REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the state of play of preparations for the full implementation of the Interoperability Regulations in accordance with Article 78(5) of Regulation (EU) 2019/817 and Article 74(5) of Regulation (EU) 2019/818
Date: 2024-07-11
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, European Agency for the Operational Management of Large-Scale IT Systems in the Area of Freedom, Security and Justice, Schengen Information System, area of freedom, security and justice, biometrics, data protection, exchange of information, external border of the EU, information system

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 11.7.2024  COM(2024) 293 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the state of play of preparations for the full implementation of the Interoperability Regulations in accordance with Article 78(5) of Regulation (EU) 2019/817 and Article 74(5) of Regulation (EU) 2019/818  
 
 
1.  Introduction 

The Regulations1  establishing  the framework for  interoperability  entered into  force on 11 June 
2019  laying  out  the  legal  provisions  on  the  development,  data  handling  and  monitoring  of  the 
European  Search  Portal  (ESP),  the  shared  Biometric  Matching  Service  (sBMS),  the  Common 
Identity Repository (CIR), the Multiple-Identity Detector (MID) and the Central Repository for 
Reporting  and  Statistics  (CRRS).  Interoperability  brings  economy  of  scale  and  efficiency 
advantages to the EU IT-architecture in the field of migration, borders and security and, through 
the interconnection of its databases, establishes new features without the need to collect more data. 
These features include enhanced detection of identity fraud, new means to identify third-country 
nationals without proper identification documents and a fast and efficient way to cross-check the 
systems  to  prevent,  detect  or  investigate  terrorist  or  other  serious  crime  offences.  The 
interoperability of EU information systems also puts in place data quality control mechanisms to 
prevent,  detect  and  address  data  quality  issues,  facilitating  the  Union’s  exercise  of  its  positive 
obligation under data protection law to ensure that data inserted in the systems is accurate and up 
to date. 

The Regulations mandate the Commission, in cooperation with the European Union Agency for 
the Operational  Management  of Large-Scale  IT Systems  in  the Area of  Freedom,  Security and 
Justice  (eu-LISA),  to  monitor  and  evaluate  the  state  of  implementation.  In  line  with  these 
requirements,  the  Commission  submits  annual  reports  to  the  European  Parliament  and  to  the 
Council on the state of play of preparations for the full implementation of the Regulations. This 
4th report covers the period between October 2022 and November 2023. 

The implementation of the Regulations depends on the proper implementation of the underlying 
systems  that  are  part  of  the  interoperability  framework.  Although,  the  delayed  delivery  of  the 
Entry/Exit System  (EES) at  central  level  by eu-LISA’s contractor remains a risk factor for the 
proper  implementation  of  the  Regulations,  remedial  action  by  eu-LISA  is  bearing  fruit.  The 
Agency’s action allowed for the continuation of work with the existing contractor and managed to 
unlock the project’s implementation problems. The successful release of the EES minimum viable 
product2 is a decisive step towards the the EES going live. Furthermore, the Justice and Home 

1   Regulation (EU) 2019/817 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;  and  Regulation  (EU)  2019/818  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. Throughout the report 
these Regulations are referenced to as ‘the Regulations’.    

2   In  May 2023,  eu-LISA  developed  a  new  resolution  strategy  by  elevating  the  interaction  level  with  the project 
Consortium's  CEOs  to  ensure  their  commitment  and  resource  allocation,  implementing  a  gradual  ‘build-up’ 
approach  with  a  more  secure  timeline  and  agile  working  methods.  The  new  minimal  viable  product  (MVP) 
approach, endorsed by eu-LISA’s Management Board, aims to stabilise the implementation of EES by focusing 
on aspects that would add value for end-users and accelerate their preparations. The first release of the MVP, end 
of July 2023, is the first step of the resolution strategy. Subsequent steps concentrate on resuming Member State 
testing activities and the upgrade of the MVP improving the quality of the product.  

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Affairs Council of October 2023 approved the new waves approach roadmap, allowing the EU 
information  systems  and interoperability components  to  enter into operation in  a series of  four 
consecutive waves (first wave second half 2024, second wave first half 2025, third wave mid 2025 
and fourth wave end 2026). The waves approach creates much needed clarity for all stakeholders 
on the way forward for the upcoming years. 

In  the  meantime,  work  on  the  implementation  of  the  Regulations  continues  to  progress  across 
Member States, Schengen Associated Countries and EU agencies. As the interoperability project 
requires all stakeholders to work in a coordinated manner to avoid delays in one Member State 
affecting all, the Commission closely monitors and supports each Member State’s readiness for 
the moment the interoperability components go live.  

2.  State of play of interoperability framework systems 

Under the interoperability framework the new EU large-scale information systems, the Entry-Exit-
System3,  the  European  Travel  Information  and  Authorisation  System  (ETIAS)4,  the  European 
Criminal  Records  Information  System  for  Third-country  Nationals  (ECRIS-TCN)5,  the  already 
existing  but  revised  EU  information  systems  –  Schengen  Information  System  (SIS)6  and  Visa 
Information System (VIS)7, as well as Eurodac – will be interacting with one another through the 
newly established interoperability components and the tool for statistical reporting. The timeline 
described above is now seeing steady progress in the gradual entry into operation of the new and 
revised EU information systems.  

3   Regulation 2017/2226 establishing an Entry/Exit System (EES) to register entry and exit data and refusal of entry 
data of third-country nationals crossing the external borders of the Member States and determining the conditions 
for access to the EES for law enforcement purposes, and amending the Convention implementing the Schengen 
Agreement and Regulations (EC) No 767/2008 and (EU) No 1077/2011 (OJ L 327, 9.12.2017, p.20). 

4   Regulation (EU) 2018/1240 establishing a European Travel Information and Authorisation System (ETIAS) and 
amending  Regulations  (EU)  No  1077/2011,  (EU)  No  515/2014,  (EU)  2016/399,  (EU)  2016/1624  and  (EU) 
2017/2226 (OJ L 236, 19.9.2018, p. 1). 

5   Regulation  (EU)  2019/816  establishing  a  centralised  system  for  the  identification  of  Member  States  holding 
conviction information on third-country nationals and stateless persons (ECRIS-TCN) to supplement the European 
Criminal Records Information System and amending Regulation (EU) 2018/1726 (OJ L 135, 22.5.2019, p. 1). 
6   Regulation 2018/1860 on the use of the Schengen Information System for the return of illegally staying third-

country nationals (OJ L 312, 7.12.2018, p. 1); 
Regulation (EU) 2018/1861 on the establishment, operation and use of the Schengen Information System (SIS) in 
the field of border checks, and amending the Convention implementing the Schengen Agreement, and amending 
and repealing Regulation (EC) No 1987/2006 (OJ L 312, 7.12.2018, p. 14); 
Regulation (EU) 2018/1862 on the establishment, operation and use of the Schengen Information System (SIS) in 
the  field  of  police  cooperation  and  judicial  cooperation  in  criminal  matters,  amending  and  repealing  Council 
Decision  2007/533/JHA,  and repealing  Regulation  (EC)  No  1986/2006  of  the  European  Parliament  and  of  the 
Council and Commission Decision 210/261/EU (OJ L 312, 7.12.2018, p. 56). 

7   Regulation (EU) 2021/1134 amending Regulations (EC) No 767/2008, (EC) No 810/2009, (EU) 2016/399, 

(EU) 2017/2226, (EU) 2018/1240, (EU) 2018/1860, (EU) 2018/1861, (EU) 2019/817 and (EU) 2019/1896 of the 
European Parliament and of the Council and repealing Council Decisions 2004/512/EC and 2008/633/JHA, for 
the purpose of reforming the Visa Information System (OJ L 248, 13.7.2021, p. 11). 

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On  7  March  2023,  an  important  milestone  was  reached  when  the  renewed  SIS  entered  into 
operation, as the first element in the interoperability framework. The novelties of new types of 
alerts, more data categories and enhanced cooperation functionalities improve security and border 
management of the Schengen area. It does so by providing additional tools to combat criminality 
and terrorism, find missing persons, and protect vulnerable persons. It also allows to prevent and 
deter irregular migration and safeguard the rights of citizens. On 25 July 2023, Cyprus started to 
operate SIS, making it the 31st member country to use the system. 

In preparation for the entry into operation of the EES, 15 implementing and delegated acts have 
been adopted.8 Although the project has experienced significant delays, the implementation of the 
system is now entering the final stages, both at central and national level. The resolution strategy 
developed by eu-LISA to overcome the project’s delays is bearing fruit. The successful release of 
the EES minimum viable product is an important first step that allows for technical and business 
testing of the system. To soften the impact of the of the EES going live on border crossing points, 
the Commission discussed precautionary measures with eu-LISA and the Member States, while 
Frontex is developing a mobile application that allows the pre-registration of data of third country 
nationals. The EES Practical Handbook has already been shared with the Member States to support 
the  training  of  national  authorities.  In  addition  to  this,  the  launch  of  the  EES  website  with 
information for travellers and the preparation of an EES information campaign accompanying the 
start of operations will facilitate understanding of the new procedures at the external borders. The 
EES and the sBMS are now part of the first wave for the implementation of the Interoperability 
Framework, and are foreseen to enter into operation during the second half of 2024.  

As regards the ETIAS, implementation activities are ongoing. Out of the 31 implementing and 
delegated acts that have to be adopted, five acts remain to be adopted and three acts are currently 
being finalised before their adoption. Two of the remaining delegated acts (on the duration of the 
transition and grace periods) can only be adopted once ETIAS has started. A global communication 
campaign  is  being  prepared,  including  a  dedicated  ETIAS  website,  to  ensure  that  travellers  to 
Europe will be adequately informed about the new travel requirements in a timely manner. The 
ETIAS, together with the ESP and the CIR, are part of the second wave which should enter into 
operation in the first half of 2025.  

The development of the ECRIS-TCN is progressing. The implementing act laying down measures 
for the technical development and implementation of the centralised system for the identification 
of Member States holding conviction information on third-country national and stateless persons 
has been adopted. eu-LISA is currently implementing the system. The ECRIS-TCN, together with 
the ESP, CIR and sBMS for ECRIS-TCN, will go live in the third wave, which is set for mid-2025. 

The work on the revision of the VIS is underway since the adoption of amending Regulation (EU) 
2021/1134. The current focus is on the preparation of the secondary legislation necessary for the 
development of the revised VIS. Six out of 12 acts have been adopted. The revised VIS, together 

8   An implementing act laying down rules on a functionality for the centralised management of lists of authorities 

for both Entry/Exit Systems and Visa Information System is under preparation at Commission level.  

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with the MID, the last component of Interoperability, will go live in the fourth wave (second half 
of 2026). With the delivery of the MID, the MID Transitional Period will start9.  

The Regulations will also be applicable to the revised Eurodac10.  

3.  State of implementation of interoperability by the Commission 

The Regulations confer on the Commission the power to adopt delegated and implementing acts 
to supplement and implement certain detailed technical aspects of the Regulations. Some of these 
acts  are  necessary  to  fully  enable  eu-LISA  to  commence  its  design  and  development  of  the 
components in the context of the overall system architecture, especially as this requires defining 
technical specifications and preparing procurement procedures in order to work with contractors. 
Other acts are needed to lay down technical rules to facilitate the relevant authorities’ operations 
on  the  ground,  for  example  through  the  use  of  standard  forms  and  cooperation  procedures  to 
address security incidents. 

The acts are adopted in close cooperation with Member States and relevant agencies as well as the 
European Parliament and the Council of the EU and are discussed in the committees and expert 
groups  that  have  been  established  for  that  purpose.  All  acts  required  for  the  development  of 
interoperability  have  been  adopted  (three  delegated  and  ten  implementing  acts).  Due  to  the 
adoption of the Revised VIS Regulation11, the VIS consequential amendments Regulation12 and 

9   Article 69 of Regulation (EU) 2019/817, Article 65 of Regulation (EU) 2019/818. 
10   Regulation (EU) 2024/1358 of the European Parliament and of the Council of 14 May 2024 on the establishment 
of ‘Eurodac’ for the comparison of biometric data in order to effectively apply Regulations (EU) 2024/1351 and 
(EU) 2024/1350 of the European Parliament and of the Council and Council Directive 2001/55/EC and to identify 
illegally staying third-country nationals and stateless persons and on requests for the comparison with Eurodac 
data  by  Member  States’  law  enforcement  authorities  and  Europol  for  law  enforcement  purposes,  amending 
Regulations (EU) 2018/1240 and (EU) 2019/818 of the European Parliament and of the Council and repealing 
Regulation (EU) No 603/2013 of the European Parliament and of the Council 

11   Regulation (EU) 2021/1134 for the purpose of reforming the Visa Information System (OJ L 248, 13.7.2021, p. 

11) 

12   Regulation (EU) 2021/1133 as regards the  establishment of the conditions for accessing other EU information 

systems for the purposes of the Visa Information System (OJ L 248, 13.7.2021, p. 1) 

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the ETIAS consequential amendments Regulations13 on 7 July 2021, three acts14 had to be revised. 
The new texts are  now considered stable and close to  their  final  adoption. The power to  adopt 
delegated acts is conferred on the Commission for a five year term by the Regulations. Due to the 
delays caused by the EES project and its effect on the entry into operation of the interoperability 
components, the Commission has requested an extension of the delegated powers. This is the only 
way  to  guarantee  that  the  transitional  period  foreseen  for  the  European  search  portal15  and  the 
transitional period for the multiple-identity detection16 could be extended if necessary. 

Pursuant to Article 77 of Regulation (EU) 2019/817 and Article 73 of Regulation (EU) 2019/818, 
the Commission is also mandated to make available a Practical Handbook for the Implementation 
and Management of the Interoperability Components. The Handbook is vital to support the users 
of the EU information systems (such as border, visa, immigration and law enforcement authorities) 
with  ready-made,  user-friendly  guidance  for  using  the  features  made  available  through 
interoperability. The  Handbook is  developed by  the Commission  in  close cooperation with  the 
Member  States,  eu-LISA,  Europol,  Frontex  and  the  Fundamental  Rights  Agency.  During  the 
reporting  period,  seven  expert  group  meetings  and  three  joint-expert  group  meetings  were 
organised 
to  develop  standard  procedures  and 
recommendations to be inserted in the Handbook. The first version of the interoperability Practical 
Handbook is planned to be ready by mid-2024. 

to  foster  common  understanding  and 

The Commission is also developing a digital, easy to navigate version of the Handbooks in order 
to  respond  to  the  increasingly  complex  work  environment  of  the  users  of  the  EU  information 
systems. Due to the addition of features, like links requiring manual verification, users will need 
to perform operations sometimes involving several of the information systems and interoperability 
components at once. The online dissemination tool17 that is currently being set-up, will interlink 
all Handbook sections so that users can navigate through them from a systems perspective (e.g. 
EES or ETIAS) or from an end-users perspective (e.g. border guard or police officer). Depending 
on  the  users’  role,  information  and  procedures  will  be  filtered  to  display  only  the  information 

13   Regulation  (EU)  2021/1150  amending  Regulations  (EU)  2018/1862  and  (EU)  2019/818  as  regards  the 
establishment  of  the  conditions  for  accessing  other  EU  information  systems  for  the  purposes  of  the  European 
Travel Information and Authorisation System (OJ L 249, 14.7.2021, p. 1); 
Regulation (EU) 2021/1151 amending Regulations (EU) 2019/816 and (EU) 2019/818 as regards the establishment 
of the conditions for accessing other EU information systems for the purposes of the European Travel Information 
and Authorisation System (OJ L 249, 14.7.2021, p. 7); 
Regulation (EU) 2021/1152 amending Regulations (EC) No 767/2008, (EU) 2017/2226, (EU) 2018/1240, (EU) 
2018/1860, (EU) 2018/1861 and (EU) 2019/817 as regards the establishment of the conditions for accessing other 
EU information systems for the purposes of the European Travel Information and Authorisation System (OJ L 
249, 14.7.2021, p. 15); 

14   C(2021)4982  supplementing  Regulation  (EU)  2019/817  with  detailed  rules  on  the  operation  of  the  central 
repository for reporting and statistics, C(2021)5052 laying down technical rules for European search portal user 
profiles,  and  C(2021)6176  laying  down  technical  rules  for  creating  links  between  data  from  different  EU 
information systems. 

15   Article 67(2) Regulation (EU) 2019/817, Article 63(2) Regulation (EU) 2019/818. 
16   Article 69(8) Regulation (EU) 2019/817, Article 65(8) Regulation (EU) 2019/818. 
17   The dissemination tool is a website whose access is restricted to the user community of the systems to which the 

Handbooks apply and hosted by the Commission’s IT service (DIGIT).  

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relevant to that particular user. The SIS, EES, ETIAS and Interoperability Handbooks will be made 
available on the dissemination tool by the second quarter of 2024.   

4.  State of implementation of interoperability by Member States and 

Union agencies 

The  Regulations  establish  the  governance  framework  comprised  of  the  Interoperability 
Programme Management  Board18  and the  Interoperabiliy  Advisory Group19  to  ensure  adequate 
design and development of the interoperability components and tools. Both bodies are under the 
umbrella of eu-LISA, with the Commission being a member of both. Technical implementation of 
the Regulations is discussed in these bodies and progress is monitored using a monthly/bi-monthly 
questionnaire on the technical preparations at Member States’ and relevant EU agencies’ level.  

In order to assess the state of implementation beyond the technical preparations, the Commission 
organises at  regular intervals  the Forum on the implementation of the new architecture for EU 
information systems for borders, migration and security. The Forum is preceded by a questionnaire 
to  all  Member  States  and  relevant  EU  agencies  to  gauge  implementation  levels.  During  the 
reporting period, the Commission organised two Forums (December 2022, November 2023) and 
launched two questionnaires (November 2022 and April 2023).  

A small group of Member States can be identified as front-runners, while the other Member States 
are showing more modest progress. This is not yet a cause of concern but will be closely monitored 
to ensure timely readiness by all Member States. For the first time, the April 2023 questionnaire 
also focused on the steps taken at national level to get ready for the manual verification of links 
between  data  in  the  different  EU  information  systems,  which  is  the  biggest  change  to  current 
business  operations  for  the  authorities  involved.  About  one  third  of  the  Member  States  and 
Schengen Associated Countries have started to develop national software for this purpose. Several 
Member  States  prefer  eu-LISA  to  develop  a  central  tool  for  this  purpose  and  a  request  for  its 
development has been filed during the reporting period. Furthermore, several Member States are 
planning  for  some  level  of  centralisation  to  perform  the  manual  verification  more  efficiently, 
which is a step welcomed by the Commission.       

The  Commission  continues  to  monitor  Member  States’  implementation  progress  in  order  to 
identify areas of potential concern early on and ensure readiness for the start of operation of the 
EU information systems and their interoperability. During the reporting period, the Commission 
organised, with the support of eu-LISA, 56 meetings with Member States, Schengen Associated 
Countries, EU agencies and carriers.  

18   Article 54(4) Regulation (EU) 2019/817 and Regulation (EU) 2019/818. 
19   Article 75 Regulation (EU) 2019/817, Article 71 Regulation (EU) 2019/818. 

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5.  Training needs 

During the reporting period, the Commission supported Interoperability related trainings organised 
by CEPOL20. Six courses were organised during the reporting period.  Three webinars on using 
interoperability to facilitate law enforcement access to data and three full-week courses, two on 
the  Interoperability  Regulations  in  general  and  one  specific  course  on  the  MID  and  related 
operations. 

The delays and rescheduling of the entry into operations of the revised and new EU information 
systems, will also affect the interoperability training schedule. This is particularly relevant for the 
preparatory training for the entry into operation of the MID. The MID is the last interoperability 
component to go live, but it has the biggest impact on business operations in the Member States 
and Frontex. To properly prepare end users, CEPOL will organise courses focussing on the MID 
process and links management.  

The  Commission  is  developing  interoperability  training  material  to  support  these  training 
activities. A detailed training programme covering all aspects related to interoperability is being 
developed as well as shorter, more tailor-made training sessions for the different user communities.   

6.  EU funds 

Expenditures  during  the  reporting  period  are  below  the  amounts  estimated  in  the  legislative 
financial  statement  and  no  risk  of  overspending  has  been  identified  to  date.  According  to  eu-
LISA’s latest Interoperability Progress Report21, EUR 32.5 million has been paid to contractors 
and EUR 60.6 million has been contracted so far for development and implementation activities. 

Member  States  are  encouraged  to  make  full  use  of  the  resources  available  under  their  Internal 
Security  Fund  programmes  for  the  period  2014-2020,  until  the  deadline  for  eligibility  of 
expenditure lapses on 30 June 2024. Member States are also encouraged to use the resources for 
the further development and implementation of the interoperability of EU information systems that 
are available under their programmes, funded by the Instrument for Financial Support for Border 
Management and Visa Policy (BMVI) actions for the development and further implementation of 
the interoperability of EU information systems.  

7.  Conclusion 

The implementation of interoperability is an essential part of the improved IT-architecture for new 
and upgraded EU information systems facilitating not only faster, more efficient and systematic 
access to data by border, visa, immigration and law enforcement authorities, but allowing also for 
smoother  and  safer  border  crossing  for  the  millions  of  third-country  nationals  who  visit  the 
European Union every year.  

20   The European Union Agency for Law Enforcement Training. 
21   Eighth progress report on the development of interoperability as per article 78(2) of Regulation (EU) 2019/817 

and article 74(2) of Regulation (EU) 2019/818 (2023-215). 

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The  report  shows  steady  progress  during  the  period  October  2022  -  November  2023.  The 
Commission is in the final stages of adopting three amended and delegated acts22 related to the 
Interoperability  Framework.  Work  progressed  steadily  on  the  development  of  the  Practical 
Handbook for the Implementation and Management of the Interoperability Components and a first 
version  is  expected  by  mid-2024,  and  the  online  dissemination  tool  for  the  interoperability 
Handbook  and  other  Handbooks  has  also  progressed.  The  state  of  implementation  of  the 
Regulations among Member States shows a small group of front-runner Member States and a large 
group making more modest progress. This is not yet a cause of concern, but close monitoring is 
required.  

The  impact  of  the  obligation  to  manually  verify  links  generated  by  the  MID  on  the  business 
operations of the authorities affected is considered to be substantial. The first in-depth inquiry into 
levels of preparedness showed positive results as efforts are underway in Member States taking 
account of these new obligations, but the preparatory work is far from completed. While the new 
date  for  the  go  live  of  the  interoperability  components,  in  particular  the  MID,  offers  some 
additional preparation time, this should not result in a slowing of the project’s momentum. 

The  Commission  will  continue  to  monitor  progress  closely  and  assess  the  risks  for  the 
implementation  of  the  Regulations.  It  will  continue  to  regularly  engage  with  all  stakeholders 
concerned in order to coordinate and monitor actions, identify areas of potential difficulty, reduce 
the  risks  related  to  the  implementation  of  interoperability  and  support  timely  and  efficient 
implementation of all projects in line with the agreed timeline. The Commission will also keep the 
Council and the European Parliament informed on progress achieved through annual reporting and 
through the proceedings of the Commission’s Committees and expert groups.  

22 C(2021)4982, C(2021)5052, and C(2021)6176. See footnote 14 for the full titles. 

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