COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE 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) 659 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE 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) 658 final}  
 
 
Executive Summary Sheet 

Legislative initiative on the digitalisation of visa procedures  (2021 CWP item) 

A. Need for action 

Why? What is the problem being addressed?  
Member States’ authorities dealing with visa applications and visa issuing are burdened by lengthy processes 
and  accumulating costs to manage, process, archive and eventually destroy paper documents under the current 
visa  procedure.  Member  States  are  also  increasingly  dependent  on  external  service  providers.  There  is  also  a 
security risk related to the possibility of forgery and counterfeiting of the visa sticker, as well as increased risk of 
visa shopping due to fragmented visa procedures across Member States. Finally, the  COVID-19 pandemic has 
shown that the current practice is not fit to respond and react to crises.  

The current procedure is also complex and burdensome for visa applicants. Visa applicants have to travel to the 
nearest consulate or visa application centre for each application and leave the travel document there, preventing 
further travel during the application process. Frequent travellers need to repeat the same lengthy procedure for 
each  application,  which  may  differ  depending  on  the  destination.  Applicants  also  pay  additional  fees  when 
applying through an external service provider.  

The  root  causes  of  these  problems  are  the  legal  requirement  for  Member  States  to  issue  a  paper  visa  sticker, 
Member  States’  reliance  on  in-person/paper-based  practices,  and  the  heterogeneous  level  of  digitalisation  and 
fragmented visa procedures across the Member States. 
What is this initiative expected to achieve?  
The overall objective of the initiative is to simplify, harmonise and reduce the administrative burden to apply for 
a  Schengen  visa  to  make  the  EU  a  more  attractive  destination  for  visa-required  travellers  and  to  improve  the 
security  and  safety  of  the  Schengen  area.  In  order  to  achieve  this,  it  aims  at  streamlining  and  making  more 
efficient the visa application procedure for applicants and Member States through digital means and at increasing 
the  security  of  the  Schengen  area  through  the  digitalisation  of  the  visa  sticker  and  digitalised  application 
procedures.  

A largely paperless and contactless visa procedure will be more cost-effective and save time for travellers and 
consulates,  while  also  ensuring  the  highest  level  of  security  at  EU  borders  and  safeguarding  the  protection  of 
applicants’ personal data.  
What is the value added of action at the EU level?  

The  objective to  make  visa  procedures  more  secure and  fit  for the digital age  cannot  be  achieved  by  Member 
States  acting  alone.  The  further  improvement  of  these  common  procedures  requires  EU  action.  The  problems 
identified  above  are  unlikely  to  disappear  in  the  near  future  and  they  are  directly  related  to  the  current  legal 
provisions.  Amendments  of  the  related  legislation  (mostly  the  Visa  Code  and  the  VIS  Regulation)  are  only 
possible at EU level since the objectives of this Regulation build on other initiatives aiming at streamlining and 
harmonising the procedures in the context of the common visa policy, and also because  short-stay visas are part 
of the Schengen acquis. By reason of scale, effects and impact of the envisaged actions, the objectives can only 
be achieved efficiently and systematically at EU level.  

B. Solutions 

What legislative  and  non-legislative  policy  options  have  been  considered?  Is  there  a  preferred choice 
or not? Why?  
The Impact Assessment evaluates five policy options, with varying levels of EU intervention in the current visa 
process: 

  Option  1,  considered  as  the  baseline  scenario,  envisages  no  legislative  action  to  be  undertaken  at  EU 
level.  Member  States  would  continue  (or  not)  to  develop  their  national  tools.  The  Commission  would 
issue  non-binding  recommendations  to  Member  States  and  support  them  with  soft  law  measures.  The 
visa sticker would continue to be used to issue visas. 

  Option 2 includes minimal legislative changes at EU level, aiming to remove legal obstacles that limit 
the possibility for the Member States to further digitalise the visa application process. The digital visa 

1 

 
 
 
 
 
would replace the paper visa sticker (mandatory) and a common web service for visa holders would be 
introduced to check its validity.  

  Option  3  foresees  the  (mandatory)  replacement  of  the  paper  visa  sticker  with  the  digital  visa  and  the 
development  of  an  optional  EU  visa  application  platform.  Under  this  option,  Member  States  could 
choose  to  participate  in  the  EU  visa  application  platform,  develop/continue  to  use  their  own  national 
portals or not develop any digital solution.  

  Option 4 foresees a mandatory digital visa and a mandatory EU visa application platform, in which all 

Member States would have to participate after a transition period.  

  Option  5 foresees  a  mandatory  EU  visa  application platform  for  all  Member  States  without  transition 
period,  a  fully  digital  procedure  (including  enrolment  of  biometric  data  by  applicants  through  digital 
means) and the digital visa (mandatory).  

The preferred option is option 4, as it 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, while ensuring a high degree of security. 
Who supports which option?  

Member States have an overall preference for options 3 and 4. In particular: 

  14 Member States favour the use of an EU application platform on a voluntary basis (option 3) whereas  
  10 would be in favour of mandatory use of the platform with a transition period (option 4).  
  All Member States support an option which provides for a digital visa.  

National data protection authorities also expressed a preference for options 3 and 4.  

The travel and tourism industry unanimously supports option 4, highlighting the positive impact on travel to 
the EU and the increased attractiveness of the EU as a travel destination.  

What are the main benefits of the preferred option?  

C. Impacts of the preferred option 

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

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,  under  option  4,  Member  States  would  save  EUR  510.9 
million in administrative costs over 2025-2029.  

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,  applicants  would  on  average  save  EUR  31  per  application  out  of  a  total  of  EUR  74 
spent in the baseline scenario for each application.  

Option  4  is  also  expected  to  have  a  slight  positive  impact  on  the  contribution  of  visa-required  third-country 
nationals to the EU GDP due to a possible increase of visa required third-country nationals travelling to the EU. 
However, the impact of the increase in travellers on the EU GDP 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. 

Overall, option 4 would largely harmonise the currently fragmented landscape for application procedures in the 
Member States, and improve the image of the EU as a unified entity in line with the common visa policy. 
What are the main costs of the preferred options?  

2 

 
 
 
 
 
 
 
 
 
 
Establishing the EU visa application platform will represent a substantial cost in comparison to the baseline. The 
estimated  cost  is  EUR  41.2  million  for  its  creation  and  EUR  12.8  million  yearly  for  it  to  be  operated  and 
maintained.  

Every Member State will need to connect and update their national system(s) so they can use the services from 
the  new  centralised  EU  digital  application  platform.  Cost  estimates  are  EUR  270  000  -  330  000  per  Member 
State. Investments at Member States level for the implementation of the digital visa are negligible.  

The environmental costs associated with the application process for repeat applicants will be nearly null, as they 
no  longer  need to travel  to  apply  or  collect their travel  document.  Paper  consumption  will also  decrease, with 
positive impacts on the environment.  The potential increase in tourism to the EU thanks to the digitalisation of 
visa procedures could trigger additional CO2 emissions; however this expected increase relies on an additional 
number of travellers that is difficult to predict and that is not certain, unlike the environmental benefits linked to 
the reduction of travel for applicants and paper consumption for applications and the visa sticker.  
How will businesses, SMEs and micro-enterprises be affected?  

The  main  businesses  that  would  benefit  from  the  initiative  would  be  those  in  the  travel  and  tourism  sectors. 
Representatives of the European tourism industry expressed strong support for digitalising the visa process and 
underlined  the  need  for  the  EU  to  offer  a  seamless  travel  experience  in  order  to  compete  with  other  global 
destinations.  
Will there be significant impacts on national budgets and administrations?  
The preferred option foresees an impact on national administration  in particular as regards the costs to connect 
and  update  their  national  system(s)  and  store  application  data.  Expected  savings  in  administrative  costs  (EUR 
510.9 million in the 2025-2029 period for all Member States) would largely offset these costs (EUR 140 million 
for all Member States in the 2025-2029 period). 

Will there be other significant impacts?  
As  regards  data  protection,  in  option  4  the  EU  platform  would  introduce  uniform  data  processing  practices, 
which would apply to all Member States. It would reduce exposure of personal data to external service providers, 
as repeat travellers would be able to apply directly through the EU application portal. Nevertheless, according to 
by the EDPS, certain data protection risks are inherent to digitalisation. This is why  the principles of “purpose 
limitation” and “data minimisation” will have to be strictly respected.  

The  right  to  non-discrimination  for  third  country  nationals  with  low  IT  access  and  literacy  would  not  be 
breached as external service providers and travel operators would provide assistance.  

As to the rights of people with disabilities, people unable to hear and/or see would benefit from less assistance 
in person but could be helped by enhancing the accessibility of online application tools, in line with recognised 
guidelines  on  web  accessibility.  External  Service  Providers  could  also  provide  guidance  to  people  with 
disabilities  or  low  IT  literacy.  The  situation  of  people  with  reduced  mobility  would  improve  as  in  certain 
circumstances people would no longer be required to visit a visa application centre or consulate. 

D. Follow up 

When will the policy be reviewed?  
Article 57 of the Visa Code and Article 50 of the revised VIS Regulation on Monitoring and Evaluation already 
provide for 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  also 
apply to the changes stemming from the adoption of the proposal on digitalisation of visa procedures. 

3