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 establishing an application for the electronic submission of travel data ("EU Digital Travel application") and amending Regulations (EU) 2016/399 and (EU) 2018/1726 of the European Parliament and of the Council and Council Regulation (EC) No 2252/2004, as regards the use of digital travel credentials
Date: 2024-10-08
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU national, border control, electronic government, exchange of information, external border of the EU, foreign national, information system, mobile application, personal data, traveller

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  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.10.2024  SWD(2024) 672 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 establishing an application for the electronic submission of travel data ("EU Digital Travel application") and amending Regulations (EU) 2016/399 and (EU) 2018/1726 of the European Parliament and of the Council and Council Regulation (EC) No 2252/2004, as regards the use of digital travel credentials       {COM(2024) 670 final} - {SEC(2024) 670 final} - {SWD(2024) 670 final} - {SWD(2024) 671 final}  
 
 
Impact assessment on the digitalisation of travel documents and facilitation of travel  

Executive Summary Sheet 

A. Need for action 

Why? What is the problem being addressed?  
Over half a billion passengers enter or leave the EU every year, putting a strain on the EU’s external 
borders. When crossing these borders, all travellers are subject to systematic checks, which include 
verifying  their identity and nationality, and the validity and authenticity of  their travel  documents. 
They are  also  checked in  the Schengen  Information  System  (SIS) and in  INTERPOL’s stolen and 
lost travel documents (STLD) database. For non-EU nationals, border authorities additionally check 
that the relevant entry conditions are met, and they will check that the traveller is registered in the 
Entry/Exit  System  (EES),1  once  that  system  is  up  and  running  in  2024.  Given  the  pressure  at  the 
external borders of the Schengen area and varying levels of digitalisation in the Member States, new 
challenges  are  emerging  in  terms  of  a)  ensuring  smooth  travel  and  b) tackling  the  problems  of 
security risks and inefficient border management. 

The  advantages  of  digitalisation  became  apparent  during  the  COVID-19  pandemic  in  a  range  of 
situations, but the EU is only now exploring the potential of digitalised travel documents, such as the 
digital  travel  credential  (DTC).  The  DTC  is  essentially  a  replica  of  the  personal  data  (excluding 
fingerprints)  on  the  chip  of  a  travel  document,  and  it  can  be  stored  securely  on  electronic  devices 
such as mobile phones for one-off or multiple use. DTCs can be shared ahead of travel, for example 
with border authorities and carriers, via an interface such as a mobile application. By using (verified 
and  authentic)  chip  data,  DTCs  can  address  the  following  problems  that  currently  hamper  smooth 
travel and may cause security risks: 

•  Errors  in  capturing  and  transmitting  data  required  by  border  management  and 
immigration  authorities.  The  advance  passenger  information  transmitted  by  carriers  often 
relies on self-declarations, including the context of ETIAS authorisation or visa applications, 
or  in  the  case  of  EU  nationals.  Errors  in  these  data  can  lead  to  security  risks,  inefficient 
border management and additional hassle; indeed, individual travellers may be refused entry 
and carriers fined. 

•  Possible divergences in standards in the implementation of DTCs and varying levels of 
digital maturity. These may cause fragmentation, leading to further security risks associated 
with document fraud, and may hamper the efficiency of external border management in the 
area without internal controls. 

•  Over-reliance  on  physical  checks,  which  puts  significant  pressure  on  border  control 
processes,  leads  to  potential  security  risks  and  stress  for  travellers.  Whereas  the  traditional 
travel document control process starts with travellers presenting their travel documents to the 
border  authority,  the  use  of  DTCs  means  that  most  checks  can  be  carried  out  in  advance 
before travellers even arrive at the border-crossing point. 

What is this initiative expected to achieve?  
The purpose of the initiative is to bolster security in the Schengen area, to enhance the efficiency 

1 Regulation (EU) 2017/2226 of the European Parliament and of the Council of 30 November 2017 establishing an 
Entry/Exit System (EES) to register entry and exit data and refusal of entry data of third-country nationals 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. 

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of  external  border  management  and  to  provide  a  framework  for  a  smoother,  easier  cross-
border travel for individual travellers. In order to achieve these objectives, the initiative sets out 
to: 
•  establish  a  uniform  standard  for  DTCs  based  on  passports  and  EU  identity  cards,  thereby 

fostering interoperability and cooperation; 

•  enable  travellers  to  submit  DTCs  securely  on  a  voluntary  basis  before  they  travel,  thus 

increasing the reliability and quality of the information provided; 

•  allow border authorities to carry out advance checks to reduce bottlenecks and the time spent 

by travellers at border-crossing points; 

•  ensure  that,  in  the  field  of  border management,  all  Member  States  achieve  the  minimum 
level of digital maturity required for interoperability of systems, mutual trust and more efficient 
management of external borders. 

What is the value added of action at the EU level?  
The current EU legal framework does not allow digital solutions for verifying the authenticity and 
integrity of travel documents for border checks or for other purposes related to free movement ahead 
of travel. Given the nature of the issue, the Member States cannot unilaterally introduce a uniform 
format  for  DTCs  to  facilitate  cross-border  mobility,  and  therefore  cannot  facilitate  the  exercise  of 
free movement by EU citizens on the basis of such DTCs. 

EU action could add considerable value in terms of addressing the challenges of security and ease of 
travel,  given  that  the  current  situation  adversely  affects  security  at  the  EU’s  borders.  Not  only  its 
external borders but also the EU as a whole have been placed under considerable strain, and joint EU 
action would ensure harmonised measures to enhance integrated border management. 

The EU needs to take action before Member States and private stakeholders develop individual, less 
effective and potentially fragmented solutions to facilitate travel within the current legal framework. 
Joint  action  at  EU  level  will  also  give  the  EU  greater  influence  over  future  global  standards. 
Preserving  the  status  quo  is  not  going  to  solve  these  problems,  neither  for  the  Member  States’ 
authorities nor for individual travellers. Objectives would be better  achieved through action at  EU 
level.  The need for a uniform  EU approach  was  confirmed by  a targeted  consultation process that 
was carried out among representatives of relevant Council preparatory bodies: 96% of them believe 
that a uniform approach across EU Member States is essential or very essential, and 82% think that 
truly  integrated  management  of  borders  and  facilitation  tools  within  the  EU  (without  overlapping 
border-management rules and laws that would cause operational inefficiencies) is essential or very 
essential. 

B. Solutions 

What legislative and non-legislative policy options have been considered? Is there a preferred 
choice or not? Why?  
All  the  policy  options  considered  entail  changes  to  existing  EU  law,  particularly  as  regards  travel 
documents  and  border  checks.  A  ‘soft-law’  approach  (e.g.  exchanging  good  practices, 
recommendations,  training  and  workshops)  was  ruled  out  from  the  start,  as  the  current  EU  legal 
framework does not allow for the use of digital travel documents for travel and border checks. 

All policy options have certain common building blocks, including a transition period, reliance on an 
existing international technical standard (developed by the International Civil Aviation Organization 
- ICAO), the voluntary nature of the use of DTCs by travellers, and a central EU technical solution 
for  the  creation  and  submission  of  DTCs.  The  main  difference  between  the  three  policy  options 
concerns  the  amount  of  flexibility  for  the  Member  States  in  areas  such  as  1)  the  possibility  for 
individuals to have DTCs (some have explicitly prohibited access to the chip data by anyone other 

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than the authorities) and 2) allowing travellers to use DTCs for cross-border travel. 

Policy option 1 allows Member States to make DTCs available to travellers and to facilitate border 
checks for people with DTCs. 

Policy option 2 obliges Member States to make DTCs available to travellers, and allows Member 
States to implement measures at border-crossing points for their use. 

Policy  option  3  obliges  Member  States  to  make  DTCs  available  to  travellers  and  to  implement 
measures at  border-crossing  points for the use of DTCs.  This  would remove legal  obstacles to  the 
use of digital travel-document data for border checks and establish a harmonised approach to their 
use across Member States. 

The preferred option is a combination of Options 2 and 3 with a suitable transition period, to 
allow EU citizens and non-EU nationals to: 

a)  obtain  their  DTCs  from  existing  ICAO-compliant  travel  documents  (passports  and  EU 

identity cards); 

b)  to use DTCs to cross the external borders of Member States that have chosen to implement 

DTCs during the transition period; and 

c)  to use DTCs to cross the external borders of all Member States after a reasonable transition 

period and once the shared EU technical solution is ready. 

Who supports which option?  
Most of the consulted stakeholders welcomed the digitalisation of all travel documents initiative, and 
this  favourable  view  came  through  in  strategic  interviews,  a  written  questionnaire,  in-depth 
interviews  and  a  Special  Eurobarometer  survey.  Only  in  the  public  consultation  did  a  majority  of 
respondents  (individuals  and  other  stakeholders)  express  a  negative  opinion.  However,  the  much 
more  favourable  results  of  the  Special  Eurobarometer  survey  involved  a  significantly  larger  and 
more  representative  sample.  Among  the  stakeholders  consulted,  opinions  were  mixed  on  whether 
implementation  of DTCs should be mandatory or voluntary. All  agreed, however, that the scheme 
should always be voluntary for the public. 

Despite  the  impact  on  national  systems,  among  experts  working  in  Member  State  administrations 
that took part in the survey, 65% said that it should be mandatory to accept DTCs and 71% said that 
it should be mandatory to enable the use of DTCs for facilitating travel. As for the creation of DTCs, 
77% stated that this should  be  done using a  shared  EU technical  solution.  Similarly, two thirds of 
respondents  in  the Eurobarometer survey  supported a single technical  solution.  Lastly, 94% of  the 
Member  States’  expert  respondents  thought  that  their  Member  State  would  be  successful  in 
introducing DTCs for external border-crossings, provided there was a gradual transition period. 

Most  stakeholders  consulted  (outside  the  public  consultation)  supported  the  different  measures 
proposed as part of the preferred option.  

C. Impacts of the preferred option 

What are the benefits of the preferred option (if any, otherwise main ones)?  
The preferred option is expected to have the most positive impact on: 

1.  bolstering security in the Schengen area and enhancing the efficiency of external border 

management, and 

2.  providing for smoother, easier cross-border travel for individual travellers. 

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This is mainly because the Member States will be obliged to allow individuals both to have DTCs 
and  to  actually  use  them  for  border-crossing  purposes.  Of  all  the  policy  options,  this  one  has  the 
highest  expected  uptake  of  DTCs.  It  would  give  the  authorities  the  best  chance  of  carrying  out 
advance  checks  and  would  enable  all  travellers  (with  a  travel  document  containing  a  chip)  to  use 
DTCs. 

The standardisation of DTCs and their use in external border management across the Member States 
would  also  bring  further  benefits,  such  as  increased  efficiency  for  carriers  as  they  could  integrate 
DTCs into their workflows. DTCs could also be used by EU citizens if an attribute is established for 
the  EU  Digital  Identity  Wallet  that  can  be  used  for  as  a  form  of  identification  within  the  EU,  for 
example. 

What are the costs of the preferred option (if any, otherwise main ones)?  
The preferred option does not place an excessive burden on Member States, and it is offset by the 
expected positive impact of the measures, in making border checks more effective and efficient and 
ensuring  better  use  of  resources  at  local  level.  This  option  mostly  involves  improving  existing 
arrangements rather than creating new obligations; in particular, travellers would be cleared 
for travel by means of pre-arrival border checks. An obligation to allow travellers to use DTCs 
for external border-crossings would create one burden: building the technical infrastructure to allow 
DTCs  to  be  processed  in  national  border-management  systems.  Due  to  the  ‘backwards 
compatibility’ of the DTC standard (i.e. its resemblance to existing travel documents) this should not 
be very complicated or expensive. Member States involved in the DTC pilot projects have estimated 
that  it  will  cost  between  EUR 300 000  and  EUR 700 000  per  Member  State.  In  addition,  server 
capacity may need to  be increased, depending  on the Member State and the exact  border-crossing 
points,  which  could  cost  up  to  EUR 250 000  per  Member  State.  Taking  account  of  changes  to 
national systems, differences in technological maturity and capacities, and reasonable overhead, it is 
estimated  that  an  average  of  EUR 2 million  per  Member  State  is  required  to  prepare  for  handling 
DTCs at their external borders. 

The costs for the EU institutions are limited to those incurred by eu-LISA (the EU Agency for the 
operational management of large-scale IT systems in the area of freedom, security and justice). The 
agency  will  need  to  develop  and  maintain  the  central  EU  system  for  obtaining  a  DTC  from  an 
existing  travel  document  and  for  submitting  that  DTC  (along  with  necessary  travel  data)  to  the 
Member  State  in  question.  eu-LISA  has  estimated  the  one-off  costs  for  the  development  and 
deployment of such an EU-wide application at EUR 49.5 million up to 2031. Additional staff needs 
are approximately 20 full-time equivalent staff from 2028 to 2031. 

How will businesses, SMEs and micro-enterprises be affected?  
Businesses, SMEs and micro-enterprises are not directly affected. However, with the establishment 
of a harmonised EU-wide definition of DTCs, businesses and other entities may benefit from being 
able  to  integrate  the  use  of  DTCs  into  their  customer-management  applications  and  workflows,  in 
accordance with national law and private contractual relationships. 

Will there be significant impacts on national budgets and administrations?  
As  described  above,  the  preferred  option  will  have  a  limited  impact  on  national  administrations, 
which  will  mostly  have  to  adjust  their  legislation  to  allow  the  use  of  DTCs,  as  referred  to  in  the 
Regulation.  Member  States  may  also  need  to  make  limited  investments  in  terms  of  technical 
infrastructure, software and hardware, depending on the existing equipment at their border-crossing 
points. 

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Will there be other significant impacts?  
The initiative will support the Commission’s Digital Europe strategy, which is aimed at ensuring the 
integrity  and  resilience  of  the  EU’s  data  infrastructure  and  boosting  the  uptake  of  technology  that 
will make a real difference to people’s daily lives.  The preferred option will also contribute to the 
EU’s  Digital  Decade  and  in  particular  to  the  target  of  80%  of  citizens  using  a  digital  identity  by 
2030. 

D. Follow up 

When will the policy be reviewed?  
The  proposed  legislation  should  be  reviewed  once  the  Member  States  have  had  sufficient  time  to 
implement  it.  The  measures  for  using  DTCs  under  the  preferred  option  would  be  mandatory  for 
Member  States  after  a  transition  period,  making  it  simpler  to  collect  data  on  their  use  and  added 
value. 

The specific objectives for evaluation are: 

1)  improved  security  in  the  Schengen  area  and  enhanced  efficiency  of  external  border 

management, and; 

2)  a smoother, easier travel experience for travellers. 

Monitoring and evaluating the fulfilment of these and other general objectives will involve several 
indicators such as figures on DTCs used and submitted, forgery in relation to their use, cost savings 
for authorities and feedback from individual travellers. 

The data would feed into separate reports from the Commission to the European Parliament and the 
Council.  The  Schengen  Handbook  (Practical  Handbook  for  Border  Guards)2  should  be  updated  to 
incorporate the  changes  to the legal framework and  to  provide the Member States  with guidelines 
and recommendations on the implementation of DTCs for external border management. 

The  implementation  of  the  measures  under  this  initiative  would  also  be  examined  as  part  of  the 
Schengen  evaluation  and  monitoring  mechanism  –  and  covered  in  the  annual  State  of  Schengen 
reports and in the Schengen Barometer and the Schengen Scoreboard, which accompany the reports. 
At  the  same  time,  the  Commission  must  closely  monitor  global  developments  in  travel  and  in  the 
digitalisation  of 
reciprocity  and 
competitiveness. 

travel  documents 

interoperability, 

to  ensure 

in  order 

2 https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf 

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