  

For the targeted consultations, Member States, the representatives of the tourism and travel industry 
and the data protection stakeholders were invited to participate in meetings where they were given the 
opportunity  to  present  their  views  to  the  Commission  services.  Questionnaires  were  distributed  to 
gather their views in a structured manner. In addition, participants had the opportunity to submit written 
position papers.  

121 (i) A study to assess the various options related to the digitalisation of the visa process and to support the preparation of an impact assessment; (ii) A 
project with eu-LISA to develop a prototype of the EU online visa application portal; (iii) A project on digital visas under the Kaliningrad Special Transit 
Scheme managed by Lithuania. 

66 

 
 
 
 
                                                           
Interviews (conducted by the contractor and/or DG HOME) took place, to complement the available 
information with the following stakeholders: 

 

relevant EU agencies: Europol, Frontex – for border management/law enforcement aspects, eu-
LISA – for data security aspects; 

  data protection stakeholders, which includes the European Data Protection Supervisor; 
 

fundamental rights stakeholders, in particular for digital accessibility. 

A public consultation was conducted through an internet-based survey between March and May 2021, 
targeting visa applicants and citizens or organisations who wish to give their input on the modernisation 
of  the  EU's  visa  policy.  Similarly,  organisations  mostly  active  in  the  travel  and  tourism  and 
transportation  sectors  had  the  opportunity  to  share  their  views  through  the  public  consultation. 
Respondents  were  asked  in  particular  to  provide  input  on  economic  impacts  (costs/savings, 
facilitations),  social  impacts,  impacts  on  fundamental  rights  (notably  on  accessibility  issues)  and 
general views on the expected simplification impact of digitalisation.  

The  table  below  provides  an  overview  of  the  different  stakeholders  consulted  and  data-collection 
activities conducted.  

Table 14: Overview of consultation activities  

Activity 

Interviews  with  EU  bodies 
and agencies 

Status 

eu-LISA 

European Border and Coast Guard Agency (EBCGA) 

Europol 

Fundamental Rights Agency (FRA) 

DG JUST Unit C.3 

European Data Protection Supervisor (EDPS) 

Public Consultation 

515 responses received. Closed on 03/06/2021 

Interviews  with  national 
authorities 

Conducted: 19 

Member States survey 

Responses received from: all Member States , except Liechtenstein 

Consultation  with 
protection authorities 

data 

Responses received from: 10 Member States  

67 

 
 
 
 
Consultation  with  tourism 
and travel operators 

(Community  of  European  Railway  and 

Infrastructure 
CER 
Companies), CLIA Europe (Cruise Lines International Association), 
ECSA  (European  Community  Ship  owners’  Associations),  ETOA 
(European Tourism Association), IRU (International Road Transport 
Union),  WTTC  (World  Travel  and  Tourism  Council),  HOTREC 
(Association  of  Hotels,  Restaurants,  Pubs  and  Cafes  in  Europe), 
PEARLE (Live Performance Europe). 

1. Feedback on the Inception Impact Assessment  

A  call  for  feedback,  seeking  views  from  any  interested  stakeholders,  on  the  basis  of  the  Inception 
Impact  Assessment,  was  open  for  response  from  4  December  2020  to  1  January  2021.  This  public 
consultation received six replies from the following stakeholders:  

  companies/business organisation (3 replies); 
  business associations (2 replies) and 
  non-EU citizens (1 reply).  

All the responses have been published in full online.  

All  the  responding  stakeholders  expressed  wide  support  for  the  initiative,  underlining  the  expected 
benefits and conveniences deriving from a modern, user-friendly digital solution, which is expected to 
facilitate administrative procedures. According to the responding stakeholders in the business sector, 
facilitated administrative procedures will smoothen business travel in general, which is underlined as 
a particular benefit for small and medium companies, helping them to increase competitiveness. 

The  responding  business  associations  and  companies/business  organisations  underlined  the  need  to 
ensure data security, and to envisage a transitional period to ensure a smooth transition from paper-
based to digital solutions, as well as a need for fall-back solutions in case of technical issues.  

The responding business associations also underlined the need for the existing industry facilitations to 
be retained and possibly replicated in the new digital set-up.  

The  Inception  Impact  Assessment  consultation  is  available  in  Have  your  Say122.  All  contributions 
received are publicly available.  

2. Targeted consultation of Member States 

122 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12758-Entering-the-EU-online-visa-application-process-and-digital-visa.  

68 

 
 
 
                                                           
All Member States support an option which provides for a digital visa. They would also support the 
extension of this digitalisation to long-stay visas123. This makes sense as the format of the visa sticker124 
is regulated at EU level and concerns both short-stay visas and long-stay visas125. 

Regarding the EU online application platform, 14 Member States would favour the use of an EU 
application platform on a voluntary basis (O3) whereas 10 would be in favour of mandatory use of the 
platform  with  a  transition  period  (O4).  Two  Member  States  would  support  mandatory  use  without 
transition period (O5). Many Member States expressed security concerns on option 5. 

These answers show a real interest for an EU online application platform, mandatory or not. At this 
stage, the preference for an EU online application platform on a voluntary basis seems logical as the 
EU platform does not exist yet (the Commission is working on a prototype in collaboration with eu-
LISA).  A  certain  number  of  Member  States  have  already  partly  digitalised  their  application 
procedure126. Other Member States are developing their own platform and would prefer to see the EU 
platform in operation before deciding to use it. 

Regarding the use of the EU platform for long-stay visas applications, 20 Member States would 
favour this synergy, but half of them would prefer to wait before integrating long-stay visas in the EU 
platform. Legislation and application procedures for long-stay visas vary greatly from one Member 
State to another whereas short-stay visas are harmonised through EU Law.  

The information gathered in the context of the consultation with and feedback from Member States has 
been taken into account in the analysis of the different policy options, in particular as regards Member 
States’ overall preference for O3 and O4. Member States concerns regarding security were confirmed 
by the results of the impact assessment and were taken into consideration when discarding O5.  

A detailed analysis of Member States’ responses is available Paragraph 2 of this Annex. 

3. Targeted consultation of EU Agencies  

Targeted  meetings  were  organised  with  the  Fundamental  Rights  Agency,  Europol  and  eu-LISA, 
relating in particular to data protection, fundamental rights, interoperability and security.  

The Fundamental Rights Agency emphasised the need to adhere to the GDPR principles of ‘purpose 
limitation’ and ‘data minimisation’ when collecting personal data, the importance of clearly defining 
which  authorities  have  access  to  which  data  and  the  need  for  the  digital  application  process  to  be 
accessible for people with disabilities.  

Europol views enhanced security as an added value of digitalising the visa procedure as visa applicants’ 
data is systematically cross-checked against other EU systems when processing applications.  

123 Long-stay visas concern stays between 90 days and one year (studies, work, etc.). They are issued by Member States on the basis of national or EU 
law. Their format is regulated at EU level through the visa sticker regulation. 
124 Council Regulation (EC) No 1683/95 of 29 May 1995 laying down a uniform format for visas (Official Journal L 164, 14/07/1995 p. 1-4). 
125 Regulation (EU) No 265/2010 of the European Parliament and of the Council of 25 March 2010 amending the Convention Implementing the Schengen 
Agreement and Regulation (EC) No 562/2006 as regards movement of persons with a long-stay visa (OJ L 85, 31.3.2010, p. 1–4). 
126 19 Schengen Member States have digitalised parts of the application procedure to a greater or lesser extent. 

69 

 
 
                                                           
Both the Fundamental Rights Agency and Europol are of the opinion that enrolment of biometrics in a 
non-controlled  environment  (O5)  poses  risks  with  regard  to  identity  fraud  and  data  quality.  They 
consider digital visas overall as a good development and a signed 2D barcode as a safe means (and 
offline solution) with which a third-country national can prove possessing a valid visa.  

eu-LISA estimated that from the side of the technical development and implementation there should 
not be visible difference in costs between option 4 and 5, as only few additional steps would be added 
to the VIS workflow. However, the remote collection of biometrics with applicant’s device might affect 
VIS operation, as necessary quality of biometrics cannot be assured.  

4. Targeted consultation of data protection stakeholders  

European Data Protection Supervisor  

A consultation meeting with the European Data Protection Supervisor (EDPS) took place on 1 June 
2021.  

The EDPS explained that the higher degree of digitalisation of the options, the greater the risks to 
data  protection.  The  EDPS  underlined  that  the  paper-based  approach  entails  some  data  protection 
risks, but that – all things being equal – a digital process is likely to bring along new challenges in 
terms of data protection and entail higher risks compared to the paper-based process. This is because 
paper-based documentation is usually located at the premises of a consulate and thus one needs to be 
at  the location to  be  able to  access  the documents  and cause data breaches. On the other hand, the 
digital documentation stored online may be accessible from anywhere.  

In  particular,  as  regards  the  application  process  under  O5,  the  EDPS  noted  that  the  collection  of 
biometrics though an online application raises data protection concerns but also many issues beyond 
data protection (i.e. data quality, etc.). This merits special attention as biometric data are considered as 
sensitive under the GDPR. 

As regards the digital application platform, the EDPS mentioned the concern that this could – even 
temporally – store more data than in the VIS because of the collection of supporting documents.  

As regards the options for storage of data, either in a centralised storage facility or at national level, 
the EDPS mentioned that a downside of a centralised database is that there is a single point of failure 
and attacks. Therefore, such a solution is more prone to technical errors and to security breach. The 
after-life error is also higher. However, from a data protection perspective, the fact that the data are 
stored  in  a  centralised  storage  facility  (“centralised”  option)  or  in  national  storage  facilities  with 
temporary central storage (“hybrid” option) is not a deal breaker. In other words, although in principle 
the former option entails higher  risks because  all data  are stored in  the same location, it cannot  be 
concluded that the latter option is safer. A detailed analysis needs to be carried out on how the solution 
is implemented. In the case of centralised storage or a hybrid option, new measures should be identified 
to mitigate privacy risks. 

70 

 
 
The  EDPS  advised  to  carry  out  two  Data  Protection  Impact  Assessments  (DPIA),  one  before 
adopting the legislation, and one during the implementation phase. The second DPIA should be carried 
out once the technical details and alternatives to implement the initiative are defined, so that a more 
detailed assessment is possible.  

The  Commission  took  the  feedback  of  the  EDPS  in  close  consideration,  including  as  regards  the 
concerns raised by the online collection of biometrics under O5. With regard to the digital application 
platform, although additional data may be stored temporarily, no additional data would be requested 
from visa applicants other than the ones currently collected. The Commission explained that there will 
not be enough time to carry out a fully-fledged Impact Assessment on Data Protection before proposing 
the legislation in Q4 2021.  

National data protection authorities  

On 8 April 2021 DG HOME requested the input of Member States Data Protection authorities on the 
data protection issues related to visa digitalisation.  

The following (10) Member States submitted replies: Belgium, Bulgaria, Switzerland, Croatia, Czech 
Republic, Greece, Lithuania, Malta, the Netherlands and Slovakia.  

As regards the aspects to be further analysed in view of the envisaged changes in data processing, 
the  responses  largely  emphasised  adherence  to  the  principles  of  ‘purpose  limitation’  and  ‘data 
minimisation’. In particular, respondents mentioned the need to: 

  clarify which data have to be processed, by whom (which authority/entity/person), for how long 
and why, as well as defining the ownership of the stored data and who is in  charge of visa 
processing, and ensuring the supervision of the processing activity; 

  ensure that data access is configured in a way that only the competent authorities can access 
data that is strictly necessary for the purpose of the digitalised visa application/issuance; 

  ensure that the data are deleted as soon as they are no longer needed;  
  explore  the  possible  links  between  the  changes  resulting  from  the  digitalisation  of  visa 
procedures  and  the  existing  central  Visa  Information  System  –  National  Visa  Information 
System (C.VIS-N.VIS) set-up and Schengen Evaluation mechanism; the rules establishing a 
framework  for  interoperability  between  EU  information  systems  in  the  field  of  borders  and 
visa127 and in the field of police and judicial cooperation, asylum and migration128, other IT 
systems, bodies, offices and agencies129, and the new Pact on Migration and Asylum. 

127 Regulation (EU) 2019/817 of the European Parliament and of the Council of 20 May 2019 on establishing a framework for interoperability between 
EU information systems in the field of borders and visa and amending Regulations (EC) No 767/2008, (EU) 2016/399, (EU) 2017/2226, (EU) 2018/1240, 
(EU) 2018/1726 and (EU) 2018/1861 of the European Parliament and of the Council and Council Decisions 2004/512/EC and 2008/633/JHA (OJ L 135, 
22.5.2019, p. 27–84). 
128 Regulation (EU) 2019/818 of the European Parliament and of the Council of 20 May 2019 on establishing a framework for interoperability between 
EU information systems in the field of police and judicial cooperation, asylum and migration and amending Regulations (EU) 2018/1726, (EU) 2018/1862 
and (EU) 2019/816 (OJ L 135, 22.5.2019, p. 85–135). 
129 For example SIS, EES, ETIAS, in the fields of Border, Asylum and Migration, SIS, EPPO, Eurojust, ECRIS-TCN in the field of Police and Justice 
Cooperation.  

71 

 
 
                                                           
Some of the main recommendations for the design of the initiative include: 

 

Independently from the option chosen, ensure that the data security and confidentiality are 
guaranteed, especially during the following steps: when sending data via e-mail; if and when 
the applicant submits his/her fingerprints, facial  image and copy of travel document using a 
smartphone application. This is particularly important when handling sensitive data, e.g. health 
data. Data breaches due to unsecure payment methods in third countries were also mentioned 
in this regard. 

  Ensure  that  the  data  cannot  be  forged,  in  particular  when  the  applicant  submits  his/her 
fingerprints and facial image during the application process and when the visa holder needs to 
prove being in  possession of a visa to  private entities in  the Schengen territory  (e.g. hotels, 
banks, etc.). 

  For reasons of security, two-factor authentication should be required for the digital visa, or 

notification thereof, to prevent for example the applicant's password being hacked. 

  Follow  the  principle  of  transparency  and  accountability,  ensure  that  all  roles  –  data 
controllers, processors, and joint-controllers are well defined including those that would store 
personal information along with eu-LISA. 

  Ensure  that  the  rights  and freedoms  of  visa  applicants  are  protected,  when  creating  a  new 
database (e.g. the right to have access to personal data, to have a copy of the data, to have data 
modified or deleted, etc.. 

  Ensure consent of the applicant at all stages, e.g. including consent for the re-use of his/her 
personal data for future applications. In this regard, sufficient information has to be given to 
the data subject for fair and lawful processing, in line with the EDPB guidelines. 

  With  regard  to  supervision,  envisage  audit  logs  and  audit  possibilities  for  the  central 

component and/or the hybrid model (central and local storage). 

  As regards accessibility, the possibility that a visa applicant might not be in possession of a 
smart phone or an email account must be considered, and alternative possibilities to apply for 
a visa should be envisaged to that effect. 

As regards the preferred policy options, a preference was expressed for O3 and O4, and in one case 
for  O5.  One  Member  State  mentioned  that  all  the  options  and  possibilities  can  be  implemented  in 
accordance with data protection principles, although  some concerns were raised as regards the data 
protection and security implications of O5. It was also mentioned that in general, the more similarities 
in the system in Member States, the more clarity for the data subjects, hence support was expressed for 
an EU visa application platform. 

As regards the preferred option for the system architecture, from a data protection perspective, six 
Member  States  (Switzerland,  Croatia,  Czech  Republic,  Greece,  Lithuania  and  the  Netherlands) 
expressed a preference for a hybrid option with decentralised storage of data, which is considered 
better in terms of data minimisation and security by the data protection authorities. 

72 

 
 
One Member State (Malta) expressed a preference for a centralised system hosted at EU level, which 
is  considered  to  limit  the  risks  of  data  inconsistency  and  inaccuracy,  especially  where  biometric 
information is concerned.  

One  Member  State  (Lithuania)  however  noted  that  a  hybrid  option  would  be  preferable  when  the 
system is set up properly and in strict accordance with data protection safeguards and principles. If this 
should not be the case (e.g. due to lack of means), then a centralised system may be preferable, as both 
options could be implemented in accordance to data protection principles.  

Finally, one Member State (Slovakia) expressed support for both options and two Member States 
(Bulgaria,  Belgium)  mentioned  that  both  options  for  system  architecture  should  be  further 
examined.  

With regard to the policy options and options for system architecture, it should be noted that not all 
Member States expressed an explicit preference.  

5. Targeted consultation of travel and tourism industry stakeholders  

The aim of the consultation was to gather the views of representatives of the travel and tourism industry 
on the visa digitalisation initiative. 

Representatives  from  the  following  organisations  participated  in  the  consultation  meeting:  CER 
(Community  of  European  Railway  and  Infrastructure  Companies),  CLIA  Europe  (Cruise  Lines 
International  Association),  ECSA  (European  Community  Ship  owners’  Associations),  ETOA 
(European Tourism Association), IRU (International Road Transport Union), WTTC (World Travel & 
Tourism Council), HOTREC (Association of Hotels, Restaurants, Pubs and Cafes in Europe), PEARLE 
(Live Performance Europe). 

Representatives of the travel and tourism industry consulted by DG HOME supported unanimously 
O4 (digital visa + mandatory EU visa application platform with a transition period). They highlighted 
that this would facilitate the application procedure for visa applicants, as well as the positive impact on 
voyages to the EU and the increased attractiveness of the EU as a travel destination. They underlined 
the need for the EU to offer a seamless travel experience equivalent to the one proposed by countries 
like Australia, in particular towards travellers from Asian countries subject to visa requirements. Whilst 
also showing an interest in O5, they recognised it could pose security challenges. 

The information gathered in the context of the consultation with and feedback from travel and tourism 
industry has been taken  into account  in  the  analysis of the different  policy  options, in  particular as 
regards their strong preference for O4. The recognition of the security challenges posed by O5 also 
confirmed the results of the impact assessment and were taken into consideration when discarding O5. 

6. Public consultation  

73 

 
 
 
An open public consultation was conducted through an internet-based survey between March and June 
2021. The public consultation targeted visa applicants and citizens or organisations who wish to give 
their input on the modernisation of the EU's visa policy.  

The  public  consultation  was  accessible  via  the  Have  Your  Say  portal  and  DG  HOME’s  public 
consultation  webpage.  Additionally,  efforts  were  made  to  promote  the  public  consultation  through 
Member States’ consulates and external service providers. To increase its reach and accessibility, the 
questionnaire was made available in all official languages and, if possible, some key non-EU languages 
(e.g.  Russian,  Arabic,  Chinese,  Turkish).  The  public  consultation  met  the  12-weeks  minimum 
mandatory requirement.  

Methodology  

As regards the methodology adopted, since the impact assessment is mainly targeted at third-country 
nationals  who  require  a  visa,  the  analysis  primarily  focuses  on  their  replies,  especially  regarding 
questions related to their experience with previous visa applications. The opinions of EU citizens and 
other profiles are taken into account in the more general questions, also because EU citizens may have 
a particular interest in the digitalisation of the visa process or in some cases, as indicated in further 
information  provided  by  respondents,  EU  citizens  share  views  on  the  process  on  behalf  of  family 
members who are third-country nationals.  

It should be noted, as a disclaimer, that the questions that were presented to the respondents depended 
on the profile they had indicated (as depicted in Annex 2). This explains why some questions have a 
lower amount of responses. Additionally, the respondents did not have to complete every question to 
submit a valid form. This explains why the response rate sometimes differs.  

The respondents  

As of 3 June 2021, the Public Consultation had a total of 515 respondents out of which 341 were non-
EU  citizens  and  98  EU  citizens.  The  remaining  respondents  consisted  of  business  associations, 
institutions,  non-governmental  organisations  and  companies  or  business 
academic/research 
organisations.  

55% of Third-country nationals fall within the age category of 25 to 39. 35% of third-country nationals 
are  between  40  and  60  years  old.  5%  is  younger  than  24.  The  final  age  category,  above  60,  is 
represented by 5%. The analysis below therefore mainly reflects the point of view of the people below 
60.  

As regards the respondents’ main reason for travel to the EU, 59% of respondents indicated tourism; 
the second most common reason for travelling to the Schengen area is to visit family or friends (16%).  

As regards the difficulties currently faced by the respondents when applying for a Schengen visa: 

  52% of respondents pointed out that the process was time consuming; 
  34% of respondents saw the long distance they have to travel to the consulate/ VAC as an issue; 

74 

 
 
  33% of respondents thought it was annoying to leave their passport at the consulate; 
  29% of respondents said the application process was complicated; 
  25% of respondents have not encountered any particular difficulty; 
  14% of respondents thought there were other difficulties; 
  13% of respondents did not know exactly when to collect their passport from the consulate/ 

VAC; 

  5%  of  respondents  said  their  application  was  not  admitted  due  to  incomplete  files  or  other 

mistakes. 

131

86

82

72

64

35

32

13

The application
process was
time
consuming.

I had to travel
long distance to
the consulate /
visa application
centre.

I could not
travel during
the application
process because
my passport
was at the
consulate.

The application
process was
complicated.

No particular
difficulty.

Other

I did not know
when to collect
my passport
from the
consulate/visa
application
centre.

My application
was not
admitted due to
incomplete file
or other
mistakes.

  95% find receiving email messages easy and 4% are neutral; 
  88% think online/ mobile payment is easy. 8% are neutral and 5% of the respondents find this 

difficult; 

  82% believe that scanning and uploading documents to an online website or portal is easy.14% 

are neutral and 4% think this is difficult; 

  84% think it is easy to scan their travel document with a mobile device. 10% are neutral and 

6% find this difficult; 

  76% find using support tools such as online tutorials or chatbots easy. 19% are neutral and 2% 

find this difficult. 

Main findings 

The results of the public consultation shows very strong support for the digitalisation process, both 
regarding the digital visa and the possibility to apply online.  

81% of the respondents are very positive about the initiative and 14% are positive about digitalising 
the  visa  procedure  and  making  it  less  paper-based.  Only  2%  have  a  negative  opinion  on  the 
digitalisation with the fact of losing personal contact as a main argument and 3% are neutral. 

75 

 
 
 
 
3%1% 1%

14%

Very positive

Positive

Neutral

Negative

Very negative

81%

Additionally, 86% of respondents agree with the statement that digitalisation would increase family 
visits / business / cultural or scientific exchanges; 90% of respondents agree that digitalisation would 
contribute to a positive image of the EU or Schengen Area; 83% agree that digital visa procedures 
would increase the transparency of the visa process, and 67% agree that digitalising the visa procedure 
would increase the security of the Schengen area.  

The benefits of the digital visa are summarised in the table below. 

Do you think… 

Digital visa 
procedures would 
promote travel and 
tourism to the EU? 

Digital visa 
procedures would 
promote family 
visits / business / 
cultural or 
scientific 
exchanges 

Digital visa 
procedures would 
contribute to a 
positive image of 
the EU or 
Schengen Area 

Digital visa 
procedures would 
lead to greater 
transparency in the 
Schengen visa 
process 

Digital visa 
procedures would 
promote the security 
of the Schengen 
Area 

Strongly agree 

Agree 

Neutral 

Disagree 

Strongly disagree 

60% 

26% 

8% 

1% 

4% 

62% 

24% 

8% 

1% 

4% 

66% 

24% 

5% 

1% 

4% 

58% 

25% 

11% 

2% 

4% 

44% 

23% 

25% 

3% 

5% 

Questions related to the online application portal 

As regards the online application portal, 96% of respondents believe that the introduction of an online 
application procedure would facilitate the process of applying for a Schengen visa. 2% of respondents 
do not agree with this statement and 2% are neutral. 

As regards the main benefits of the online application procedures: 439 (85%) respondents indicated 
that  the  largest  benefit  of  introducing  an  online  application  procedure  is  the  fact  that  the  entire 
procedure would be quicker. This is in line with the two main burdens of the current process that were 
both characterised by the lengthiness of the process.  

76 

 
 
 
  
 
 
 
Additional benefits mentioned by respondents include: making the online application procedure more 
in line with the digital age (61%); the online procedure would be cheaper than the current situation 
which often requires one or more visits to the consulate/VAC (49%). Additional arguments for a more 
digital solution are the fact that it would be more user-friendly for 214 people (42%) and create a more 
transparent and predictable application process for 161 (31%) people. Other benefits that have been 
highlighted by 18 respondents (4%) are: the ability to travel during the visa process because you would 
not have to leave your passport at the consulate and; the ecological aspect that the digitalisation entails. 

The figure below shows what the main benefits of the online application procedure would be according 
to the respondents. 

439

316

quicker

more
modern and
in line with
an
increasingly
digital world

252

214

161

cheaper

more user-
friendly

more
transparent /
predictible

18

other

As  regards  the  importance  for  repeat  applicants  of  not  having  to  visit  the  consulate/VAC,  89%  of 
respondents  find  it  important  that  they  would  not  have  to  visit  the  consulate  or  VAC  in-between 
applications.  

Although  the  majority  of  the  respondents  have  stated  that  they  would  benefit  from  a  digital  visa 
procedure, 32% still indicate that they see some obstacles or drawbacks. 68% do not see any obstacles 
or drawbacks. 

Respondents mentioned the following obstacles or drawbacks of the digital application procedure: 
not  having the possibility to  ask questions as a possible drawback to  the digital  application service 
(58%), applicants’ lack of computer literacy (43%); inadequate or no access to internet (31%); scanning 
and uploading documents (33%); concerns about the privacy and data security of the online process 
(30%); unavailability of necessary equipment (e.g. computer or mobile phone) to access the application 
portal  (23%).  15%  of  respondents  believe  that  there  are  other  obstacles/drawbacks  to  a  digital 
application procedure. The main other obstacles/drawbacks that were brought up were concerns about 
fraud being more easy with a digital application procedure and the lack of standardisation of required 
documents which could lead to incomplete applications. 

When  asked  about  the  form  of  support  that  applicants  would  prefer  to  overcome  these 
obstacles/drawbacks, a large amount of respondents indicates they still would like to receive support 
through real life guidance: 

77 

 
 
 
  63% of respondents would still like to go to the consulate/VAC to get help with filling out their 

applications; 

  56% would also like to maintain the paper-based procedure in exceptional cases.  

The online solutions that could be offered on the platform also prove to be quite popular: 

  44% of respondents see online tutorials as the preferred form of support; 
  26% of respondents would like to get support through automated chatbots.  

Asking help from relatives or friends (27%) or travel agencies or other intermediaries (19%), have also 
been  indicated  by  some  respondents.  A  human/physical  contact  point  therefore  still  seems  to  be 
important despite the desire for digitalisation.  

102

90

72

49

42

43

31

Visa application
centres or
consulates

Maintaining the
paper-based
procedure in
exceptional
cases

Online tutorials Other solutions Automated

chatbots

Relatives or
friends

Travel agencies
or other
intermediaries

As regards the preferences of the respondents in terms of where the Schengen visa should preferably 
be submitted, 44% of respondents are in favour of solely submitting their Schengen visa application 
on a single EU digital visa portal. 12% think the best solution would be a national portal, managed by 
each EU Member State separately. 44% do not have a clear preference and suggest that both options 
would be fine.  

82 % agree that it is important to have the possibility to apply online for both the Schengen visa and 
long-stay visa. 13% of the respondents are neutral and 5% do not find it important. 

Questions related to the digital visa 

As regards the introduction of the digital visa, this is generally seen as a very positive development. 
The main advantages mentioned are the following: 

  92% of respondents believe that a digital visa would facilitate the Schengen visa application 

procedure and travelling to the EU Schengen area for visa holders.  

  83%  of  respondents  find  it  an  important  advantage  that  they  would  not  need  to  leave  their 
passport at the consulate to get the visa sticker affiliated to their passport. This would mean that 
applicants can travel during their application process. 

  83%  of  respondents  find  it  an  important  advantage  that  they  do  not  need  to  retrieve  their 
passport at the consulate or VAC at the end of the visa application procedure. This would save 
the applicants transportation or courier costs to collect or get their passport delivered.  

78 

 
 
 
  91% of respondents find the advantage of easily checking the status of their visa application 
through their mobile device very important. 5% are neutral about this advantage and 4% do not 
find this important. 

  93% of respondents finds it an important advantage that their visa could remain valid even if 
the passport would get lost or stolen as it would be transferred to a new passport. 5% are neutral 
and 2% do not find this advantage important.  

  88% of respondents find it an advantage that there would be smoother border control checks. 

10% are neutral and 2% do not find this an important advantage. 

Even though most respondents clearly see a lot of advantages to the digital visa, 76% still see some 
possible obstacles/drawbacks. 24% do not see any particular obstacle or drawback. The main obstacle 
identified by 55% of respondents is the limited access to the visa for other parties (carriers, hotels etc.). 
Additional obstacles include bad access or no access to the internet (44%), concerns about the security 
of personal data and privacy (40%), lack of necessary equipment to access the digital visa (38%) and 
lack of computer literacy (33%).  

As regards the  features  of the digital visa  which respondents would find important, 83% think 
email notifications on the visa status should be included, 75% believe there should be a  permanent 
access to the EU online visa portal to check the status of their visa; 57% find the possibility to print out 
their digital visa an important feature; 41% would like to have the possibility to contacts authorities; 
19% think support tools such as  online tutorials or chatbots are an important  feature and; 2%  have 
indicated other features such as having the option still to have a paper sticker. 

424

383

290

211

95

Permanent
access to an EU
online visa
portal to check
the visa status

Email
notification on
visa status
(issued, refused,
revoked,
annuled,
extended)

The possibility
to print out the
digital visa

The possibility
to contact the
authorities

Support tools,
such as online
tutorials or
chatbots

10

Other

79 

 
 
 
 
 
 
 
 2. Analysis of the consultation with the Member States  

Within the context of the Impact assessment, Member States were consulted in order to collect their 
opinion on a number of topics, including questions pertaining to the existing national visa application 
processes, the use of online tools in order to facilitate the visa application procedure and future outlook. 
This Annex represents a summary of the responses related to the topics mentioned above. 30 Member 
States  replied  to  the  questionnaire,  namely:  Austria,  Belgium,  Bulgaria,  Croatia,  Cyprus,  Czech 
Republic,  Denmark,  Estonia,  Finland,  France,  Germany,  Greece,  Hungary,  Iceland,  Ireland,  Italy, 
Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, 
Slovenia, Spain, Sweden and Switzerland.  

National digital application services 

Figure 5: Question 7: Implementation of national online tools (n=30)  

30

20

10

0

21

7

2

Any online tool in operation to facilitate the visa application process

No online tool in operation to facilitate the visa application process

Planned implementation of online tool in operation to facilitate the
visa application process

28 Member States explained that they either have some kind of national online visa application tool in 
place, or are planning to implement one in the near future. Two Member States130 expressed that they 
do not have or plan to implement an online tool to facilitate the visa application process. It should be 
noted  that  the  stage  of  digitalisation  varies  greatly  between  Member  States,  as  well  as  the  type  of 
national online visa application tool and associated features of the tool in place.  

Figure 6: Question 8: Timeline of implementation national application tools (n=26)  

130 Luxembourg and Malta.  

80 

 
 
 
 
                                                           
s
e
t
a
t
S
r
e
b
m
e
M

f
o

r
e
b
m
u
N

e
n

i
l

n
o

l

a
n
o
i
t
a
n

a

i

g
n
v
a
h

25 25 26

23 23

19 19

17 17

14 15

30

25

20

15

10

5

0

e
c
a
p

l

n

i

l

o
o
t

8 9 9 10 11

5

1 2

The graphic above portrays the evolution of the first implementation of national application platforms 
within the Member States. The timeline varies between Member States, with the first Member State 
implementing an online tool in 2007, whilst others are planning to implement their first online tool to 
facilitate  the  visa  application  process  in  2025.  Besides  the  two  Member  States  without  a  national 
application tool in place or plans to do so, the Czech Republic and Slovakia did not indicate when their 
national application tool was implemented.  

Figure 7: Question 9: Visa covered by national online tools (n=28)  

s
S
M

f
o

r
e
b
m
u
N

20

15

10

5

0

15

8

5

Online tool covers only Schengen Visa

Online tool covers only national visa

Online tool covers both

When asked about the type of visa covered by their national online tool, eight Member States replied 
that only Schengen visa are or will be included in their national online tool, whilst five Member States 
indicated that their national online tool only covers national visa. 15 Member States stated that their 
national online tool covers or will cover both types of visa. Three Member States also include different 
visas within their national online platform131. 

Regarding the technical updates related to the online tools implemented by Member States, 16 Member 
States indicated that they updated their existing national platform in some shape or form in the last 
couple of years, including small technical updates and the implementation of completely new features 

131 Denmark issues visa for Greenland and the Faroe Islands, whilst the Netherlands offers visa for the Caribbean. Further, the Norwegian online tool 
covers applications for residence and work permits, citizenship, etc. as well. 

81 

 
 
  
 
  
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
such as an online payment option132 and the possibility to upload supporting documents for applicants 
applying for long stay student visas133.  

Member States were also consulted regarding the development, maintenance and support cycles related 
to  the  online  tool,  including  any  associated  contracts  with  external  partners.  In  parallel  with  the 
aforementioned  diversity  in  implementation  date  and  updating  schedule,  the  development, 
maintenance and support cycles are very different between Member States with an online tool in place, 
as well as any contracts with external partners. Four Member States also indicated that their online tool 
is an in-house solution, encompassing its development, maintenance and support, whilst seven Member 
States did not provide an answer to the question. Below, the number of Member States for which the 
contract ends in a specific year are depicted134: 

Table 15: Question 11: Overview of the year in which maintenance contracts of Member States with 
external IT contractors will end:  

2021  2022  2023  2024  2025  2026  Other 

Number of Member States 

4 

3 

2 

3 

0 

2 

1135  

On average, the respondents with an existing national online tool in place indicated that 72.7% of the 
worldwide visa applications are submitted online, including Schengen visa, long-stay visa and other 
issued visa by the consulted Member States. It should be noted that this does not necessarily mean that 
the entire visa process was conducted online but that in those cases some online tool was used. 

Besides the listed features in the table below, six Member States indicated that their online national 
tool  also  included  other  options,  including  a  feature  to  monitor  the  status  of  the  submitted  visa 
application, FAQ and News sections and the possibility to verify the supporting documents online at 
the stage of the appointment registration.  

132 Switzerland. 
133 France.  
134 The remaining Member States that submitted a reply to this question did indicate whether they used external contractors or developed their national 
tool in-house. 
135 2033 

82 

 
 
 
 
 
                                                           
Table 16: Question 12: Overview of included features in national online tools  

Wizard 
guiding the 
applicant 
on the type 
of visa, visa 
fee, 
documents 
needed etc. 

Information 
about 
general 
rules for 
lodging an 
application 

Indication 
on the next 
available 
appointment 
before 
starting 
application 
process 

Creation 
of 
personal 
account 

Error 
detection / 
data quality 
check (e.g. 
alphanumeric) 

Filling in 
the 
application 
form 

Application fill-
in and print out 
option (no 
direct link with 
the national 
VIS) 

Member 
States with 
the feature 
included in 
their 
national 
online tool 

Member 
States with 
the feature 
included in 
their 
national 
online tool 

15 

21 

5 

15 

22 

26 

12 

Data 
upload to 
the national 
VIS (direct 
link with 
the national 
VIS) 

Upload of 
supporting 
documents 

Lists of 
supporting 
documents 
(per third 
country / 
travel 
purpose) 

Online 
payment 
of the visa 
fee 

Appointment 
management 

Signing the 
application 

ESP access to 
correct or 
complete/upload 
data 

15 

9 

9 

7 

14 

4 (Tick box) 

12 

The following table gives an overview of the technologically advanced functionalities and features 
that  are  included  or  considered  to  be  included  in  the  online  application  platforms  of  the  consulted 
Member States. Six Member States did not provide a detailed overview in this regard.  

Table 17: Question 13: Overview of technologically advanced features in national online tools  

Chatbot to 
support 
preparation 
and application 
process (from 
start to finish) 

Providing facial 
image with a 
webcam / 
smartphone 

Identification 
with live face 
recognition 
using webcam / 
smartphone 

Scan of the 
travel 
document to 
extract relevant 
data 

Passport chip 
contents 
authentication 
using a 
smartphone 

Photo 
morphing 
detection (for 
consulate) 

Member States 
with the feature 
included in their 
national online 
tool 

Member States 
that will include 
the feature in 
their national 
online tool 

3 

6 

0 

5 

0 

3 

83 

1 

9 

0 

2 

1 

3 

 
 
 
 
 
 
 
 
Member States 
that do not 
consider this 
feature 

Number of 
Member States 
that did not 
indicate 
anything for the 
feature in 
question 

Member States 
with the feature 
included in their 
national online 
tool 

 Member States 
that will include 
the feature in 
their national 
online tool 

Member States 
that do not 
consider this 
feature 

Member States 
that did not 
indicate 
anything for the 
feature in 
question 

15 

18 

20 

14 

21 

19 

0 

1 

1 

0 

1 

1 

Communicatio
n with the 
applicant 
through the 
online tool 

Application 
status 
notification or 
verification 

Statistics and 
reports on the 
submitted 
applications 
(for consulates) 

Smartphone 
application 

Accessibility 
functionalities 
for people with 
disabilities  

Other features 

4 

9 

10 

13 

12 

7 

0 

3 

0 

9 

5 

0 

5 

9 

3 

8 

10 

13 

2136 

0 

22 

0 

0 

0 

136 Croatia: “Further development includes the calendar appointment system. Also, along with current six (6), additional language versions will be added.” 
     Sweden: “Automatic control via sticker/application number in the e-application whether the applicants biometrics can be re-used" 

84 

 
 
 
 
                                                           
Potential digitalisation of the application process  

Figure 8: Question 15: Assessment of the introduction of an online application procedure (n=29) 

4%3%

93%

Introducing an online application procedure facilitates the existing
visa application process and reduces possible administrative
burdens

Introducing an online application procedure does not facilitate the
existing visa application process and does not reduce possible
administrative burdens

Undecided

93%  of  the  responding  Member  States  assessed  that  the  implementation  of  an  online  application 
procedure would facilitate the existing (Schengen) visa application process, and believe that it would 
reduce the possible administrative burdens of the central authorities and consulates. 4% believe this is 
not the case, whilst 3% remain undecided.  

Figure 9: Question 16: Assessment of the implementation of a digital visa (n=29)  

3%

97%

The introduction of a digital visa would facilitate the existing
visa issuing and would reduce administrative burdens

97%  of  the  respondents  believe  that  the  implementation  of  a  digital  visa  which  would  replace  the 
existing visa sticker would facilitate the existing procedure regarding the issuing of (Schengen) visa, 
as well as reduce possible administrative burdens for the central authorities and consulates. 

Regarding the assessment of the five policy option by Member States, all consulted Member States are 
in favour of digitalising the visa application procedure, as well as the implementation of a digital visa. 
No Member State was in favour of Option 1. Four Member States supported the implementation of the 
policy Option 2, with three of these Member States also supported policy options 3 and/or 4. Three 
Member States indicated that they would prefer the fifth policy option, although some Member States 
referred to the unrealistic nature of the policy option at this point in time.  

85 

 
 
 
 
 
 
All  other  Member  States  supported  policy  options  3  and  4  as  the  most  realistic  and  preferred 
approaches to digitalise the visa application process and implement a digital visa, or at least included 
the third or fourth policy option within their answer. The returning motivation point vis-à-vis the third 
option entails the voluntary nature of the EU online platform, which allows the use of national tools 
and more flexibility for Member States. For the fourth policy option, reasons raised by Member States 
include a harmonised and unified approach across Member States and their consulates, countering the 
practice of visa shopping and the inclusion of a transitional period which would smooth the transition 
from national tools to the EU-wide platform.  

In the context of the general preference of the respondents for policy options 3 and 4, some Member 
States express that they prefer policy option 3 because of the voluntary basis of enrolment, but that an 
effective and adequate EU-wide platform would encourage them and other Member States to join the 
initiative, eventually resulting in the outcome of policy option 4.  

The  following  table  lists  the  overview  of  the  consulted  Member  States  and  their  preferred  policy 
option(s).  

Table 18: Question 17: Preference of the consulted Member States in regard to the policy options  

Member State 

Preferred option 

Member State 

Preferred option 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Option 2 

Options 3 and 4 

Option 2 and 3 

Option 5 

Option 5 

Option 4 

Option 2 and 3 

Option3 and 4 

Option 3 

Option 3 

Option 3 

Options 4 and 5 

Options 4 and 5 

Option 4 

N/A 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Under evaluation 

Option 3 

Option 3 

Option 3 

Option 4 

Netherlands 

Options 4 and 5 

Norway 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Option 3 

Options 3 and 4 

Option 3 

Option 3 

Option 3 

Option 3 

Option 3 

Option 4 

Switzerland 

Options 2,3 and 4 

86 

 
 
 
 
Figure 10: Question 18: Assessment of the potential benefits of a digital application service for the 
Member States (n=30)  

25

27

26

11

30

20

10

0

Lower costs

Increased efficiency at consulates (application management,
archiving)

Reduced administrative burden for the central authorities and
consulates

Increased travel and tourism to the Schengen Area

Out of the potential benefits, lower costs, increased efficiency at the consulates and the reduction of 
the administrative burden for the central authorities and consulates are assessed favourably by the vast 
majority of the consulted Member States. The increase in travel and tourism to the Schengen Area is 
considered a benefit by 11 out of the 30 respondents. 
A number of Member States also indicated other potential benefits related to the implementation of an 
EU digital application service, including simplifying the process for the applicants, easier handling of 
the visa fees and more effective document verification.  

Potential implementation of digital visa 

Figure 11: Question 19: Assessment of the potential benefits of the implementation of a digital visa 
for the Member States (n=30)  

40

30

20

10

0

25

29

22

22

Lower costs
Increased efficiency at consulates
Increased efficiency at Schengen borders
Enhanced security in the EU

29 Member States identified the increased efficiency at the consulates as a potential benefits of the 
implementation of a digital visa, whilst respectively 25, 22 and 22 respondents labelled the lowering 
of  the  costs,  the  increased  efficiency  at  the  Schengen  border  and  the  enhanced  security  within  the 
European Union as possible upsides of the digital visa compared to the existing system with the visa 
sticker.  

87 

 
 
 
 
The  questionnaire  included  a  question  to  assess  the  inclusion  of  national  long-stay  visa  within  the 
European online platform and digital visa initiative. The responses to this question were not pointing 
clearly at one direction, with a group of Member States which would like to include the possibility to 
apply for a long-stay visa through the platform, Member States that do not want to include this option 
and a number of Member States that want to first evaluate the implementation of an European platform 
in regard to the Schengen visa before discussing the inclusion of national visa.  

Table  19:  Question  20:  Overview  of  preference  of  the  consulted  Member  States  in  regard  to  the 
inclusion of long stay visa in the online visa application platform  

Member State 

Should the online visa application 
platform cover long-stay visa along 
with short-stay visas (i.e. by 2025)? 

Should the online visa application 
platform cover long-stay visas at a 
later stage? 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Iceland 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Norway 

Yes 

No  

No 

No 

Yes 

No 

No 

Yes 

No definitive position 

No definitive position 

No definitive position 

Yes 

No definitive position 

No 

No definitive position 

No definitive position 

N/A137 

N/A 

No definitive position 

No definitive position 

No 

Yes 

No 

Yes 

N/A138 

Yes 

No 

Yes 

Yes 

No definitive position 

Yes 

No 

Yes 

N/A 

Yes 

No definitive position 

Yes 

Yes 

No definitive position 

No definitive position 

No 

No 

No definitive position 

No 

137 Finland did not answer this question.  
138 Ireland is not part of the Schengen area, and did not answer this question.  

88 

 
 
                                                           
Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Switzerland 

Yes 

No 

Yes 

Yes 

Yes 

No 

No 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

No definitive position 

No 

Yes 

Recurring  advantages  of  the  inclusion  of  long-stay  visa  within  the  EU  platform  mentioned  by  the 
consulted Member States include the following: 

 

 

 

eight Member States wanted to avoid having two different systems and procedures in place for 
short- and long-stay visas; 
three Member States listed the removal of the administrative burdens associated with the visa 
sticker altogether; and  
four Member States stated the synergies with the VIS regulation recast that already provides 
for data records on long-stay visas.  

The main factor advising against including national visa into the EU platform are the differences in 
legislature  and  practices  surrounding  the  issuing  of  long  stay  visa  between  Member  States. 
Nonetheless, some Member States that are against the inclusion of national visa within the platform 
nonetheless mentioned that the implementation of a digital visa should cover the long-stay visa as well.  

Statistics regarding the application process  

 

 

 

 
 

On  average,  national  authorities  spend  8.74  minutes  when  replying  to  one  visa  application 
request received per phone, whilst spending 9.2 minutes for requests submitted via email; 
On average, consulate personnel require 15.02 minutes to take in a paper application directly 
from an applicant and encode it in the system. This includes collecting the visa fee.  
On average, it takes 6.8 minutes to capture and collect the biometrics of the applicant by the 
consulate; 
On average, the consulate spends 5.17 minutes to file one application file in the archive; 
On average, it takes 5.28 minutes to  print a visa sticker and  affix it to  the passport  or on  a 
separate sheet in case the travel document is not recognised by the Member State. 

Current situation within Member States 

The  following  table  depicts  the  statistics  reported  by  Member  States  for  2019  regarding  the  total 
number of long-stay visa applications submitted, the total number of issued long-stay, and the number 
of Schengen visa applications which were collected by the ESPs. The total number of submitted and 
issued short stay  visa applications in  2019 are included as well from  an external  source to  give an 
encompassing overview of the situation.  

89 

 
 
 
 

 

The number of submitted and issued long stay visa varies a lot between Member States, with 
Iceland receiving 48 submitted long stay visa applications in 2019, whilst Poland received more 
than 1.1 million long stay visa applications.  
The ESPs play a substantial role in the collection of Schengen visa applications. On average, 
the ESPs collected 83,6% of the Schengen visa applications within a Member State. 

Table 20: Question 4-5-6: Overview visa statistics per Member State  

Member State 

Total number 
of submitted 
long stay visa 
applications in 
2019 

Total number of 
issued long stay 
visa in 2019 

Total number 
of submitted 
short stay visa 
applications in 
2019139 

Total number 
of issued short 
stay visa 
applications in 
2019140 

Total number of 
Schengen visa 
applications 
collected by 
ESPs 

Member States that are part of the EU 

Austria 

Belgium 

Croatia 

28 800 

40 600 

N/A  

Czech Republic 

69 257 

Denmark 

22 132  

323 262 

248 021 

N/A 

739 818 

165 191 

26 400 

32 000 

N/A 

56 092 

In 2019, Danish 
missions issued 
19 017 residence 
and work permit 
cases 

306 458 

190 222 

N/A 

699 088 

148 145 

299 000 (85%) 

211 000 (85%) 

49 212 (66%) 

686 274 (92%) 

 ≈ 160 000 
(98%) 

Estonia 

Finland 

France 

MFA/Consulates
: 13 066 
PBGB141: 13 695 

MFA/Consulates
: 12 346 
PBGB: 13 310 

145 711 

143 582 

121 478 (83%) 

0142 

0 

895 775 

875 356 

888 739 (99%) 

296 823 

237 196 

3 980 989 

3 291 128 

3 968 669 
(99,6%) 

Germany 

384 648 

324 636 

2 171 309 

1.916.408 

1 748 000 (80%) 

Greece 

Hungary  

Italy 

Latvia 

Lithuania 

17 501 

29 120 

86 439 

9 185 

54 469 

15 312 

21 914 

880 892 

237 851 

827 291 

217 108 

149 034 

2 053 521 

1 892 648 

7 750 

48 790 

167 743 

359 484 

163 229 

354 166 

880 892 (85%) 

155 199 (65%) 

1 856 986 
(90,4%) 

167 743 (72%) 

≈ 330 000 
(91,7%) 

139 Complete statistics on short-stay visas issued by the Schengen States, https://ec.europa.eu/home-affairs/what-we-do/policies/borders-and-visas/visa-
policy_en. 
140 Complete statistics on short-stay visas issued by the Schengen States, https://ec.europa.eu/home-affairs/what-we-do/policies/borders-and-visas/visa-
policy_en.  
141 Estonian Police and Border Guard Board. 
142 Finland does not issue long stay visa, solely resident permits. 

90 

 
 
 
                                                           
Member State 

Total number 
of submitted 
long stay visa 
applications in 
2019 

Total number of 
issued long stay 
visa in 2019 

Total number 
of submitted 
short stay visa 
applications in 
2019139 

Total number 
of issued short 
stay visa 
applications in 
2019140 

Total number of 
Schengen visa 
applications 
collected by 
ESPs 

Luxembourg 

Malta 

2 552 

3 631 

2 342 

3 488 

Netherlands 

61 960 

62 000143  

1 147 153 

1 090 294 

48 064 

6 934 

978 

37 807 

5 702 

926 

11 723 

34 765 

739 248 

454 026 

297 236 

25 202 

27 722 

11 251 

27 701 

630 181 

437 420 

235 897 

23 504 

21 685 

4 948 (42%) 

33 402 (96%) 

666 000 (90%)  

348 008 (75%) 

251 044 (85%) 

12 246 (49%) 

22 145 (83%) 

195 776 

179 642 

1 912 500 

1 668 171 

1 721 018 (90%) 

3 000 

3 000 

275 239 

227 717 

245 000 (89%)  

Member States that are not part of the EU 

Poland 

Portugal 

Slovakia 

Slovenia 

Spain 

Sweden 

Iceland 

Norway 

48 

284 

40144 

129 

Switzerland 

82 080 

74 218 

18 183 

178 532 

611 598 

18 020 

165 973 

529 906 

Associated Member States 

Bulgaria 

14 435 

13 111 

Croatia 

Cyprus 

N/A  

0 

N/A 

0 

Romania 

30 699 

29 571 

N/A 

N/A 

N/A 

N/A 

Ireland 

31 908 

28 612 

N/A 

Other consulted Member States 

N/A 

N/A 

N/A 

N/A 

N/A 

≈ 17 500 (95%) 

169 605 (95%)  

524 477 (86%) 

35 735 (NA) 

49 212 (66%) 

70 923 LTV due 
to CY status 

0145 

Not applicable as 
Ireland is not 
party to 
Schengen Acquis 

143 This number may also involve applications lodged in 2018 but approved/issued in 2019. 
144 40 long-term visas were issued and 8 refused (long term visas issued in Iceland). D visas (long stay visas) issued by Icelandic Embassies to those who 
have been granted a residence permit and need to travel to Iceland to have issued a residence permit were 108. 
145 Romania does not use ESPs. 

91 

 
 
 
 
                                                           
3. Questionnaires: Consultation with Member States and Public Consultation 

I. 

Questionnaire for Member States 

Purpose of the questionnaire:  

I. Contact details 

1.  Member State 
2.  Institution 
3.  Contact person / email 

Click here to enter text. 
Click here to enter text. 
Click here to enter text. 

II.  General consultation questions  

1.  Would the introduction of an online application procedure and a digital visa facilitate 
the existing (Schengen) visa application procedure and reduce possible administrative 
burdens for the central authorities and consulates? Which of the five options outlined 
in the cover note would better serve this purpose? 

Reply: 

2.  What  are  the  possible  benefits  of  online  visa  applications  and  digital  visas  for  the 
Member States? Do you expect digitalisation of visa processing to increase travel and 
tourism to the EU and thus to promote growth and employment? Do you have any 
evidence to quantify such impacts?  

Reply: 

3.  Should the initiative only cover Schengen (short-stay) visas or also national (long-

stay) visas? Why? List possible obstacles and advantages.  

Reply: 

4.  What  are  –  in  your  experience  –  the  possible  challenges  related  to  internet 
accessibility  and  computer  literacy  (if  any)  for  applicants  in  third  countries  when 
moving towards a digital visa procedure? Can you distinguish locations where specific 
issues might arise? How can these challenges be addressed and overcome? 

Reply: 

5.  What particular problems might visa holders, public authorities (other  than border 
guard and law enforcement) and private entities (e.g. hotels, banks, employers) face, 
when moving towards a digital visa processing (instead of a paper visa sticker affixed 
to  the  passport)?  How  could  these  problems  be  overcome?  Should  any  additional 
access rights to the data in the Visa Information System (VIS) be considered? 

Reply: 

III.  State of play of the national online application tools (update) 

1.  Do  you  have  (or  plan  to  create  in  the  short  to  mid-term)  any  online  tool(s)  to 
facilitate the visa application process for the applicant and/or the consulate? 

☐ In operation  

 ☐ Planned  

 ☐ No 

Comment:  

2.  What types of visas does (or will) your online tool(s) cover? 

☐ Schengen visa  

 ☐ National visa  

 ☐ Other: 

Comment: 

3.  When did you / when do you plan to introduce your online tool(s) to facilitate the visa 

application process? 

92 

 
 
 
Reply: (year) 

4.  If you significantly updated the online tool(s), when were the updates implemented? 

Reply: (year) 

5.  When  will  your  online  tool  development,  maintenance  and  support  cycle/contract 

end? 

Reply: (year) 

6.  Which of the following basic functionalities and features are included in your online 

application platform:  

☐ Wizard guiding the applicant on the type of visa 
☐ Information about general rules for lodging an application   
☐ Indication on the next available appointment before starting application 

process 

☐ Creation of personal account 
☐ Error detection / data quality check (e.g. alphanumeric) 
☐ Filling in the application form 
☐ Application fill-in and print out option (no direct link with the national VIS) 
☐ Data upload to the national VIS (direct link with the national VIS)  
☐ Upload of supporting documents  
☐ Lists of supporting documents (per third country / travel purpose) 
☐ Online payment of the visa fee 
☐ Appointment management 
☐ Signing the application:  

☐ Electronic signature or  
☐ Tick-box 

☐ ESP access to correct or complete/upload data 
☐ Other (provide information in the comment field) 

Comment: 

7.  Which  of  the  following  technologically  advanced  functionalities  and  features  are 
included or are considered to be included in the your online application platform:   
Choose  the  answer    Chatbot  to  support  preparation  and  application  process 
(from start to finish)  
Choose the answer  Providing facial image with a webcam / smartphone 
Choose  the  answer    Identification  with  live  face  recognition  using  webcam  / 
smartphone 
Choose the answer  Scan of the travel document to extract relevant data 
Choose the answer  Passport chip contents authentication using a smartphone  
Choose the answer  Photo morphing detection (for consulate) 
Choose the answer  Communication with the applicant through the online tool 
Choose the answer  Application status notification or verification 
Choose  the  answer    Statistics  and  reports  on  the  submitted  applications  (for 
consulates) 
Choose the answer  Smartphone application  
Choose the answer  Other (provide information in the comment field) 

Comment: 

93 

 
 
IV. 

Technical questions 
A.  Online application 

1.  Interaction with the applicant and work with the paper file today 
1.1. What is the average number of calls and/or emails from applicants related to the visa 

application process received at your consulates monthly? 

Reply: 

1.2. What is the average time spent replying to one visa application process related request 

received by phone or email? 

Reply: (min) 

1.3. What is the average time the consulate spends to accept  one paper application file 

(checking competence, completeness and admissibility)? 

Reply: (min) 

1.4. Please estimate how the time spend to accept, admit and examine application file will 
change,  if  applicants  submit  the  application  form  and  supporting  documents  only 
online and the online portal performs a check of completeness and quality? 

Reply: 

1.5. What is the average time the consulate spends to file one paper application file in the 

archive (selection, assessment, binding, organising etc.)? 

Reply: (min) 

1.6. What are the estimated costs to archive visa applications and supporting documents 
(paper-based  format)  for  2  years?  Please  consider  the  costs  related  to  premises, 
security and destruction.  

Reply: (EUR) 

2.  The  feasibility  study  estimated  the  costs  that  the  EU  would  face  related  to  the 
development and maintenance of an EU online application portal, as well as the costs 
the Member States will face related to the existing national online application tools 
or the adaptation and maintenance of the national systems to accommodate the EU 
online application portal. In addition to these potential costs for system development 
and maintenance, do you expect any additional costs at the national level related to 
the  implementation  of  the  EU  online  application  portal  (e.g.  training,  change 
management)? If yes, please provide estimations (EUR) 

Reply: 

B.  Digital visa 

1.  The  feasibility  study  concluded  that  implementation  of  the  digital  visa  would 
require  additional  investments  at  the  national  level:  software  to  generate  an 
encrypted 2D barcode, software for the border and/or law enforcement officers’ 
devices  to  read  the  2D  barcodes  and  update  of  national  systems  to  upload 
information  about  the  issued  visa  to  the  EU  portal  for  the  purpose  of  notifying 
applicants.  

1.1. How many of your border control and law enforcement officers are equipped with 
portable  devices  which  have  internet  connection,  specialised  applications  and  a 
camera to be able to scan and read the 2D barcode?  

Reply:  

94 

 
 
 
1.2. Do you plan to increase the number of officers equipped with such devices over the 
next  3-4  years?  To  what  extent?  If  a  digital  visa  would  be  implement,  how  many 
devices should be purchased? 

Reply: 

1.3. In addition to the potential costs mentioned above, do you expect any other costs at 

national level related to the implementation of the digital visa?  

Reply: 

3.  What is the number of FTEs146 dedicated to visa sticker management, printing and 
affixing in you consulates p.a.147? What  is  the average time needed to  print  a visa 
sticker  and  affix  it  to  the  passport  (including  all  tasks  needed  for  visa  sticker 
management)? 

Reply: (min) 

4.  Without  the  costs  associated  with  the  visas  sticker  production,  transportation  and 
personalisation, what would be other savings related to the digital visa introduction? 

Reply: (EUR) 

146 FTE means full-time equivalent (one person assigned at 100% to a task equals 1 FTE). 
147 Per annum (p.a.): refers to an average over the last 3 years (i.e. 2016, 2017, and 2018). 

95 

 
 
 
 
 
 
                                                           
I. 

Introduction 

II. 

Questionnaire for the public consultation 

Have you obtained a short-stay ‘Schengen’ visa over the past 5 years or would you like to make your 
voice heard on how the visa process could be modernised?  

The  European  Commission,  in  its  2020  New  Pact  on  Migration  and  Asylum,  set  the  objective  of 
making the Schengen visa procedure fully digitalised by 2025, and would like to hear your views on 
the idea to digitalise the current visa process, which includes the possibility for visa applicants to apply 
for a visa online and replacing the current (paper) visa sticker by a digital document. 

To apply for a Schengen visa, applicants today have to fill in an application form, gather the necessary 
supporting  documents  and  then  book  an  appointment  at  a  consulate  or  –  in  most  cases  –  a  visa 
application  centre  managed  by  an  external  service  provider,  to  submit  the  application,  give  their 
fingerprints, have a photo taken and pay the visa fee (in cash, by credit card or bank transfer). 

The initiative would introduce a number of novelties for visa applicants and Member States. The online 
application  process  would  enable  a  large  number  of  applicants  to  submit  their  applications  online, 
without having to show up in person at the consulate or visa application centre. In case of a positive 
decision, the visa would be issued in a digital format, accessible to the visa holders and the authorities 
that need to have access.  

This consultation concerns the digitalisation of the EU’s visa procedures. To travel to the EU, third 
country nationals may require a Schengen visa (Type C) or long-stay visa (Type D). This consultation 
focuses mainly on the Schengen Visa which entitles its holder to travel throughout the 26 Member 
States148 for up to 90 days in any 180-day period.  

Individuals: Tell us about your experience and views by replying to our questionnaire. You do not 
need to answer all of the questions. However, for your response to be taken into account, all questions 
under the 'About you' section need to be answered. If you have any concerns regarding data protection 
matters, please consult the Privacy Statement. 

Organisations:  Send  written  contributions  on  any  issue  linked  to  the  visa  process  digitalisation 
through the online questionnaire. Organisations are also invited to encourage individual members to 
reply to the questionnaire. 

Disclaimer 

The possible changes to the visa procedures envisaged in this questionnaire do not prejudge the final 
options that will be proposed by the European Commission. The questions refer to specific options for 
digitalisation of the procedures currently being considered by the European Commission. 

II.  About you (all respondents) 

148 Belgium, Czech Republic, Denmark, Germany, Estonia, Greece, Spain, France, Italy, Latvia, Lithuania, Luxembourg, Hungary, Malta, the 
Netherlands, Austria, Poland, Portugal, Slovenia, Slovakia, Finland, Sweden, Iceland, Liechtenstein, Norway and Switzerland. 

96 

 
 
                                                           
1.  Language of my contribution 

Language drop list 

2.  I am giving my contribution as 

Defined drop list 

3.  First name 
Free text 

4.  Surname 
Free text 

5.  Email (this won't be published) 

Free text 

6.  Have you applied for a Schengen visa in the past five years? (only for non-EU citizens) 

Yes/No 

7.  What was the (main) reason for travel? (Single choice) (only for Yes Q6) 

  Tourism  
  Business/professional training/conference 
  Visit to family/friends  
  Cultural/sports event  
  Medical treatment 
  Other 

8.  I travel frequently to the Schengen area (more than twice a year – at least before COVID-

19-related travel restrictions) (only for Yes Q6) 
Yes/No 

9.  I am a family member of a mobile EU citizen travelling with or joining the EU citizen (i.e. 

I am covered by Directive 2004/38/EC) (only for Yes Q6) 
Yes/No 

10. What is your age group: (only for Yes Q6) 

  18 to 24 
  25 to 39  
  40 to 60 
  above 60 

11. Scope (only for organisations) 

97 

 
 
 
 
 
 
 
 
 
 
 
 
Defined drop list 

12. Level of governance (only for organisations) 

Defined drop list 

13. Organisation name (only for organisations) 

Free text 

14. Organisation size (only for organisations) 

Free text 

15. Transparency register number149 (only for organisations) 

Free text 

16. Country of origin150  
Country drop list 

The Commission will publish all contributions to this public consultation. You can choose whether 
you would prefer to have your details published or to remain anonymous when your contribution is 
published.  For  the  purpose  of  transparency,  the  type  of  respondent  (for  example,  ‘business 
association, ‘consumer association’, ‘EU citizen’) country of origin, organisation name and size, 
and its transparency register number, are always published. Your e-mail address will never be 
published. Opt in to select the privacy option that best suits you. Privacy options default based on the 
type of respondent selected 

Contribution publication privacy settings151  

(for individuals) 

Anonymous:  
The type of respondent that you responded to this consultation as, your country of origin and 
your contribution will be published as received. Your name will not be published. Please do 
not include any personal data in the contribution itself. 
Public 
Your name, the type of respondent that you responded to this consultation as, your country of 
origin and your contribution will be published. 

(for organisations) 
Anonymous 
Only  organisation  details  are  published:  The  type  of  respondent  that  you  responded  to  this 
consultation  as,  the  name  of  the  organisation  on  whose  behalf  you  reply  as  well  as  its 

149 Check if your organisation is on the transparency register (. It's a voluntary database for organisations seeking to influence EU decision-making. 
150 Please add your country of origin, or that of your organisation. 
151 The Commission will publish the responses to this public consultation. You can choose whether you would like your details to be made public or to 
remain anonymous. 

98 

 
 
 
 
 
 
 
                                                           
transparency number, its size, its country of origin and your contribution will be published as 
received.  Your  name  will  not  be  published.  Please  do  not  include  any  personal  data  in  the 
contribution itself if you want to remain anonymous. 
Public 
Organisation  details  and  respondent  details  are  published:  The  type  of  respondent  that  you 
responded to this consultation as, the name of the organisation on whose behalf you reply as 
well as its transparency number, its size, its country of origin and  your contribution will be 
published. Your name will also be published. 

I agree with the personal data protection provisions (hyperlink) (check box) 

III.  Cost and benefits for visa applicants (only persons having previously applied for a 

Schengen visa) 

The following questions will help the European Commission to estimate the costs and benefits of visa 
digitalisation for visa applicants.  

17. When you last applied for a Schengen visa, did you encounter any of the following 

difficulties? (at most 3 choice(s)) 
  I had to travel long distance to the consulate / visa application centre. 
  The application process was time consuming.  
  The application process was complicated. 
  My application was not admitted due to incomplete file or other mistakes. 
  I could not travel during the application process because my passport was at the consulate. 
  I did not know when to collect my passport from the consulate/visa application centre. 
  Other: ____________ 
  No particular difficulty. 

Please specify other: (free text) 

18.  When you last applied for a Schengen visa,  

  which distance did you have to cover to get to the next consulate or visa application centre: 

… km 

  how many hours did it take you to get there, to apply and to get back (total time spent): … 

hours 

  how much did you pay for the transport to get there (return trip): … EUR 
  how much did you pay for accommodation in that location: … EUR 

Apart from the visa and service fees, costs of providing supporting documents and travel 
medical insurance, were there any other costs? If yes, for what and how much: (free text) 

99 

 
 
 
  
 
19. How did you retrieve your passport at the end of the visa application and how much did 

you pay? 
  By personal pick-up: … EUR in transportation costs 
  By courier delivery: … EUR in delivery costs 

20. Do you expect any additional costs due to the online application and the digital visa? 

Yes / no 

If yes, for what and how much: (free text) 

21. How easy or difficult would the following tasks be for you: 

  accessing  the  internet  to  submit  an  application  online,  or  to  have  access  to  the  digital 

documents (e.g. digital visa, if/once your visa is issued) 

  receiving and reading email messages  
  online / mobile payment  
  scanning and uploading documents to an online website/portal 
  scanning your travel document with your mobile device (through a dedicated app) 
  using support tools, such as online tutorials or chatbots 

(on each point, rank from very easy to very difficult from 1 to 5) 

22. Which form of electronic payment tools would you be able to use? (at most 5 choice(s)) 

  credit cards 
  debit cards 
  PayPal 
  mobile payment 
  Other: … 

Please specify other: (free text) 

IV.  General views (all respondents)  

23. What is your general view on making visa procedures less paper-based and more digital?  

Very positive – positive – neutral – negative – very negative 

24. Do you think that digital visa procedures would: 

  promote travel and tourism to the EU  
  promote family visits / business / cultural or scientific exchanges  
  contribute to a positive image of the EU or Schengen Area 
  lead to greater transparency in the Schengen visa process 
  promote the security of the Schengen Area 

(on each point, rank from 1 (strongly agree) to 5 (strongly disagree)) 

V.  Online application (all respondents)  

100 

 
 
 
 
Instead of  a paper-based application that exists today, the applicants  would  use an online portal  to 
apply for a Schengen visa in the future. The visa portal would allow the applicants to: 

fill out the digital application form online,  

 
  upload the supporting documents and a copy of the passport,  
  pay the visa fee online,  
  book an appointment (where necessary – see below for further information),  
  sign and submit the application electronically, 
 
track their application status online and  
 
receive a notification when a decision has been taken.  

Booking an appointment to visit the consulate or visa application centre might still be necessary for 
first-time applicants and then every five years to give fingerprints and have a photo taken, as well as 
each time the visa applicant has a new passport. If they don’t fall into any of these cases, repeat visa 
applicants would therefore be able to complete the entire application process online, without visiting 
the consulate or visa application centre. 

25. Do you agree that such an online application process would facilitate the Schengen visa 

application procedure for visa applicants? 
Strongly agree – agree – neutral – do not agree – do not agree at all  

(if not agree/do not agree at all): Why? … 

26. What would be the main benefits of the online application? (at most 3 choice(s)) 

The application procedure would be: 
  quicker 
  cheaper 
  more transparent / predictable 
  more user-friendly 
  more modern and in line with an increasingly digital world. 

If you see any other benefit, please specify: … 

27. How important do you consider the fact that (repeat) applicants would not have to visit 

the consulate or visa application centre? 
Very important – important – neutral – not very important – not important at all  

28. Do you foresee any obstacles / drawbacks for visa applicants with the online application 

procedure? 
Yes / no 

If yes, what would be the main obstacles / drawbacks? (at most 3 choice(s)) 
  no / bad access to the internet 
  lack of necessary equipment (e.g. computer/mobile phone) to access the application portal 

101 

 
 
 
  applicants’ lack of computer literacy  
  online / mobile payment 
  scanning and uploading documents 
  no possibility to ask questions  
  concerns about privacy / data security 
  other: … 

Please specify other: (free text) 

What would help applicants to overcome these obstacles / drawbacks? (at most 3 choice(s)) 
  support from relatives or friends 
  support from travel agencies or other intermediaries 
  support from visa application centres or consulates 
  support through online tutorials 
  support through automated chatbots in the online portal 
  maintaining the paper-based procedure in exceptional cases  
  other: … 

Please specify other: (free text) 

29. It would be preferable to submit the Schengen visa application on: 

  a single EU digital visa portal, regardless of the main destination of the trip 
  national portals managed by each EU Member State, depending on the main destination of 

the trip 

  both solutions would be fine 

Schengen visas (C type) are valid for short stays in the EU up to 3 months. For stays of more than 3 
months (and up to one year), for example for studying or working in the EU, it is necessary to apply 
for long-stay visas (D type). 

30.  How important do you consider the possibility to apply online not only for Schengen 
visas (for stays up to 3 months), but also for long-stay visas (for stays between 3 months 
and 1 year)? 
Very important – important – neutral – not very important – not important at all  

VI.  Digital visa (all respondents)  

Nowadays visas are issued in the form of a paper visa sticker affixed to the passport. In the future, 
visas could be issued in a secure digital format. Applicants would be notified on the decision taken by 
the consulate (if the visa is issued, refused etc.) by email or other electronic means. The notification 
would  contain  the  data  currently  found  on  the  visa  sticker  and  (possibly)  a  barcode.  A  secure 
verification tool, which would be part of the digital visa portal, would enable applicants both to verify 
the status of their application and the validity of their visa after issuance.  

102 

 
 
By moving away from paper visa stickers, the visa procedure would change from the point of view of 
the  applicants/visa  holders:  the  applicants  would  no  longer  need  to  leave  their  passport  with  the 
consulate for the duration of the application procedure. The applicants would thus be able to travel 
abroad  while  the  visa  application  is  being  processed.  Collecting  the  passport  at  the  end  of  the 
procedure, or receiving it via courier delivery, would also not be needed anymore. Digital visa validity 
would be independent of the validity of passports, meaning that a valid visa could be confirmed and 
linked to a new passport (also in cases of lost or stolen passports). 

31. Do  you  agree  that  the  digital  visa  (instead  of  the  physical  sticker)  would  facilitate  the 
Schengen  visa  application  procedure  and  travelling  to  the  EU  Schengen  area  for  visa 
holders? 
Strongly agree – agree – neutral – do not agree – do not agree at all  

32. Which advantages of the digital visa do you consider as important? 

  Not having to leave a passport for a period of time at the consulate and thus the possibility 

to travel abroad during the visa application procedure. 

  Not having to retrieve the passport at the end of the visa application procedure. 
  Having easy access to the visa status from a mobile device. 
  The visa could remain valid even if the passport validity expires or if the passport is lost or 

stolen, and could be transferred to a new passport. 

  Smoother border control checks.  

(on each point, rank in importance from 1 to 5) 

33. Do you foresee any obstacles / drawbacks for holders of a digital visa? 

Yes / no 

If yes, what would be the main obstacles / drawbacks? (atmost 3 choice(s)) 
  no / bad access to the internet 
  lack of necessary equipment to access the digital visa 
  applicants’ lack of computer literacy  
  limited access to the visa by other parties (carriers, hotels etc.)  
  concerns about personal data / privacy  
  other: … 

Please specify other: (free text) 

34. What would be important features for visa applicants: (atmost 3 choice(s)) 

  email notification on visa status (issued, refused, revoked, annulled, extended)  
  the possibility to print out the digital visa 
  permanent access to an EU online visa portal to check the visa status 
  support tools, such as online tutorials or chatbots 
  the possibility to contact the authorities 

103 

 
 
 
  other: … 

Please specify other: (free text) 

VII.  Conclusion (all respondents) 

35. Are there other problems that should/could be addressed? If you wish to add information 
on other issues linked to the digitalisation of visa procedures, please feel free to do so here: 
(free text) 

36. You can upload here a concise written contribution (such as a position paper) on any issue 

linked to the digitalisation of visa procedures. The maximal file size is 1MB.  

Please note that your responses to the questionnaire as well as the uploaded document will be 
published. 

104 

 
 
 
 
 
 
ANNEX 3 – WHO IS AFFECTED AND HOW? 

1.  Practical implications of the initiative 

The preferred option (O4) would have a positive impact on EU travel and GDP with an additional 
GDP of EUR 53.3 billion on the 2025-2029 period, as  it would mark the transition  from  a largely 
paper-based application process to a truly digital and harmonised process.  

The  EU  visa  application  platform  would  benefit  Member  States  by  decreasing  time  spent  by 
consulates  on  processing  and  archiving  paper  visa  applications.  Cases  of  visa  shopping  would  be 
directly reduced and checks against the Visa Information System would be done at an earlier stage 
allowing only admissible applications for processing 

The digital visa would improve the internal security of the Schengen area, as the visa sticker could no 
longer be falsified, and would considerably reduce the administrative burden on Member States’ 
central  authorities  and  consulates,  who  would  no  longer  have  to  spend  time  and  money  on 
manufacturing, ordering and securely transporting visa stickers to  the consulates. Overall, Member 
States would save EUR 553 million in administrative costs on the 2025-2029 period under O4.  

Finally, visa applicants would also benefit from option 4. Repeat applicants would no longer need to 
incur the cost of travel to apply for a visa, and applicants would keep their travel documents with them 
throughout the application process. Under option 4, each applicant would save EUR 31 per application 
out of a total of EUR 74 spent in the baseline scenario for each application.  

2.  Summary of costs and benefits 

Table 21: Overview of benefits for the preferred option  

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

Description 

Amount 

Comments 

Recipient:  third-country  nationals.  As 
most  repeat  applicants  would  be  able  to 
submit  their  applications  in  a  totally  digital 
manner, they would no longer need to spend 
money and time to visit a consulate/VAC and 
to pick up their travel document. Moreover, 
although first time applicants will still have a 
cost  associated  with  travelling  during  the 
application  process,  the  expenditure  related 
to collecting the travel document is abolished 
for them as well. 

Cost savings for third 
country nationals 
(2025-2029) 

Direct benefits 

Average  cost  saved  by  one  applicant  in  the 
application process: approximately EUR 14 

Average  cost  saved  by  one  applicant  to  pick  up 
travel document: approximately EUR 17 

Average  total  cost  saved  by  one  applicant 
(application and pick-up): approximately EUR 
31 

Total  cost  saved  by  all  applicants 
application process: EUR 1.3 billion 

in 

the 

Total cost saved by all applicants to pick up travel 
document: EUR 1.6 billion 

Total  cost  saved  by  all  applicants:  EUR  2.9 
billion 

105 

 
 
 
 
 
 
 
Cost savings for 
Member States 
(2025-2029) 

Archiving visa applications 
Cost  saved  by  all  MSs  on  resources:  EUR  4.4 
million 

Average cost saved by one MS on resources: EUR 
170 000 

Visa stickers 
Cost saved by all MSs: EUR 80.3 million 

Average cost saved by one MS: EUR 3.1 million 

Administrative cost 
savings for Member 
States (2025-2029) 

Processing visa applications  
Time saved by all MSs: 867 FTEs 

Cost saved by all MSs on staff: EUR 38.1 million 

Replying to queries 
Time saved by all MSs: 576 FTEs 

Cost saved by all MSs on staff: EUR 25.3 million 

Archiving visa applications 
Time saved by all MSs: 4 248 FTEs  

Cost saved by all MSs on staff: EUR 186.9 million 

Managing visa stickers 
Time saved by all MSs: 4 014 FTEs 

Cost saved by all MSs on staff: EUR 176.6 million 

Total FTEs saved by all MSs: 9 685152 

Total FTEs saved on average by one MS: 372 

Total admin costs saved by all MSs: EUR 510.9 
million 

Total admin costs saved on average by one MS: 
19.7 million 

Paper saved: approximately 3 million kg 

CO2 saved: approximately 1.4 billion kg 

Lower use of paper 
due to digital visa and 
application platform 
(2025-2029) 

Lower CO2 emissions 
during the application 
process (2025-2029) 

Lower risk of fraud 
and thus 

Not quantified 

Recipient:  Member  States.  The  online 
storage would enable cost savings on paper-
based archiving and real estate; the removal 
of  the  visa  sticker  would  enable  Member 
States  to  save  current  costs  to  procure, 
transport, store and print stickers. 

Recipient:  Member  States.  The  online 
submission of most visa applications and the 
automated functionalities of the EU platform 
would  enable  Member  States  to  save  time 
and staff currently allocated to the intake and 
archiving  applications,  and  replying 
to 
queries by applicants. The digital visa would 
enable  savings  on  staff  currently  managing 
(printing and affixing) visa stickers. 

States 

Member 

Recipient: 
& 
environment. The majority of third-country 
nationals  would  no  longer  use  paper  to 
submit their application form and supporting 
documents. Paper currently used for stickers 
would no longer be needed. 

Recipient:  Environment.  The  majority  of 
repeat  applicants  would  no  longer  need  to 
visit a consulate/VAC to apply, hence  their 
carbon  footprint  during 
the  application 
process would be sensibly reduced. 

Recipient: Schengen border authorities & 
EU residents with regard to the removal of 

152 Includes 59 extra FTEs needed to collect biometrics of the additional group of third country nationals expected to apply under O4. 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
strengthening 
security of the EU  

data 

Not quantified 

Harmonised 
management 
practices 
processing of data 

for 

More attractive image 
of the Schengen Area 

Not quantified 

Increased mobility for 
country 
third 
nationals 

Not quantified 

Reduced  reliance  on 
External 
Service 
Providers (ESPs) 

Not quantified 

Indirect benefits 
Contribution 
of 
international  travel  to 
EU GDP (2025-2029) 

Approximately EUR 19.1 billion  

Lower  risk  of  visa 
shopping 

Not quantified 

Benefits  for  the  visa 
examination process 

Not quantified 

107 

the sticker. It would reduce the risk of fraud 
and  enable  Schengen  border  authorities  to 
exploit the synergies of interoperability. 

Recipient:  third  country  nationals.  With 
the EU platform the Member States would no 
longer  use  their  national  data  management 
practices that are currently not harmonised. 

Recipient:  Member  States  and  third 
country nationals. The EU platform would 
offer a coherent and harmonised entry point 
to  third  country  nationals,  increasing  the 
consistency  and  attractiveness  of 
the 
Schengen Area and encouraging travel. This 
would  increase  the  incentives  to  travel  for 
third country nationals.  

Recipient:  third  country  nationals,  who 
would be free to use their passport and travel 
during 
the  application  process;  Repeat 
applicants  with  reduced  mobility  would  no 
longer  need  to  appear  in  person  at  a 
consulate/VAC. 

Recipient:  third  country  nationals.  There 
is  no  longer  a  need  for  ESPs  to  intake  visa 
applications  and  process  personal  data  of 
repeat  applicants.  Third  country  nationals 
would  therefore  not  have  to  pay  additional 
fees  for  the  ESP  to  apply  for  a  visa  and/or 
lower fees may apply. 

Recipient: Member States. By encouraging 
more  third  county  national  to  apply  for  a 
visa,  the  EU  platform  would  increase  the 
the  GDP 
travellers  and 
number  of 
contribution  of  visa  holders/third  country 
nationals would increase accordingly. 

Recipient: Member States. By providing a 
single-entry  point  for  all  visa  applications, 
the EU platform would oblige third country 
nationals to apply for the competent Member 
State. It would limit the input of misleading 
information on the Member State of entry.  

Recipient:  Schengen  visa  authorities  and 
border  authorities. 
If  Schengen  visa 
authorities  re-allocate  (part  of)  the  saved 
FTEs  to  decision-making,  Member  States 
may  further  improve  the  examination  and 
risk  assessment  of  visa  applicants,  thereby 
further contributing to EU security. 

 
 
 
 
Third country 
nationals 

Environment 

Recurrent (no one-
off costs) 

Recurrent (no one-off 
costs) 

N/A 

N/A 

Table 22: Overview of costs for the preferred option  

II. Overview of costs – Preferred option 

EU institutions  

Member States 

One-off 

Recurrent 

One-off 

Recurrent 

EU 
application 
platform 

Direct 
costs 

EU  digital  application 
platform (total: 
EUR 
31.2 – 38.1 million) 
Design:  EUR  6.3  –  7.6 
million 
Development:  EUR  5.9  – 
7.2 million 
Testing:  EUR  4.7  –  5.8 
million 
Deployment: EUR 1.6 – 2 
million 
& 
Hardware 
Infrastructure: EUR 11.3 – 
13.8 million 
Overhead:  EUR  1.4  –  1.7 
million 
VIS  adaptations  (total : 
2.6 – 3.1 million) 
Initial migration: EUR 220 
000 – 270 000 
Synchronisation: 
200 000 – 240 000 
Hardware 
& 
Infrastructure : EUR 2.2 – 
2.6 million 
Training  costs:  EUR  20 
000 – 33 000 
Development 
staff: EUR 2.5 million 

support 

EUR 

recurrent 

costs 
Total 
per  MS): 
(average 
& 
Maintenance 
Operations: EUR 460 000 
– 570 000 
Total  recurrent  costs  (all 
MSs):  Maintenance  & 
Operations:  EUR  11.6  – 
14.1 million 

Yearly 
recurrent 
costs: EUR 10.5 – 12.8 
million 
EU  digital  application 
platform: EUR 8.2 – 10 
million 
VIS  adaptations:  EUR 
390 000 – 480 000 
Licenses: EUR 1.9 – 2.3 
million 

EU digital application 
platform (average per 
MS):  EUR  2.8  –  3.3 
million 
Integration 
& 
adaptation:  EUR  270 
000 – 330 000 
Hardware 
Infrastructure : 
2.5 – 3.0 million 
EU digital application 
platform  (all  MSs): 
EUR  68.3  –  83.5 
million 
Training costs 
Average  per  MS:  EUR 
33 000 
All MSs: EUR 858 000 

& 
EUR 

108 

 
 
 
Indirect 
costs 

N/A 

N/A 

N/A 

N/A 

CO2  produced  by 
increased travel to the 
(2025-2029): 
EU 
approximately 
8.5 
billion kg  

with 

Potentially 
limited 
access  to  IT  tools 
with 
(decreases 
time) 
Potentially 
higher 
service  fee  for  IT 
assistance 
(decreases 
time) 
Additional 
processing 
of 
personal data by the 
platform 
(email 
address, 
credentials); 
and 
potentially  by  ESPs 
(on-site 
identification 
first-time 
applicants) 

of 

Digital visa   Direct 
costs 

N/A 

Indirect 
costs 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

109 

 
 
 
 
 
ANNEX 4 – METHODOLOGICAL NOTE ON COSTS AND BENEFITS 

This annex lists the general and option-specific assumptions and estimates that are adopted to estimate 
the impacts of the policy options to digitalise the Schengen visa process. The reader is referred to the 
‘Study to assess the various options related to visa process digitalisation and to support the preparation 
of  an  impact  assessment  -  Final  Report’153  for  details  on  the  rationale  and  calculations  behind  the 
assumptions. 

Table 23: Assumptions used in the study  

Assumption 

Value 

General assumptions (valid for all options) 

10 seconds 
15 minutes 

17.8 million 
19.7% 

Number of baseline visa applications (2025-2029) 
Contribution of Visa holder-TCNs to GDP against total contribution of 
international travel to GDP 
Average time for checking visa sticker at the border 
Average time to receive and admit a Schengen visa application at the 
consulate 
Average time to enrol biometrics of a Schengen visa applicant at the consulate  6.6 minutes 
Percentage of visa applications for which applicants submit a query to 
consulate / ESP 
Average time spent by the consulate to reply to one query 
Percentage of visa applications collected by consulates vs ESPs against the 
total number of visa applications submitted 
Percentage of repeat visa applicants 
Percentage of applicants expected to utilise the available digital solutions 
Average cost for one visa applicant to travel to the consulate / VAC to apply 
Average cost for one visa applicant to travel to pick up the travel document 
Weighted average of the carbon footprint of one third country national 
travelling to the EU 
The average distance between one visa applicant and the closest VAC or 
consulate  
Average distance covered by one TCN to reach the Schengen Area 
Assumptions related to Option 1 

75% 
97% 
EUR 56.89 
EUR 16.84 
0.18388492 kg 
CO2/km154 
129.79 km155 

8.9 minutes 
90% 

4 073.74 km156 

16% 

Percentage of visa applicants needing to travel in visa application process 
Level of digitalisation of visa process in the Member States 

100% 
Refer to external 
study 

Percentage of visa applicants needing to travel in visa application process 

76% 

Assumptions related to Option 2 

153 Study to assess the various options related to visa process digitalisation and to support the preparation of an impact assessment - Final Report, available: 
https://ec.europa.eu/home-affairs/study-assess-various-options-related-visa-process-digitalisation-and-support-preparation-impact_en. 
154 Reflecting the tourist transportation trends within the European Union Tourism Trends 2018, which states that 47% will travel to the EU by air, 40% 
by land and 3% by water, and the aforementioned carbon footprints of these means of transportation. 
155 Based on 247 observations from the public consultation. 
156 This value was obtained based on the number of short-stay visas issued to citizens of each third country, and on the distance between the capital of 
each third country and Berlin (i.e. a central location in the Schengen Area). Each distance was multiplied by the total number of visas issued to the third 
country in question. Finally, the results for each third country were summed up. 

110 

 
 
 
                                                           
Assumption 

Assumptions related to Option 3 

Number of Member States expected to join the optional digital application 
platform 
Growth rate in visa applications due to digital process  
Rate of queries that are solved by the introduction of the platform (with no 
need for intervention by ESP / consulate staff) 
Percentage of paper saved during the visa application process (valid also for 
options 3 and 4) 

Assumptions related to Option 4 

Growth rate in visa applications due to digital process 

Assumptions related to Option 5 
Number of applicants needing to travel in visa application process 
Growth rate in visa applications due to digital process 

Value 

16 

2% 
50% 

60% 

2% 

3% 
4% 

111 

 
 
 
 
 
ANNEX 5 – GLOBAL TRENDS ON VISA PROCESS DIGITALISATION 

International perspectives and benchmarking  

As global mobility is increasing, more and more countries are digitalising their visa services. Not only 
to be able to meet the continuing rise in demand but also to accommodate the expectations of applicants 
for digital public services. However, as the number of people crossing the borders s increases, so do 
the  security  risks.  By  digitalising  their  visa  process,  countries  on  the  one  hand  aim  to  offer  to  the 
applicants a better service and on the other hand improve their risk assessment capabilities through 
increased availability of digital data and interoperability of systems in which this data is recorded.  
The development and implementation of an EU online application platform also intends to meet these 
contemporary  demands  and  expectations.  It  will  contribute  to  the  digitalisation  of  public  services, 
making Europe fit for the digital age, and to a safe and secure EU.  

Benchmarking countries 

When identifying countries for benchmarking, the guiding principle was that there should be a high 
visa volume as well as a high degree of digitalisation of the visa procedures. The following countries 
have been taken into consideration in the identification phase: Australia, Canada, China, India, New 
Zealand, Russian Federation, UK, US.  
In order to establish how the envisioned EU online application platform compares with similar systems 
these countries have in place, the benchmarking was carried out on following principles: 

  all third country nationals who are subject to visa requirements can apply online; 
  all visas are issued digitally. 

Desk research has shown that, of the eight aforementioned countries, only two have digitalised their 
visa procedures as expected for the future EU Online application platform: Australia and New Zealand.  
The digital visa services that the other six countries have in place do not fully meet these principles 
and are therefore not suitable for comparison. The majority of the eVisa services that these countries 
offer are more similar to ETIAS. They have been introduced to pre-screen visa exempt travellers prior 
to  travel  or to  facilitate  certain  foreign nationals subject  to  visa requirements  in  quickly and  easily 
obtaining an electronic travel authorisation (ETA) for specific travel purposes.  When the eligibility 
requirements to apply for a travel authorisation are not fulfilled, visa required third country nationals 
cannot,  or  only  partially,  apply  online  and  visas  are  issued  in  paper  format,  affixed  to  the  travel 
document.  

Benchmarking digital visa systems Australia and New Zealand  

112 

 
 
 
For the benchmarking exercise, the Visitor visa systems of Australia and New Zealand were compared 
with the prototype157 of the EU Online application platform on the basis of the most common steps in 
the online application procedures and the issuance and verification of digital visas.  

Digital Services  
for applicants 
Visa type 
Apply online 
Creation of an account 
Upload digital facial image 
Upload bio date page travel 
document 
Upload digital documents 
Online payment during 
application process 

EU 

Australia 

New Zealand 

Prototype 
 
 
- 

Visitor visa 
 
 
 

Visitor visa 
 
 
 

 

 

 

 

 

 

 

 

 

Collection of biometrics at 
consulate or VAC 

 
Every 5 years 

Check application status 
Check validity biometrics 
online 
Digital visa 
View digital visa details 
online 
Request extension online 
Chatbot 

 

 

 

 

 
 

 
For each 
application 
 

 
For each 
application 
 

Not applicable  Not applicable 

 

 

 
 

 

 

- 
- 

Conclusion 

The services that a future EU Online application platform would offer are almost equal to the Visitor 
Visa systems  of Australia and New Zealand with the exception of uploading a facial  image by the 
applicant. A major difference concerns the enrolment of biometrics. Foreign nationals wishing to travel 
to Australia or New Zealand, are required to provide their biometric at a VAC every time they apply. 
The future EU Online application platform, would enable repeat applicants to submit their application 
entirely online until the 59-month validity of their biometrics. This distinguishing feature would make 
the envisioned EU system the ahead of its time.  

State of play Australia and New Zealand 

Australia 

157 The development of a prototype of an EU online application platform is part of the recommendation in the feasibility study on digitalisation of visa 
procedures, to conduct a two-phased pilot  

113 

 
 
 
 
 
                                                           
Australia  was  the  first  country  in  the  world  to  launch  electronic  visas  in  1996  by  introducing  an 
Electronic Travel Authority System (ETA), a system that allowed visas to be issued electronically, 
linking them to the applicant’s passport and eliminating paper application forms.  
The  short  stay  visa  regime  caters  different  groups  of  applicants:  eVisitor,  ETA,  and  Visitor  visa. 
eVisitor is reserved for European citizens, allowing them to travel to Australia for up to 3 months per 
visit,  for  tourism  or  business  purposes.  It  is  a  pre-screening  before  travel  and  therefore  similar  to 
ETIAS despite the fact that European citizens are not exempt from the visa requirement. 
ETA is an electronic travel authorisation for a short term stay and reserved for nationals of Brunei, 
Canada, Hong Kong (SAR PRC), Japan, Malaysia, Singapore, South Korea and the United States.  
The Visitor visa is required for all other foreign nationals and therefore similar to the future EU online 
application platform. Applying for a Visitor visa can be done fully online but applicants are required 
to appear in person and provide biometrics for each application.  
Australia officially ceased the issuance of visa stickers in  2015. All  visas are recorded in  a central 
database  where  they  can  be  accessed  through  an  online  verification  Service  called  VEVO  (Visa 
Entitlement  Verification  Online),  allowing  visa  holders,  employers,  education  providers  and  other 
organisations to check visa details and conditions.  

New Zealand 

In 2019 New Zealand launched the New Zealand electronic Travel Authority (NZeTA) which is similar 
to ETIAS as it is a requirement for visa exempt foreign nationals (including EU-citizens) for a short-
term  stays  for  tourism,  visiting  friends  and  family,  meetings,  short  term  study  or  a  transit  through 
Auckland International Airport. 
Visa-required nationals need to apply for a Visitor visa which can be done fully online. In almost all 
cases applicants are required to visit a VAC to provide their biometrics which has to be done for each 
subsequent application. 
New Zealand abolished the use of the paper visa sticker in 2018. All issued visas are recorded in a 
central  database  where  they  can  be  accessed  through  a  Visa  Verification  Service.  Applicants  also 
receive an eVisa letter to be printed out and carried during the journey. Upon request and payment of 
a fee a visa sticker can be affixed to the holder’s passport. 

State of play of other six countries – short overview 

Canada 
Foreign nationals that are subject to visa requirements need to obtain a Visitor visa. They can apply 
online but most applicants still need to go to a VAC for the collection of biometrics. The validity of 
biometrics is 10 years so repeat applicants do not have to provide them for subsequent applications 
within that time period. They can check the validity with an online tool. Visas are issued as a sticker 
and when granted, the applicant needs to submit the travel document to the VAC once more in order 
to have the visa sticker affixed.  

An  Electronic  Travel  Authorisation  (ETA)  is  required  for  visa-exempt  foreign  nationals  (including 
EU/EEA countries and Switzerland) if they arrive in Canada by air. This can be done fully online and 

114 

 
 
 
 
the travel authorisation is issued electronically. This system was introduced in 2016 and is equal to 
ETIAS in terms of purpose and target group.  

China 
In 2018, China introduced the China Online Visa Application (COVA), which all nationals who require 
a  visa  (including  citizens  of  the  EU,  EEA  and  Switzerland)  are  obliged  to  use  to  submit  their 
application form online. However, after submitting it online, applicants should print and sign the form 
and submit it along with all other required documents to the consulate. Visas are issued in paper format 
and affixed to the travel document. China is considering offering a fully digital application procedure 
in the future for eligible foreign nationals.  

India 
India introduced the Electronic Travel Authorization (ETA) for citizens from more than 40 countries 
in 2014, extending it to 113 countries in 2015 while also renaming it e-Tourist Visa (eTV). In 2017, 
the scheme was renamed e-Visa and divided into 5 subcategories: e-Tourist Visa, e-Business Visa, e-
Conference Visa, e-Medical Visa and e-Medical Attendant Visa. Applicants receive their e-Visa by e-
mail and they are obliged to carry a copy at the time of travel. Currently there are 151 countries eligible 
for e-Visa (including EU-, EEA-countries and Switzerland).  
Foreign nationals not eligible for an e-Visa need to apply for a regular visa where use of the online 
form is mandatory. After submitting the application  online, including digital facial image, the form 
should  be  printed,  signed  and  submitted  at  the  consulate  or  VAC  together  with  the  supporting 
documents  and  payment  of  visa  fee  (for  locations  where  e-payment  is  not  available).  The  travel 
document  is  withheld  for  the  purpose  of  affixing  the  visa  sticker  and  can  be  collected  from  the 
consulate or Visa Application Centre or sent  by  post after the application has been processed. The 
status of a visa application can be checked online with a visa enquiry tool.  

Russian Federation 
The  Russian  Federation  introduced  its  first  electronic  visa  (e-Visa)  in  2017.  It  could  be  granted  to 
foreign nationals from 18 countries to visit selected regions in the country. It allowed a single entry 
(for business, tourism or a humanitarian visit) for a maximum term of 8 days to travel to the far eastern 
regions  of  the  country.  In  2019  the  territorial  validity  was  expanded  to  Kaliningrad  and  Saint 
Petersburg and the number of eligible countries extended to 53 (including EU/EEA-countries (except 
UK) and Switzerland). The Unified eVisa was launched early this year as part of the Russian ‘Digital 
Economy’ plan. It is a single entry visa valid for the entire territory of the Russian Federation, for a 
stay up to 16 days. The electronic visa will be issued electronically and sent to the applicant by email. 
It is expected that Unified eVisas will come into full force by the end of 2021 for the same 53 eligible 
countries.  
Foreign nationals not eligible for an eVisa, need to apply for a regular visa. This application procedure 
is not digitalised; applicants must visit the consulate to submit their application in paper. This visa is 
issued in the form of a sticker to be affixed in the travel document. 

115 

 
 
 
 
 
United Kingdom 
Foreign nationals who are subject to the visa requirements must apply for a standard Visitor visa. The 
application procedure was digitalised in 2016 as part of the ‘Government Digital Services’. Applying 
for a standard visitor visa can be done online but for identification purposes, collection of biometrics 
and submitting supporting documents, applicants need to book an appointment at the VAC. The visa 
is issued in the form of a sticker. If the applicant had to leave his/her passport behind, it will be returned 
by VAC by post otherwise the applicant will need to take it to the VAC to collect the visa.  

Under the Electronic Visa Waiver (EVW) program, introduced in 2014, passport holders of three visa 
required countries are allowed to visit the UK without a visa for the purpose of tourism, business, study 
or medical treatment. Applying for an EVW is fully digital and quicker than applying for a visa. It is 
issued electronically and needs to be shown upon arrival.  
Visa-exempt nationalities (including EU/EEA-countries and Switzerland) can stay for short visits in 
the UK without a visa. 

United States 
All foreign nationals travelling to the United States for a short stay must obtain a non-immigrant visa. 
Applications  for  a  non-immigrant  visa  can  be  initiated  online  but  after  submitting  the  application 
online,  applicants  are  required  to  schedule  an  appointment  for  an  interview  at  a  US  embassy  or 
consulate. They will need to bring their travel document and have their biometrics enrolled. Visas are 
issued in the form of a sticker and affixed to the travel document which is returned by courier.  

Under the Visa Waiver Program the US has waived the visa requirement for 39 countries, including 
citizens of the EU, EEA and Switzerland. Since 2009 however, nationals from these countries have to 
apply for an ESTA (Electronic System for Travel Authorization) to be pre-screened prior to travel. A 
system equal to ETIAS. 

116 

 
 
 
 
 
 
ANNEX 6 – SENSITIVITY ANALYSIS ON THE PREFERRED OPTION 

Sensitivity analysis can be referred to as “what if” analysis and looks at how changes in a variable can 
change the result of the impact assessment. The impact analysis becomes more uncertain with time – 
meaning that what is estimated today as the expected costs may be influenced by a number of future 
external factors such as the political or legal context, the evolution of largescale information systems, 
changes in the visa process or by technological advancement. 

The sensitivity analysis for the preferred option (Option 4) has been approached with the following 
questions: 

 
 
 
 

What if the expected number of visa applications changes? 
What if the implementation of the digital visa platform is delayed? 
What if the benefits of digitalisation are achieved gradually (i.e. not to their full extent in 2025)? 
What if the average time to process a visa application is higher or lower? 

These questions are very much inter-related. In the analysis on the potential impact time may have on 
the costs and benefits associated with the platform, the main variable impacted is the number of visa 
applications. As it is assumed that between 2025-2029 the number of visa applications is on average 
17.8  million  per  year,  over  time  this  might  increase  or  decrease  depending  on  unforeseen  factors. 
Therefore, the potential impact of average positive and negative application growth rates per Member 
State in the period 2025-2029 is assessed.  

As  applying  the  average  positive  and  negative  growth  rates  per  country  results  overall  in  a  lower 
number of applications for the reference period – approximately 95 million instead of 100 million - 
the analysis assuming that the number of applications increases overall by 5% for the given period 
have been also conduced. This analysis is presented in Sections 1 and Section 2. 

Section 3 presents a sensitivity analysis assuming that the roll-out of the EU platform is delayed.  

Section 4 present a sensitivity analysis on the average time spent by consulate staff to process a paper 
visa application, which affects the overall cost savings by Member States.  

Finally, Section 5 starts from the assumption that the EU platform will not deliver its benefit for 
Member States and third country nationals right at the start, and that the amount of benefits 
will gradually increase over the 2025-2029 period.  

1.  Decrease in number of visa applications  

In the current baseline scenario, it is estimated that the number of visa applications per year stabilises 
at 17.8 million per year.  

Impact on EU tourism and GDP 

Changing the number of visa applications from a stable 17.8 million per year to 16.9 over the 2025-
2029  period,  the  net  benefits  in  EU  tourism  and travel  would  decrease  approximately  by  EUR  0.5 
billion the amount of extra GDP generated by digitalisation.  

117 

 
 
Table 24: Example impact of a decrease in visa applications on EU tourism and GDP  

Main assumption (17.8 million 
applications per year) 
EUR 411.4 billion 

Sensitivity (16.9 million 
applications per year) 
EUR 401.1 billion 

EUR 19.1 billion 

EUR 18.6 billion 

Baseline contribution 
2025-2029 
Extra GDP  

Impact on technical costs 

The number of visa applications directly affects the technical costs of the platform. It is important to 
note  that  the  digital  application  platform,  as  estimated  in  this  study,  is  scaled  to  hold  100  million 
applications.  This  is  based  on  a  ‘safety  net’  on  top  of  the  assumption  that  the  number  of  yearly 
applications will stabilise at 17.8 million per year and the retention period of these application files is 
five years. 

A deviation in the number of applications does not affect all technical cost categories. For example, 
the system retains the same features but the infrastructure on which it is hosted would change. If a 
lower number of visa applications need to be considered, the load on the system will decrease and the 
storage provisions need to be re-evaluated. 

Therefore, a decrease in the number of applications leads to a reduction in the infrastructure costs at 
national  and  central  level.  All  other  costs  of  the  digital  application  platform  remain  the  same.  As 
described  in  previous  analysis,  the  infrastructure  costs  are  linear  to  the  number  of  applications  the 
application  platform  needs  to  cover.  For  example,  if  the  number  of  applications  drop  by  1%  (1 
million158), the infrastructure costs would be 1% lower. 

Please note that this decrease in applications needs to be considered across a period of five years. For 
example, if in one year in a five year period there are 1 million applications less than the assumed 17.8 
million yearly, it has the same effect as five consecutive years with around 200 000 applications less. 

The table below illustrates these impacts in the situation where there is a reduction in visa applications 
compared to the hypothetical 20 million yearly applications taken into account for scaling the IT costs, 
e.g. 19 million applications per year. Please note that this only covers the infrastructure costs, all other 
cost categories remain unaffected. 

Table 25: Example impact of a decrease in visa applications on technical costs  

 Infrastructure & 
Hardware costs 

One-off costs 

Central 

Main assumption for IT costs 
(20 million applications per year) 

Sensitivity  
(19 million per year) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

11.3 million 

13.8 million 

10.7 million 

13.1 million 

158 A 1% reduction in applications corresponds to 1 million applications as the platform is provisioned to hold 100 million applications. 

118 

 
 
 
 
  
                                                           
 Infrastructure & 
Hardware costs 

National (total) 
National (per 
Member State) 
Recurring costs 

Central 

National (total) 
National (per 
Member State) 

Main assumption for IT costs 
(20 million applications per year) 

Sensitivity  
(19 million per year) 

Lower bound 
(EUR) 
61.6 million 

Upper bound 
(EUR) 
75.3 million 

Lower bound 
(EUR) 
58.5 million 

Upper bound 
(EUR) 
71.5 million 

2.5 million 

3.0 million 

2.4 million 

2.9 million 

1.7 million 

2.1 million 

1.6 million 

2.0 million 

9.2 million 

11.3 million 

8.7 million 

10.7 million 

380 000 

450 000 

360 000 

430 000 

Impact on administrative costs for Member States 

The table below shows the extent of administrative costs and benefits for Member States if the total 
number of applications decreased from the baseline scenario (17.8 million applications per year) to 
16.9 million applications per year. 

Table 26: Impact on administrative costs of a stable number of visa applications (16.9 million)  

Main assumption (17.8 million 
applications per year) 

Sensitivity (16.9 million 
applications per year) 

Processing visa applications 

398 FTEs / EUR 17.5 million 

379 FTEs / EUR 16.7 million 

867 FTEs saved / EUR 38.2 million 
saved 

825 FTEs saved / EUR 36.3 
million saved 

Capturing biometrics 

438 FTEs / EUR 19.3 million 

417 FTEs / EUR 18.3 million 

20 extra FTEs needed / EUR 0.9 
million 

19 extra FTEs needed / EUR 
0.85 million 

Replying to queries 

635 FTEs / EUR 27.9 million 

604 FTEs / EUR 26.6 million 

576 FTEs saved / EUR 25.3 million 
saved 

548 FTEs saved / EUR 24.1 
million saved 

Cost of processing visa 
applications under O4 
Benefit of processing 
visa applications 
compared to baseline 

Cost of capturing 
biometrics under O4 
Extra resources for 
capturing biometrics 
compared to baseline 

Cost of replying to 
queries under O4 
Benefit of replying to 
queries compared to 
baseline 

Archiving visa applications 

119 

 
 
  
 
 
Cost of archiving visa 
applications staff under 
O4 
Benefit of archiving 
visa applications staff 
compared to baseline 
Cost of resources for 
archiving visa 
applications under O4 
Benefit related to 
resources for archiving 
visa applications 
compared to baseline 

Cost of managing visa 
stickers staff under O4  
Benefit of managing 
visa stickers staff 
compared to baseline 
Cost of managing visa 
stickers resources under 
O4  
Benefit of managing 
visa stickers resources 
compared to baseline 

Total average cost 
admin burden under O4 
Total average benefit 
admin burden 
compared to baseline 

138 FTEs / EUR 6.1 million 

131 FTEs / EUR 5.8 million 

4 248 FTEs saved / EUR 186.9 
million 

4 043 FTEs saved / EUR 177.9 
million saved 

EUR 0.13 million 

EUR 0.12 million 

EUR 4.5 million saved 

EUR 4.48 million saved 

Visa stickers 

EUR 0 

EUR 0 

4 014 FTEs saved / EUR 176.6 
million saved 

3 829 FTEs saved / EUR 168.4 
million saved 

EUR 0 

EUR 0 

EUR 80.3 million saved  

EUR 76.6 million saved 

Totals 

1 609 FTEs / EUR 70.9 million 

1 531 FTEs / EUR 67.5 million 

9 685 FTEs saved / EUR 510.9 
million saved 

9 226 FTEs saved / EUR 487 
million saved 

Impact on third country nationals 

The table below shows the extent of costs and benefits for third country nationals if the total number 
of applications decreased from the baseline scenario (17.8 million applications per year) to 16.9 million 
applications per year. 

Table 27: Impact of a stable number of visa applications on costs and benefits for third country 
nationals  

Main assumption (17.8 million 
applications per year) 
EUR 4 billion 

Sensitivity (16.9 million 
applications per year) 
EUR 3.8 billion 

Total cost for TCNs 
under O4 

120 

 
 
 
 
Total benefit for TCNs 
compared to baseline  

Main assumption (17.8 million 
applications per year) 
EUR 2.9 billion 

Sensitivity (16.9 million 
applications per year) 
EUR 2.7 billion 

2. 

Increase in number of visa applications 

Impact on EU tourism and GDP 

Changing  the  number  of  visa  applications  from  a  stable  20  million  per  year  to  a  growth  of  5%  in 
applications  –  105  million  -  the  net  benefits  in  EU  tourism  and  travel  would  generate  a  positive 
difference of approx. EUR 3 billion.  

Table 28: Example impact of an increase in visa applications on EU tourism and GDP  

Main assumption (17.8 million 
applications per year) 
EUR 411.4 

Sensitivity (20 million 
applications per year) 
EUR 481.6 billion 

EUR 19.1 

EUR 53.5 billion 

Total GDP contribution 
2025-2029 
Extra GDP contribution 

Impact on technical costs 

Similar to a decrease in the number of visa applications, an increase of visa applications would also 
lead to an increase in the infrastructure needed. The reasoning is similar to the one described in the 
previous analysis. Also here we consider the hypothetical 20 million applications used to scale the IT 
costs. For example, if the number of applications increase by 1% (1 million)159, the infrastructure costs 
would be 1% higher. 

Please  note  that  the  20  million  applications  is  different  from  the  number  of  applications  used  to 
estimates other than technical. This is because the VIS will be scaled to 100 million applications160 so 
technically it makes sense to scale the application platform in line with the VIS. This can be considered 
a technical ‘safety net’ for future growth. 

Table 29: Example impact of an increase in visa applications on technical costs  

 Infrastructure & 
Hardware costs 

One-off costs 

Central 

Main assumption including 
‘safety net’ 
(20 million applications per year) 

Sensitivity  
(21 million per year) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

11.3 million 

13.8 million 

11.9 million 

14.5 million 

National (total) 

61.6 million 

75.3 million 

64.7 million 

79.1 million 

159 A 1% reduction in applications corresponds to 1 million applications as the platform is provisioned to hold 100 million applications. 
160 20 million per year with a 5 year retention period. 

121 

 
 
 
 
  
                                                           
 Infrastructure & 
Hardware costs 

National (per 
Member State) 
Recurring costs 

Central 

National (total) 
National (per 
Member State) 

Main assumption including 
‘safety net’ 
(20 million applications per year) 

Sensitivity  
(21 million per year) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

Lower bound 
(EUR) 

Upper bound 
(EUR) 

2.5 million 

3.0 million 

2.6 million 

3.1 million 

1.7 million 

2.1 million 

1.8 million 

2.2 million 

9.2 million 

11.3 million 

9.7 million 

11.9 million 

380 000 

450 000 

400 000 

470 000 

3.  Delay in the roll-out of the application platform 

The third and final sensitivity analysis topic is the possibility that the application platform is delayed. 
Unlike the other two topics, this topic is described in a qualitative way. 

This is necessary as the delay of the platform impacts neither the costs nor the benefits. The costs and 
benefits described in this impact assessment start when the application platform goes live. Therefore, 
delaying the roll-out simply means shifting these costs and benefits as well. 

There are two caveats that must be considered when interpreting the above statement: 

  First, the technology costs are based on the currently existing technologies and market trends. 
While these would probably still be representative a few additional years down the line, the 
longer the roll-out is delayed, the less accurate these estimations will become. 

  Secondly,  if  the  roll-out  is  delayed  substantially,  there  could  be  other  central  initiatives 
developed  in  the  meantime  that  could  be  leveraged.  These  synergies  would  drive  the  costs 
down. 

  The  sensitivity  analysis  concludes  that  the  costs  and  benefits  presented  in  this  report  will 

therefore remain, to some extent, relevant if the roll-out is delayed.  

There is however one potential impact, related not to the costs and benefits, but to the identification of 
the preferred option itself. If the roll-out of the application platform is delayed considerably, Member 
States would likely continue to invest in (or create new) national application portals. The more Member 
States invest in their own national solutions, the less likely it is they will then pivot to the EU digital 
application platform. Therefore, the risk exists that if the roll-out of the platform is delayed multiple 
years, the adoption of a mandatory EU digital application platform will be hindered significantly from 
a political or governance point of view.  

4.  Change in time needed to intake a visa application 

Administrative costs and benefits for Member States are calculated based on the average time spent to 
carry out the various tasks when processing visa applications. The assumption was used as to the time 

122 

 
 
  
 
needed to process applications are averages based on data provided by Member States. As the actual 
time  spent  may  vary  across  consulates  and  Member  States,  it  is  useful  to  estimate  how  the 
administrative costs and benefits would change if the average time spent decreased or increased. 

The sensitivity analysis has been applied only to the “time to process visa application”, which includes 
intake of the application at the counter, encoding it and collecting the visa fee. The average time per 
application assumed in this study for this sub-task is 15 minutes. The reason to apply the sensitivity 
only to this sub-task of the process is the significant variability between the time data provided by the 
Member States in that regard: with the sensitivity analysis the study can cater  for a wider range of 
cases, i.e. cases whereby intaking one application takes more or less time. 

Increase in time needed to intake a visa application 

In this section the impact on administrative costs and benefits of increasing the average time for intake 
of an application from 15 to 18 minutes is shown. 

The table below shows the impact on the costs in the baseline scenario and under the preferred option, 
always applying (a) the assumption that consulates only process 10% of all visa applications; and (b) 
the assumption that at least 3% of third country nationals will continue to use the paper application 
process. The table shows that if the average time to intake one visa application was 18 minutes, under 
the baseline scenario Member States would need around 285 more FTEs to process the same amount 
of applications (corresponding to approximately EUR 12.5 million more). Under the preferred option 
the number of FTEs needed would increase by 10, but Member States would also save an additional 
share  of  FTEs  (i.e.  around  275)  that  they  would  have  allocated  to  cope  with  the  higher  amount  of 
applications expected between 2025 and 2029 compared to the baseline.  

The same reasoning would apply to the monetary costs of FTEs: under the preferred option, Member 
States would see the total monetary cost of FTEs increase by EUR 0.4 million, but compared to the 
baseline the amount of FTEs saved would correspond approximately to EUR 12 million. 

Table 30: Example impact of a decrease in the processing time for visa applications on administrative 
costs for Member States (baseline)  

Main assumption (15 
minutes per application) 

Sensitivity (18 minutes per 
application) 

Baseline 

1 265 

1 518 

FTEs spent on intaking & 
encoding all visa applications, 
and collecting visa fee 

Cost for all visa applications 

EUR 55.7 million 

EUR 66.8 million 

Preferred option 

123 

 
 
 
FTEs spent on intaking & 
encoding all visa applications, 
and collecting visa fee 

FTEs saved under the 
preferred option 

398 

867 

438 

1 041 

Cost for all visa applications  

17.5 million 

EUR 21 million 

Costs saved under the 
preferred option 

38.1 million 

45.8 million 

Decrease in time needed to intake a visa application 

In  this  section  the  impact  on  administrative  costs  and  benefits  of  decreasing  the  average  time  for 
intaking an application from 15 to 12 minutes is shown. 

The table below shows the impact on the costs in the baseline scenario: if the average time to intake 
one  visa  application  was  12  minutes,  Member  States  would  need  approximately  286  less  FTEs  to 
process  the  same  amount  of  applications  (corresponding  to  approximately  EUR  12.5  million  less). 
Under the preferred option the number of FTEs needed would decrease by 10, and their corresponding 
costs would decrease by EUR 0.4 million. 

Table 31: Example impact of a decrease in the processing time for visa applications on administrative 
costs for Member States  

Main assumption (15 minutes 
per application) 

Sensitivity (12 minutes per 
application) 

Baseline 

1 265 

1 012 

FTEs spent on taking in & 
encoding all visa applications, 
and collecting visa fee 

Cost for all visa applications 

EUR 55.7 million 

EUR 44.5 million 

FTEs spent on taking in & 
encoding all visa applications, 
and collecting visa fee 

FTEs saved under the preferred 
option 

Preferred option 

398 

867 

318 

694 

Cost for all visa applications  

17.5 million 

14 million 

124 

 
 
 
Costs saved under the 
preferred option 

38.1 million 

30.5 million 

5.  Gradual realisation of administrative benefits over the 2025-2029 period 

In the main scenario it was assumed that from the start of the implementation of the platform, only 3% 
of  applications  would  still  be  submitted  to  the  consulate  on  paper.  However,  if  the  benefits  of  the 
digitalisation take longer to be realised by Member States, due to e.g. time for adoption of processes 
and adjusting to  new ways of working, there  would  be a reduced benefit overall during the 5  year 
period. 

Below  the  impact  of  a  gradual  implementation  of  the  digital  way  of  working  i.e.  with  8%  of 
applications  still  being  assessed  in  paper  in  the  first  year  and  5%  in  the  second  year  have  been 
calculated. From the third year it is assumed that the proportion would stabilise at 3%.  

Table 32: Sensitivity analysis on the administrative impact of gradual adoption of the digital way of 
working  

Costs saved 

Processing visa applications 
FTEs 
Costs in EUR 
Capturing biometrics 
FTEs 
Costs in EUR 
Replying to queries 
FTEs 
Costs in EUR 
Archiving visa applications 
FTEs 
Costs of staff in EUR 
Costs of resources in EUR 
Managing visa stickers 
FTEs 
Costs of staff in EUR 
Costs of resources in EUR 
TOTALS 
Total FTEs saved (all MSs) 
Total costs saved in EUR (all MSs) 

161 17.8 million applications per year. 

Main scenario (3% of 
applications submitted on 
paper)161 

Gradual adoption 
scenario (8%, 5%, 3%) 

685 
30 157 407 

-20 
-896 556 

576 
25 331 556 

4 185 
184 136 897 
4 412 246 

4 014 
176 635 361 
80 322 606 

9 440 
500 099 518 

867 
38 152 138 

-20 
-896 556 

576 
25 331 556 

4 248 
186 908 404 
4 471 088 

4 014 
176 635 361 
80 322 606 

9 685 
510 924 598 

125 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
                                                           
Total FTEs saved (average per MS) 
Total costs saved in EUR (average 
per MS) 

372 

19 650 946 

363 

19 234 597 

As shown above, the expected time saved due to the use of the EU digital platform would be reduced 
by  about  23%.  Although  the  benefit  is  reduced,  the  result  of  the  sensitivity  is  not  significant.  For 
Member States overall, even with a period of time required to adapt to the digital process, the expected 
benefits may decrease by only about 2-3%. 

126 

 
 
 
 
 
 
ANNEX 7 – COMPARISON OF THE POLICY OPTIONS 

This annex presents the main findings from the assessment of the impacts of each policy option. 
Due to rounding, some totals may not correspond with the sum of the separate figures. 

Option 2: Minimal EU legislative changes on the application & digital visa 

Table 33: Assessment of Option 2  

Criteria 

Assessment Option 2 

Rating 

Summary 

Effectiveness 

1.1 

Objectives 

Rating 

To  streamline  and  make  more  efficient  the  visa  application 
procedure for applicants and MS through digital means 

1,25 

Under Option 2 the EU would issue EU-wide mandatory standards for  Member 
States  operating  an  online  application  portal.  This  would  ensure  widespread 
adoption, considering that by 2029 the majority of Member States are expected to 
be  operating  a  portal.  Moreover,  the  digital  visa  would  mark  a  transition  to  a 
seamless, digital proof of visa in line with ETIAS. Therefore, under Option 2 there 
would be a higher contribution to the digitalisation of public services, although the 
level of digitalisation would still depend on the nature of the functionalities offered 
by the Member States.  

The EU-wide mandatory standards would contribute to a certain extent to simplify 
the  application  process.  Moreover,  the  removal  of  the  obligation  to  sign  the 
application  would allow repeat applicants to apply online.  However, the overall 
effect would still be limited because the visa process would continue to be based 
on national administrative practices and systems. 

To  increase  the  security  of  the  Schengen  area  through  the 
digitalisation  of  the  visa  sticker  and  digitalised  application 
procedures 

1.75 

Thanks  to  the  digital  visa,  Option  2  would  contribute  to  a  certain  extent  to  the 
security  of  the  Schengen  Area,  by  streamlining  border  checks  in  line  with 
interoperability  and  by  removing  the  visa  sticker,  which  is  prone  to  forgery. 
However,  visa  shopping  would  still  be  a  problem,  albeit  to  a  lesser  extent  than 
under Options 0 and 1. 

Impact on the environment 

0.25 

O2  would  enable  saving  38%  of  the  CO2  emitted  by  third  country  nationals 
travelling to consulates/VACs, 50% of the paper needed for visa applications, and 
all paper used for visa stickers.  

Efficiency 

1.5 

GDP contribution of travel 

No impact 

Cost  for  EU  institutions  and 
bodies 

One-off  IT  costs:  EUR  3.5  million  –  EUR  6.4 
million 

127 

 
 
 
Criteria 

Assessment Option 2 

Rating 

Summary 

Yearly  IT  costs162:  EUR  3.5  million  –  EUR  6 
million 

Costs  savings 
States (2025-2029) 

for  Member 

Time  needed  to  process  visa  applications  (all 
Member States): No impact  

Cost  to  process  visa  applications  (all  Member 
States): No impact 

Time  needed  to  reply  to  queries  (all  Member 
States): No impact 

Cost  needed  to  reply  to  queries  (all  Member 
States): No impact 

Time  needed  to  file  paper  applications  in  the 
archive (all Member States): No impact 

Cost  needed  to  file  paper  applications  in  the 
archive (all Member States): No impact 

Time  needed  to  capture  biometrics  (all  Member 
States): No impact 

Cost  needed  to  capture  biometrics  (all  Member 
States): No impact 

Cost for archiving visa applications and supporting 
documents  for  2  years  (all  Member  States):  No 
impact 

Cost saved on procuring, transporting and storing 
visa stickers: EUR 80.3 million 

Time saved on printing the visa sticker and affixing 
it  to  the  passport/travel  document  (all  Member 
States): 4 014 FTEs 

Cost saved on staff for visa stickers (all Member 
States): EUR 176.6 million 

Cost  savings  for  third  country 
nationals (2025-2029) 

Cost  savings  associated  with  the  application 
process and pick-up (per applicant): EUR 31 

Total cost savings associated with the application 
process  and  pick-up  (all  applicants):  EUR  2.7 
billion 

Environmental  impacts  (2025-
2029) 

Total  decrease  in  CO2  emission  (application  and 
pick-up): 1.5 million kg 

Paper  saved  in  regard  to  the  digitalisation  of  the 
application process: 2.6 million kg in paper 

Total CO2 emission related to travel to the EU: No 
impact 

162 After entry-in-operation of the digital application platform. 

128 

 
 
 
                                                           
Criteria 

Assessment Option 2 

Rating 

Summary 

Protection of 
personal data 

0.5 

0 

Coherence with 
EU Charter of 
Fundamental 
Rights 

Under Option 2 mandatory standards may enhance monitoring of compliance and 
legal certainty, positively contributing to data subjects' trust in the data processing. 
Exposure of personal data to ESPs would be reduced. The web service would entail 
data  security  implications  that  need  to  be  mitigated  via  a  “privacy  enhancing” 
implementation. 

Option 2 would still guarantee a high level of compliance with the EU Charter of 
Fundamental  Rights.  People  with  low  IT  literacy  and  people  with  disabilities 
applying from distance may need technical assistance to use online portals, but the 
assistance provided by family members & friends, service providers and consulates 
would be sufficient to guarantee protection and inclusion. Repeat applicants with 
reduced mobility would be able to apply with no need to visit a consulate/VAC. 
There would be a risk for the rights of the child as minors repeat applicants would 
normally  not  be  checked  by  consulate  or  ESP  staff  to  detect  instances  of  child 
abduction and trafficking in human beings. 

Overall conclusion  Option 2 would achieve the policy objectives to a wider extent, although it would not simplify 
and harmonise the visa process to the required extent. In terms of efficiency, Option 2 would 
enable some cost savings and efficiency gains for Member States and third country nationals.  

Option 3: Optional EU digital application platform & digital visa 

Table 34: Assessment of Option 3  

Criteria 

Assessment Option 3 

Rating 

Summary 

Effectiveness 

1.6 

Objectives 

To streamline and make more efficient the visa application 
procedure for applicants and MS through digital means 

Rating 

2 

With the introduction of the EU digital application platform, Option 3 would mark 
a clear transition towards an effective digitalisation of public services, contributing 
to making the EU fit for the digital age. However, the impact of Option 3 is still 
suboptimal because the optional nature of the EU application platform is expected 
to generate uncertainty amongst third country nationals on the tool to use to apply 
and  whether the Member States still operating a  national system are part of the 
Schengen  Area.  Hence,  Option  3  would  contribute  only  to  a  limited  extent  to 
making the Schengen Area more attractive to travellers.  

For the Member States joining the  EU platform Option 3  would contribute to a 
large extent to simplifying and harmonising the visa process, by enabling seamless 
application  procedures  for  repeat  applicants.  However,  third  country  nationals 
applying for Member States operating a national system may not enjoy the same 
benefits  and  the  extent  to  which  the  fragmentation  of  the  application  tools  and 
procedure would be addressed by this option is very hypothetical  

To increase the security of the Schengen area through the 
digitalisation of the visa sticker and digitalised application 
procedures 

2 

129 

 
 
Criteria 

Assessment Option 3 

Rating 

Summary 

The Member States operating the EU platform are expected to save FTEs that can 
be re-allocated to strengthen the risk assessment process, thereby contributing to 
the EU security. However, visa shopping would still be possible as some Member 
States would offer a more expeditious process than others. The impact of the digital 
visa would be the same as under Option 2. Therefore, Option 3 would contribute 
to a significant extent to EU security. 

Impact on the environment 

0.75 

Under 03, 38 % of the CO2 emissions emitted by third country national travelling 
to consulates or VACs would be saved. Due to the introduction of the platform and 
the digitalisation resulting from it, additional paper would be saved in comparison 
with O2. The potential/hypothetical increase of travellers linked to simplification 
of the application process through digitalisation would be limited with also limited 
extra emissions of CO2. 

Efficiency 

1.6 

GDP  contribution  of 
(2025-2029) 

travel 

EUR 8.7 billion 

Cost  for  EU  institutions  and 
bodies (2025-2029) 

for  Member  States 

Costs 
(2025-2029) 

One-off IT costs: EUR 25.7 million – EUR 31.3 
million163 
Recurring IT costs: EUR 44.5 million – EUR 54.4 
million164 
One-off training costs: EUR 20 000 – EUR 33 000 

Development support staff: EUR 2.5 million 

One-off  IT  costs  (average  per  Member  State): 
EUR 2.0 million – EUR 2.3 million165 
One-off  IT  costs  (all  Member  States):  EUR  30.9 
million – 37.7 million 

Recurring  IT  costs  (average  per  Member  State): 
EUR 1.7 million – EUR 2.1 million 

Recurring IT costs (all Member States): EUR 27.5 
million – EUR 33.5 million 

One-off training costs (average per Member State): 
EUR 33 000 

One-off training costs (all Member States):  EUR 
528 000 

Extra  time  needed  to  capture  biometrics  (all 
Member States): 4 FTEs 

Extra  cost  needed  to  capture  biometrics  (all 
Member States): EUR 0.4 million 

Cost savings for Member 
States (2025-2029) 

Time  saved  on  processing  visa  applications  (all 
Member States): 448 FTEs  

163 Taking into account the costs associated with the EU platform. 
164 Idem, after entry-in-operation of the digital application platform. 
165 Taking into account the number of Member States expected to join the EU platform under Option 3. 

130 

 
 
 
                                                           
Criteria 

Assessment Option 3 

Rating 

Summary 

Cost  saved  on  processing  visa  applications  (all 
Member States): EUR 19.7 million 

Time  saved  on  replying  to  queries  (all  Member 
States): 236 FTEs  

Cost  saved  on  replying  to  queries  (all  Member 
States): EUR 10.4 million 

Time  saved  on  filing  paper  applications  in  the 
archive (all Member States): 1 724 FTEs 

Cost  saved  on  filing  paper  applications  in  the 
archive (all Member States): EUR 75.8 million 

Cost  saved  on  archiving  visa  applications  and 
supporting  documents  for  2  years  (all  Member 
States): EUR 1.8 million 

Cost saved on procuring, transporting and storing 
visa stickers: EUR 80.3 million 

Yearly cost savings on resources for visa stickers 
(average per Member State): EUR 3.1 million 

Time saved on printing the visa sticker and affixing 
it  to  the  passport/travel  document  (all  Member 
States): 4 014 FTEs 

Time saved on printing the visa sticker and affixing 
it  to  the  passport/travel  document  (average  per 
Member State): 154 FTEs 

Cost saved on staff for visa stickers (all Member 
States): EUR 176.6 million 

Cost saved on staff for visa stickers (average per 
Member State): EUR 6.8 million 

Cost  savings  for  third  country 
nationals (2025-2029) 

Cost  savings  associated  with  the  application 
process and pick-up (per applicant): EUR 31 

Environmental  impacts  (2025-
2029) 

Total cost savings associated with the application 
process  and  pick-up  (per  applicant):  EUR  2.7 
billion166 

Total  decrease  in  CO2  emission  related  to  travel 
during  the  application  process  and  pick-up:  1.5 
billion kg  

Paper  saved  in  regard  to  the  digitalisation  of  the 
application process: 3.1 million kg  

Extra CO2 emission related to travel to the EU: 0.8 
billion kg 

166 Taking into account the expected increase in the total number of visa applicants under Option 3. 

131 

 
 
                                                           
Criteria 

Assessment Option 3 

Rating 

Summary 

Protection of 
personal data 

0.75 

0 

Coherence with 
EU Charter of 
Fundamental 
Rights 

Under  Option  3  the  EU  platform  would  introduce  uniform  data  processing 
practices that would however apply only to a subset of Member States. While less 
third  country  nationals  will  rely  on  ESPs,  the  new  processing  to  enhance 
identification of visa applicants for consulates would expose additional personal 
data  to  ESPs. The  EU  platform  would  entail  data  security  implications  for  data 
stored online to be mitigated via a “privacy enhancing” implementation.  

Option 3 would be compliant with the EU Charter of Fundamental Rights. A higher 
share  of  elderly  people  and  people  with  low  IT  literacy  is  expected  to  need 
technical  assistance  compared  to  Option  2;  however,  the  necessary  assistance 
would continue to be provided. Repeat applicants with reduced mobility would be 
able to apply with no need to visit a consulate/VAC. There would be a risk for the 
rights of the child as minors repeat applicants would normally not be checked by 
consulate  or  ESP  staff  to  detect  instances  of  child  abduction  and  trafficking  in 
human beings. 

Overall conclusion  Option 3 would perform better than  Option 2 in all departments. It  would go an extra step in 
simplifying  and  harmonising  the  visa  process,  although  the  optional  EU  platform  is  a  key 
limitation  and  drawback  in  terms  of  attractiveness  and  simplification  of  procedures  for  third 
country nationals. In terms of efficiency, Option 3 would require substantial one-off and yearly 
investments from the EU and the participating Member States, but would produce higher long-
term cost savings and efficiency gains for Member States and third country nationals compared 
to Option 2. 

Option 4: Mandatory EU digital application platform & digital visa 

Table 35: Assessment of Option 4  

Criteria 

Assessment Option 4 

Rating 

Summary 

Effectiveness 

1.9 

Objectives 

Rating 

To  streamline  and  make  more  efficient  the  visa  application 
procedure for applicants and MS through digital means. 

2.6 

As it would be mandatory for all Member States, the EU platform under Option 4 
would bring the same high level of simplification and harmonisation of the visa 
process for all third country nationals. Repeat applicants would be able to apply in 
a seamless way from home, and all Member States would reap the benefits of a 
digital landscape enabling a level playing field. 

The EU digital application platform under Option 4 would make the common visa 
process truly digital in all Member States, thereby contributing to a large extent to 
EU-wide digitalisation of public services. This would also increase the coherence 
of  the  EU  image  vis-à-vis  third  countries  in  line  with  worldwide  digital  trends, 
thereby making the Schengen Area more attractive to foreign travellers. 

To  increase  the  security  of  the  Schengen  area  through  the 
digitalisation  of  the  visa  sticker  and  digitalised  application 
procedures 

2.5 

132 

 
 
Criteria 

Assessment Option 4 

Rating 

Summary 

Under Option 4 all Member States could strengthen their risk assessments by re-
allocating  resources  saved.  Moreover,  as  the  application  process  would  be 
harmonised to a large extent, visa shopping would be significantly reduced. The 
digital visa would contribute to the security of border checks as under Options 2 
and 3. In addition, all documents submitted would be subject to the same quality 
standards. Therefore, Option 4 would contribute to a large extent to EU security. 

Impact on the environment 

0.5 

Almost  the  same  benefits  than  under  O3  would  materialise  under  O4  (paper 
savings and decrease of travels required for applications of third country nationals). 
The  additional  emissions  involved  by  a  possible  higher  number  of  travellers 
triggered by a single and simplified digital application would be higher than under 
O3,  thus  triggering  a  lower  score  than  O3.  The  score  remains  positive,  as  the 
benefits are certain (reduction of paper and decrease of applicant travels) whereas 
the  environmental  costs  remain  hypothetical  as  based  on  a  potential  increase  of 
travellers. 

Efficiency 

2.25 

GDP  contribution  of 
(2025-2029) 

travel 

EUR 19.1 billion 

Cost  for  EU  institutions  and 
bodies (2025-2029) 

One-off IT costs: EUR 33.8 million – EUR 41.2 
million167 
Recurring IT costs: EUR 52.5 million – EUR 63.9 
million 

One-off training costs: EUR 20 000 – EUR 33 000 

Development support staff: EUR 2.5 million 

Cost for Member States (2025-
2029) 

One-off  IT  costs  (average  per  Member  State): 
EUR 2.8 million – EUR 3.3 million 

One-off  IT  costs  (all  Member  States):  EUR  68.3 
million – EUR 83.5 million 

Recurring  IT  costs  (average  per  Member  State): 
EUR 2.3 million – EUR 2.9 million 

Recurring IT costs (all Member States):  EUR 58 
million – EUR 70.5 million 

One-off training costs (average per Member State): 
EUR 33 000 

One-off training costs (all Member States):  EUR 
858 000 

for  Member  States 

Costs 
(2025-2029) 

Extra  time  needed  to  capture  biometrics  (all 
Member States): 20 FTEs 

Extra  cost  needed  to  capture  biometrics  (all 
Member States): EUR 0.9 million 

167 Includes EU digital application platform and VIS adaptations. 

133 

 
 
                                                           
Criteria 

Assessment Option 4 

Rating 

Summary 

Cost savings for Member States 
(2025-2029) 

Time  saved  on  processing  visa  applications  (all 
Member States): 867 FTEs  

Cost  saved  on  processing  visa  applications  (all 
Member States): EUR 38.2 million 

Time  saved  on  replying  to  queries  (all  Member 
States): 576 FTEs  

Cost  saved  on  replying  to  queries  (all  Member 
States): EUR 25.3 million 

Time  saved  on  filing  paper  applications  in  the 
archive (all Member States): 4 248 FTE 

Cost  saved  on  filing  paper  applications  in  the 
archive (all Member States): 186.9 million 

Cost  saved  on  archiving  visa  applications  and 
supporting  documents  for  2  years  (all  Member 
States): EUR 4.5 million 

Cost saved on procuring, transporting and storing 
visa stickers: EUR 80.3 million 

Time saved on printing the visa sticker and affixing 
it  to  the  passport/travel  document  (all  Member 
States): 4 014 FTEs 

Cost saved on staff for visa stickers (all Member 
States): EUR 176.6 million 

Cost  savings  for  third  country 
nationals (2025-2029) 

Cost  savings  associated  with  the  application 
process and pick-up (per applicant): EUR 31 

Total cost savings associated with the application 
process (all applicants): EUR 2.9 billion168 

Environmental  impacts  (2025-
2029) 

Total  decrease  in  CO2  emission  related  to  travel 
during  the  application  process  and  pick-up:  1.4 
billion kg169 

Paper  saved  in  regard  to  the  digitalisation  of  the 
application process: 3 million kg in paper170 

168 Taking into account the expected increase in the total number of visa applicants under Option 4. 
169 The amount of CO2 emissions saved under Option 4 (net benefit) is lower than the amount saved under Option 3 (see table above) due to the fact that 
for all options this net benefit is calculated in function of the baseline CO2 emissions. As Option 4 leads to slightly higher emissions because of the higher 
number of TCNs applying compared to Option 3, the resulting net benefit is lower for Option 4, given the same baseline. 
170 Idem. 

134 

 
 
 
                                                           
Criteria 

Assessment Option 4 

Rating 

Summary 

1 

0 

Protection of 
personal data 

Coherence with 
EU Charter of 
Fundamental 
Rights 

Extra CO2 emission related to travel to the EU: 2.9 
billion kg 

Under  Option  4  the  EU  platform  would  introduce  uniform  data  processing 
practices  that  would  apply  to  all  Member  States  that  could  produce  substantial 
benefits in terms of training and harmonisation of the implementation of the data 
protection legal framework. While less third country nationals will rely on ESPs, 
the  new  processing  to  enhance  identification  of  visa  applicants  for  consulates 
would slightly expose additional personal data to ESPs. The EU platform would 
entail  data  security  implications  for  data  stored  online  to  be  mitigated  via  a 
“privacy enhancing” implementation. 

Option 4 would be compliant with the EU Charter of Fundamental Rights. A higher 
share  of  elderly  people  and  people  with  low  IT  literacy  is  expected  to  need 
technical  assistance  compared  to  Option  3;  however,  the  necessary  assistance 
would continue to be provided. Repeat applicants with reduced mobility would be 
able to apply with no need to visit a consulate/VAC. There would be a risk for the 
rights of the child as minors repeat applicants would normally not be checked by 
consulate  or  ESP  staff  to  detect  instances  of  child  abduction  and  trafficking  in 
human beings. 

Overall conclusion  By  extending  the  benefits  of  the  EU  platform  to  the  whole  Schengen  Area,  Option  4  would 
perform better than Option 3 in terms of effectiveness. In terms of efficiency, Option 4 would 
still require substantial one-off and yearly investments from the EU and from all Member States, 
but would also produce high long-term cost savings and efficiency gains for all Member States.  

Option 5: Online biometric enrolment & digital visa 

Table 36: Assessment of Option 5  

Criteria 

Assessment Option 5 

Rating 

Summary 

Effectiveness 

0.7 

Objectives 

Rating 

To  streamline  and  make  more  efficient  the  visa  application 
procedure for applicants and MS through digital means 

2.8 

By digitalising the whole application process even for first-time applicants, Option 
5 would be the most suitable option to contribute to streamlining and make more 
efficient  the  visa  application  procedure  for  applicants  and  MS  through  digital 
means. While harmonising the process to the same extent as Option 4, Option 5 
would enable a higher degree of simplification, in particular by allowing all third 
country nationals – including first-time applicants – to apply online. Both Member 
States  and  third-country  nationals  would  reap  the  highest  benefits  in  terms  of 
efficiency gains and travel cost savings.  

To  increase  the  security  of  the  Schengen  area  through  the 
digitalisation  of  the  visa  sticker  and  digitalised  application 
procedures 

-0.5 

135 

 
 
 
Criteria 

Assessment Option 5 

Rating 

Summary 

The digital visa would contribute to EU security as under Options 2 to 4. However, 
the security of the visa application process would be diminished by the possibility 
for  third  country  nationals  to  enrol  biometrics  online.  This  would  prevent 
consulates and ESP staff from linking the applicant’s identity data in person and 
would undermine the trust of border authorities in the upstream risk assessment of 
third  country  nationals.  For  this  reason,  Option  5  is  expected  to  have  a  slightly 
negative impact on EU security compared to the baseline. 

Impact on the environment 

0.25 

The same benefits as O4 would materialise under O5 (paper savings and decrease 
of  travels  required  for  applications  of  third  country  nationals).  Nevertheless  the 
potential additional emissions involved by a possible higher number of travellers 
triggered by a totally dematerialised application tool would trigger more emissions 
than under O3 and O4 and therefore O5 gets a lower score than these two options. 
The  score  remains  positive,  as  the  benefits  are  certain  (reduction  of  paper  and 
decrease of applicant travels) whereas the environmental costs remain hypothetical 
as based on a potential increase of travellers. 

Efficiency 

2 

GDP  contribution  of 
(overall 2025-2029) 

travel 

EUR 38.9 billion  

Cost  for  EU  institutions  and 
bodies (overall 2025-2029) 

One-off IT costs: EUR 34.0 million – EUR 41.5 
million 

Recurring IT costs: EUR 52.5 million – EUR 64.4 
million 

One-off training costs: EUR 20 000 – EUR 33 000 

Development support staff: EUR 2.5 million 

for  Member  States 

Cost 
(overall 2025-2029) 

One-off  IT  costs  (average  per  Member  State): 
EUR 2.8 million – EUR 3.3 million 

One-off  IT  costs  (all  Member  States):  EUR  68.3 
million – EUR 83.5 million 

Recurring  IT  costs  (average  per  Member  State): 
EUR 2.3 million – EUR 2.9 million 

Recurring IT costs (all Member States): EUR 58.0 
million – EUR 70.5 million 

One-off training costs (average per Member State): 
EUR 33 000 

One-off training costs (all Member States):  EUR 
858 000 

Cost savings for Member States 
(2025-2029) 

Time  saved  on  processing  visa  applications  (all 
Member States): 848 FTEs  

Cost  saved  on  processing  visa  applications  (all 
Member States): EUR 37.3 million 

136 

 
 
Criteria 

Assessment Option 5 

Rating 

Summary 

Time  saved on capturing biometrics (all Member 
States): 287 FTEs 

Cost  saved  on  capturing  biometrics  (all  Member 
States): EUR 12.3 million 

Time  saved  on  replying  to  queries  (all  Member 
States): 545 FTEs  

Cost  saved  on  replying  to  queries  (all  Member 
States): EUR 24 million 

Time  saved  on  filing  paper  applications  in  the 
archive (all Member States): 4 241 FTEs 

Cost  saved  on  filing  paper  applications  in  the 
archive (all Member States): EUR 186.6 million 

Cost  saved  on  archiving  visa  applications  and 
supporting  documents  for  2  years  (all  Member 
States): EUR 4.5 million 

Cost saved on procuring, transporting and storing 
visa stickers: EUR 80.3 million 

Time saved on printing the visa sticker and affixing 
it  to  the  passport/travel  document  (all  Member 
States): 4 014 FTEs 

Cost saved on staff for visa stickers (all Member 
States): EUR 176.6 million 

Cost  savings  for  third  country 
nationals (2025-2029) 

Cost  savings  associated  with  the  application 
process and pick-up (per applicant): EUR 72 

Environmental  impacts  (2025-
2029) 

Total cost savings associated with the application 
process  and  pick-up  (all  applicants):  EUR  6.9 
billion171 

Total decrease in CO2 emission: 1.9 billion kg 

Paper  saved  in  regard  to  the  digitalisation  of  the 
application process: 2.9 million kg in paper 

Extra CO2 emission related to the uptake in tourism 
to the EU: 6.2 billion kg 

Under  Option  5  the  EU  platform  would  introduce  uniform  data  processing 
practices that would apply to all Member States. While less third country nationals 
will  rely  on  ESPs  compared  to  Option  4,  the  new  processing  to  enhance 
identification of visa applicants for consulates would expose additional personal 
data  to  ESPs. The  EU  platform  would  entail  data  security  implications  for  data 
stored online to be mitigated via a “privacy enhancing” implementation; moreover, 
compared to Option 4, the online biometric enrolment would open up new privacy 
challenges,  such  as  collection  of  (new)  or  additional  sensitive  data  on  mobile 
application,  exposure  of  data  to  other  (third)  parties  (i.e.,  app.  provider-s-),  the 

Protection of 
personal data 

-0.5 

171 Taking into account the increase in the total number of visa applicants under Option 5. 

137 

 
 
                                                           
Criteria 

Assessment Option 5 

Rating 

Summary 

-0.5 

Coherence with 
EU Charter of 
Fundamental 
Rights 

internet and so on. This last element worsens the overall balance for O5 with regard 
to data protection. 

Option  5  would  hardly  guarantee  overall  compliance  with  the  EU  Charter  of 
Fundamental  Rights.  The  need  for  technical  assistance  for  elderly  people  and 
people with low IT literacy is expected to be higher and impinge upon the rights 
of  elderly  people;  on  the  other  hand  first-time  applicants  with  reduced  mobility 
would be able to apply with no need to visit a consulate/VAC. Importantly, Option 
5 would entail a significant risk for the rights of the child, because consulates and 
ESP  staff  would  normally  have  little  to  no  chance  to  perform  on-site  checks  to 
detect child abduction or trafficking of human beings. 

Overall conclusion  Option 5 would make the EU fit for the digital age and simplify/harmonise the visa process more 
than any other option; however, it would fail to contribute to EU security, performing worse than 
Option 1 in this department. In terms of efficiency, Option 5 would require similar investments 
to Option 4 from the EU and the Member States, and would produce the highest cost savings for 
third  country  nationals.  Its  lack  of  transitional  period  and  the  online  biometric  enrolment  are 
however likely to make it a politically unfeasible option. 

138