COMMISSION STAFF WORKING DOCUMENT 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

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 8.10.2024  SWD(2024) 671 final  COMMISSION STAFF WORKING DOCUMENT  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) 672 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................................... 6 

1.1.  General background ........................................................................................... 6 
1.2.  Policy and legal context ..................................................................................... 7 
1.3.  Scope of the initiative ...................................................................................... 11 

2. 

PROBLEM DEFINITION .................................................................................................................. 11 

2.1.  What are the problems (and their drivers)? ..................................................... 13 
2.2.  What are the problem drivers? ........................................................................ 17 
2.3.  What are the effects? ....................................................................................... 19 
2.4.  What are the impacts on the stakeholders concerned? .................................... 21 
2.5.  How likely is the problem to persist? .............................................................. 22 

3.  WHY SHOULD THE EU ACT? ........................................................................................................ 22 

3.1.  Legal basis ....................................................................................................... 22 
3.2.  Subsidiarity: Necessity of EU action ............................................................... 23 
3.3.  Subsidiarity: Added value of EU action .......................................................... 23 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................................... 23 

4.1.  General objectives ........................................................................................... 23 
4.2.  Specific objectives ........................................................................................... 24 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................................... 24 

5.1.  What is the baseline from which options are assessed? .................................. 24 
5.2.  Description of the policy options .................................................................... 26 
5.2.1. General definition and policy changes ............................................................ 26 
5.3.  Options discarded at an early stage ................................................................. 31 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ........................................................... 32 

6.1.  Economic impact ............................................................................................. 32 
6.1.1. Impact on EU institutions and agencies .......................................................... 32 
6.1.2. Impact on Member States ................................................................................ 32 
6.1.3. Impact on EU citizens ..................................................................................... 34 
6.1.4. Impact on third country nationals .................................................................... 34 
6.1.5. Impact on industry ........................................................................................... 35 
6.2.  Social impact ................................................................................................... 36 
6.2.1. Impact on security ........................................................................................... 36 
6.2.2. Protection of personal data .............................................................................. 37 
6.2.3. Protection of fundamental rights ..................................................................... 40 
6.3.  Environmental impact ..................................................................................... 41 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................ 41 

7.1.  Effectiveness .................................................................................................... 41 
7.2.  Efficiency ........................................................................................................ 43 

1 

 
 
7.3.  Coherence ........................................................................................................ 45 
7.4.  Proportionality ................................................................................................. 48 
7.5.  Summary of assessment .................................................................................. 50 

8. 

PREFERRED OPTION ...................................................................................................................... 50 

8.1.  Benefits  of  the  preferred  option  for  the  digitalisation  of  travel  documents 

and facilitation of travel ................................................................................... 51 
8.2.  Potential disadvantages of the preferred option .............................................. 51 
8.3.  Application of the ‘one in, on out’ approach ................................................... 52 
8.4.  REFIT (simplification and improved efficiency) ............................................ 52 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 52 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................ 54 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES .................................................................. 54 

2.  ORGANISATION AND TIMING ...................................................................................................... 54 

3. 

4. 

CONSULTATION OF THE RSB....................................................................................................... 54 

EVIDENCE, SOURCES AND QUALITY ......................................................................................... 54 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................ 55 

1. 

2. 

CONSULTATION STRATEGY ........................................................................................................ 55 

CONSULTATION ACTIVITIES ....................................................................................................... 55 

2.1.  Strategic interviews with key decision makers and key experts ..................... 55 
2.2.  Targeted consultations ..................................................................................... 56 
2.3. 
In depth-interviews .......................................................................................... 56 
2.4.  Public consultation .......................................................................................... 57 
2.5.  Special Eurobarometer .................................................................................... 58 

3. 

CONCLUSIONS ................................................................................................................................. 59 

ANNEX 3: WHO IS AFFECTED AND HOW? .......................................................................................... 61 

1. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE..................................................................... 61 

1.1. 
Individuals ....................................................................................................... 61 
1.2.  Member States’ national authorities ................................................................ 62 
1.2.1. Border management authorities ....................................................................... 62 
1.2.2. Visa, ETIAS and other authorities ................................................................... 62 
1.3.  eu-LISA ........................................................................................................... 62 
1.4.  Other entities ................................................................................................... 62 

2. 

3. 

SUMMARY OF COSTS AND BENEFITS ....................................................................................... 63 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS ............................................................... 65 

ANNEX 4: ANALYTICAL METHODS ..................................................................................................... 66 

1. 

INTRODUCTION .............................................................................................................................. 66 

2.  MEMBER STATE AUTHORITIES ................................................................................................... 66 

3. 

EU-LISA ............................................................................................................................................. 70 

ANNEX 5: COMPETITIVENESS CHECK ................................................................................................ 76 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS ................................................................... 76 

2 

 
2. 

SYNTHETIC ASSESSMENT ............................................................................................................ 76 

ANNEX 5: SUMMARY OF THE PILOT PROJECT IN FINLAND AND CROATIA .............................. 77 

1. 

2. 

3. 

INTRODUCTION .............................................................................................................................. 77 

PROJECT OBJECTIVES ................................................................................................................... 77 

PROJECT IMPLEMENTATION AND OUTCOMES ....................................................................... 77 

4.  NOTEWORTHY OBSERVATIONS AND QUESTIONS RAISED ................................................. 82 

5. 

CONCLUSIONS ................................................................................................................................. 83 

Glossary 

3 

 
 
 
Term or acronym 

Meaning or definition 

AFSJ 

API 

BCP 

DTC 

EES 

ETIAS 

EUDIW 

eMRTD 

ETIAS 

GDPR 

IATA 

ICAO 

MFF 

PNR 

SBC 

SIS 

SLTD 

SSS 

Area of Freedom, Security and Justice  

Advance Passenger Information 

Border crossing point 

Digital Travel Credential 

Entry/Exit System 

European Travel Information and Authorisation System 

European Digital Identity Wallet 

Electronic Machine Readable Travel Document 

European Travel Information and Authorisation System  

General Data Protection Regulation 

International Air Transport Association 

International Civil Aviation Organization 

Multiannual financial framework 

Passenger Name Records 

Schengen Borders Code 

Schengen Information System 

Interpol Stolen and Lost Travel Documents database 

Self-Service System  

4 

 
 
TCN 

TFEU 

VIS 

Third country national 

Treaty on the Functioning of the European Union 

Visa Information System 

5 

 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1.  General background 

Our societies are becoming increasingly mobile1, with a significant number of EU citizens and third 
country  nationals  crossing  the  external  borders  of  the  EU2  every  day.  Over  the  last  two  years, 
external  border  crossings  have  steadily  increased  to  close  to  pre-pandemic  levels.  In  2019, 
605 million  external  border  crossings  were  recorded,  while  in  2020,  the  number  of  crossings 
dropped  to  186  million.  In  2023,  a  total  of  593  million  crossings  were  recorded.  From  these 
crossings, 65% were at air borders, 31% at land borders and the remaining 4% via sea borders3.The 
fact that over half a billion passengers enter or leave the EU every year puts a strain on the external 
borders  of  the  EU.  High  volumes  of  travellers  are  a  challenge  for  the  authorities  competent  for 
carrying  out  border  checks  at  external  borders,  as  well  as  for  EU  citizens  and  third  country 
nationals  crossing  borders  on  a  daily  basis.  To  ensure  that  systematic  checks  can  be  efficiently 
performed  on  every  traveller,  there  is  a  need  to  speed  up  border  controls  and  to  ensure  the 
facilitation of passenger flows while at the same time maintaining a high level of security. 

The advantages of digitalisation have become apparent during the COVID-19 pandemic in several 
contexts,  where  paperless  transactions  proved  to  substitute  or  reduce  significantly  close  physical 
contact as well as to speed up different processes. The EU Digital COVID Certificate4, for example, 
facilitated travel  at  a time when many Member States had introduced travel  restrictions linked to 
the protection of public health. Digitalisation of travel documents may improve the identification of 
travellers,  enable  better  advance  checks  by  authorities,  and  allow,  at  a  later  stage,  the  remote 
issuance  of  documents  and  ultimately  a  smoother  and  faster  border-crossing  experience  and 
streamlined  travel  processes  for  travellers.  It  can  also  ensure  high  standards  of  security  and  data 
protection, without putting the integrity of borders at risk.  

With  the  advancement  of  technology,  in  particular  improvements  in  biometric  identification  and 
interoperability  of  several  systems  in  the  field  of  migration,  borders  and  visas,  travel  and 
international  border  crossing  can  be  facilitated  with  the  use  of  digital  travel  credentials.  Industry 
and individual governments have already been exploring ways of using digital traveller information 
more effectively in order to facilitate passengers passing through the different stages of travel in a 
more  seamless  and  customer-centric  fashion5.  In  Europe,  much  of  this  is  thanks  to  the  EU 
investments in research and innovation6. 

1 IATA, “Air Passenger Market Analysis”, June 2022, available online at:  
https://www.iata.org/en/iata-repository/publications/economic-reports/air-passenger-monthly-analysis/ 
2  Within  this  report,  the  term  ‘external  borders’  refers  to  the  external  borders  of  the  EU  Member  States  as  well  as  
internal borders where the lifting of internal border controls has not yet been finalised. It therefore includes the borders 
between  a  Schengen  Member  State  and  Bulgaria,  Romania  and  Cyprus  as  well  as  the  borders  between  Schengen 
Member States and non-Schengen EU Member States. 
3 Statistics provided by the European Border and Coast Guard Agency (Frontex).  
4  See  https://commission.europa.eu/strategy-and-policy/coronavirus-response/safe-covid-19-vaccines-europeans/eu-
digital-covid-certificate_en. 
5 See e.g. IATA OneID. 
6  See  e.g.  iMARS  (image  Manipulation  Attack  Resolving  Solutions),  https://cordis.europa.eu/project/id/883356, 
Fly), 
Document 
https://imars-project.eu/; 
https://cordis.europa.eu/project/id/833704, https://d4fly.eu/; and METICOS (A Platform for Monitoring and Prediction 

(Detecting 

D4FLY 

Identity 

Fraud 

and 

the 

on 

6 

 
 
 
By leveraging existing technology and introducing digital travel credentials for EU citizens, the EU 
aims  to  facilitate  travel  across  external  borders,  to  relieve  pressure  and  bottlenecks  at  border-
crossing  points  and  to  shorten  waiting  times.  Third  country  nationals  could  also  benefit  from  the 
use  of  digital  travel  credentials  when  crossing  the  external  borders  of  Schengen  Member  States. 
They  would  be  able  to  undergo  advance  checks  and  reduce  the  touchpoints  where  physical 
interaction is required, for instance in the context of immigration-related processes.  

The use of such digital travel credentials would not only facilitate cross-border travel but also has 
as  the  objective  to  increase  the  security  and  efficiency  of  border  checks  and  to  facilitate  free 
movement of EU citizens more generally. To this end, the use of digital travel credentials as well as 
biometric solutions should maintain harmonised high standards of security and privacy among the 
Member States and the industry.  

Since  2006,  passports  issued  by  Member  States  have  an  integrated  chip,  containing  the  personal 
data and two biometric identifiers (facial image and two fingerprints7) of the holder (i.e. a biometric 
passport).  At  global  level,  171  countries  issue  biometric  passports8.  Since  2021,  identity  cards 
issued by Member States contain the same technology. There is no central passport or identity card 
database at EU level.  

What is a digital travel credential? 

The International Civil Aviation Organization (ICAO) already started its work in 2016 to digitalise 
travel  documents,  meaning  passports  and  national  identity  cards9,  with  a  view  to  facilitating  air 
travel.  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  e.g.  on  a  mobile  phone  either  for  a  single 
interaction  or  used  multiple  times.  The  DTC  can  be  shared  with  other  stakeholders  (e.g.  border 
authorities and carriers) through an interface (e.g. mobile app) ahead of travel.  

This  Impact  Assessment  is  based  on  the  findings  of  an  external  study,  a  public  consultation, 
extensive stakeholder consultations and other sources. 

1.2. 

Policy and legal context 

This initiative links up two important EU policy fields: The Commission’s Digital Europe strategy 
of 2020 and its 2021 Schengen Strategy that has as an objective to re-establish a fully functioning 
Schengen  area.  On  19  February  2020,  the  Commission  launched  the  Digital  Europe  strategy  on 
shaping Europe’s digital future10, which aims to ensure the integrity and resilience of the EU’s data 
infrastructure and to support the uptake of technology that will make a real difference to people’s 

in 

July  2023  according 

of Social Impact and Acceptability of Modern Border Control Technology), https://cordis.europa.eu/project/id/883075, 
https://meticos-project.eu/.  
7 The obligation to include fingerprints in the passport chip entered into force in 2009. 
8  Situation 
Inverid.  https://www.inverid.com/blog/countries-
study  by 
epassports#:~:text=Currently%20(July%202023)%2C%20171,adoption%20of%20ePassports%20almost%20universal. 
9  The  first  version  of  the  ICAO  Digital  Travel  Credential  (ICAO-DTC)  standard  is  already  finalised.  This  standard 
relies  on  travellers  having  the  physical  passport  with  them  even  if  a  digital  travel  credential  is  used.  Digital  Travel 
Credentials  –  Virtual  Component  Data  Structure  and  PKI  mechanisms,  Release  1.2,  October  2020: 
https://www.icao.int/Security/FAL/TRIP/PublishingImages/Pages/Publications/Digital%20Travel%20Credential%20%
28DTC%29.pdf.  
10 See e.g. communication-shaping-europes-digital-future-feb2020_en_4.pdf (europa.eu). 

to  a 

7 

 
 
daily  lives.  On  9  March  2021,  the  Commission  presented  a  vision  and  the  avenues  for  Europe’s 
digital transformation by 2030. The Commission proposed a Digital Compass for the EU’s digital 
decade  that  evolves  around  four  cardinal  points,  one  of  which  is  the  digitalisation  of  public 
services, with the specific objective of 80% of citizens using digital identity by the end of 203011.  

As announced in the Schengen Strategy of 2 June 202112 and provided for in the Commission Work 
Programme  202313,  the  Commission  plans  to  adopt  a  legislative  proposal  on  the  digitalisation  of 
travel  documents  and  travel  facilitation.  The  Schengen  Strategy  announced  an  impact  assessment 
that  would  prepare  the  ground  for  a  proposal  on  the  digitalisation  of  travel  documents  and 
facilitation of travel.  

In September/October 2022, in the 41st Assembly of the International Civil Aviation Organization, 
the EU and others14 submitted a Working Paper presenting a common long-term vision to guide the 
actions of States and stakeholders for the common goal of delivering the optimal passenger journey. 
The  Working  Paper,  setting  high-level  principles  focusing  on  inclusivity,  avoiding  bottlenecks, 
ensuring  sustainability,  resilience  and  global  interoperability,  underlined  the  importance  of 
appropriate  tools,  such  as  digital  solutions,  prioritising  contactless  processes  and  ensuring  better 
coordination among all stakeholders.  

These efforts for Europe’s digital transformation should be seen together with the advances taking 
place  in  the  domain  of  more  digitalised  borders  and  the  so-called  Smart  Borders  Package  that  is 
currently changing fundamentally the way we manage the EU’s external borders:  

•  The Entry Exit System (EES) Regulation15 adopted in 2017, and its related amendment of 
the  Schengen  Borders  Code16  (SBC),  introducing  the  recording  and  storage  of  the  date, 
time and place of entry and exit of third country nationals and the automatic calculation of 
the  duration  of  stay.  Third  country  nationals  will  also  have  to  provide  biometric  data  to 
create their individual EES file for carrying out border checks.  

11 Europe’s Digital Decade: digital targets for 2030 | European Commission (europa.eu). 
12  Communication  from  the  Commission  to  the  European  Parliament  and  the  Council  "A  strategy  towards  a  fully 
functioning and resilient Schengen area", 2 June 2021, COM(2021) 277 final. 
13 Commission work programme 2023, COM(2022) 548. 
14 Assembly 41st session, Executive Committee, Agenda Item 13: Facilitation programmes – Establishing a resolution 
on  high-level  principles  for  the  future  of  passenger  journey,  A41-WP/77,  Presented  by  Czechia  on  behalf  of  the 
European  Union  (EU)  and  its  Member  States,  the  other  Member  States  of  the  European  Civil  Aviation  Conference 
(ECAC),  Singapore,  Brazil,  Chile,  Costa  Rica,  Uruguay,  Venezuela  (Bolivarian  Republic  of)  and  the  European 
Organisation for the Safety of Air Navigation (EUROCONTROL)). 
15  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. 
16  Regulation  (EU)  2017/2225  of  the  European  Parliament  and  of  the  Council  of  30  November  2017  amending 
Regulation (EU) 2016/399 as regards the use of the Entry/Exit System, OJ L 327, 9.12.2017, p. 1–19. 

8 

 
 
•  The  European  Travel  Information  and  Authorisation  System  (ETIAS)  Regulation17, 
adopted in  2018, introduces  a future online travel  authorisation  for  visa-free  third country 
nationals to enter the Schengen area18.  

•  The  Visa  Information  System  (VIS)  Regulation,  adopted  in  200819,  establishes  an  IT 
system involved in the registration and checking of people who apply for a short-stay visa to 
enter  the  Schengen  area.  It  has  been  operational  since  201120.  The  system  can  perform 
biometric  matching,  primarily  of  fingerprints,  for  identification  and  verification  purposes. 
This  system  is  being  extended,  through  a  2021  amendment  of  the  VIS  regulation21  to 
include data on long stay visa and residence permits. 

•  The Schengen Information System (SIS) Regulation22, adopted in 2018, further develops 
the  system  (established  in  1995)  to  assist  the  competent  authorities  in  Europe  to  preserve 
internal security in the absence of internal border checks and to carry out border checks at 
external borders. 

•  The  Interoperability  between  EU  IT  systems  in  the  field  of  borders  and  visas 
Regulation23  establishes  a  framework  to  ensure  the  interoperability  between  the  above-
mentioned systems as well as others in the field of justice, asylum and law enforcement. 

In  the  context  of  the  exercise  of  the  right  of  free  movement  of  persons  within  the  EU, 
Regulation (EU) 2019/115724 has strengthened the security of identity cards of EU citizens and of 

17  Regulation  (EU)  2018/1240  of  the  European  Parliament  and  of  the  Council  of  12  September  2018  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. 
18  Third  country  nationals  who  are  family  members  of  EU  citizens  exercising  free  movement  rights  under  Directive 
2004/38/EC and who have a residence card of a family member of an EU citizen as provided for in that Directive and in 
Regulation  (EU)  2019/1157  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  strengthening  the 
security  of  identity  cards  of  Union  citizens  and  of  residence  documents  issued  to  Union  citizens  and  their  family 
members exercising their right of free movement should not be registered in ETIAS.  
19  Regulation  (EC)  No  767/2008  of  the  European  Parliament  and  of  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, 
L 218/60, 13. August 2008. 
20 VIS is operational since 2011 for short-stay visas. With the adoption of the revised VIS Regulation, the scope of the 
VIS has been extended to include data on long-stay visas and residence permits. The data for the start of operations of 
the revised VIS has not yet been adopted. 
21  Regulation  (EU)  2021/1134 of  the  European  Parliament  and  of  the  Council  of  7  July  2021  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. 
22  Regulation  (EU)  2018/1862  of  the  European  Parliament  and  of  the  Council  of  28  November  2018  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 
2010/261/EU. 
23  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. 

9 

 
 
residence  documents.  Under  the  Regulation,  all  Member  States  must  include  an  integrated  chip, 
containing the personal data and two biometric identifiers (facial image and two fingerprints) of the 
holder in identity cards in the same way as they do in the passports they issue. Prior to the adoption 
on  the  Regulation,  no  harmonised  standards  for  such  documents  existed  at  EU  level,  resulting  in 
some Member States not issuing identity cards with a digital component. 

That Regulation is not part of the Schengen acquis and covers all EU Member States – independent 
of their membership in the Schengen area  – and, through its incorporation into the Agreement on 
the European Economic Area, also applies in Iceland, Liechtenstein and Norway25.  

the  Court  of  Justice’s 

Following 
in  case 
Landeshauptstadt Wiesbaden26, the Commission proposed a new Regulation on identity cards on 23 
July 202427. 

invalidation  of  Regulation  (EU)  2019/1157 

This initiative is also linked to other ongoing developments at EU level. In the context of identity 
management  in  the  digital  sphere,  the  Commission  is  currently  rolling  out  the  European  Digital 
Identity Wallet (EUDIW) established by the recently adopted Digital Identity Regulation28. That 
Regulation  introduces  an  EU-wide  framework  for  public  electronic  identities  based  on  a 
harmonised standard  allowing any individual to  have access  to  a secure  European digital identity 
that  gathers  different  electronic  attestations  (e.g.  identity  card,  passport,  driver’s  license,  medical 
prescriptions)  in  one  single  interoperable  digital  wallet,  the  EUDIW,  with  the  possibility  to 
cryptographically prove their authenticity and provenance.  

The revised rules on Advance Passenger Information29 (API) will soon be adopted. The revised 
API rules on the collection and transfer of advance passenger information (API) for enhancing and 
facilitating  external  border  controls  would  oblige  air  carriers  to  collect  by  automated  means  and 
transmit  the  API  data  (traveller  information  as  featuring  on  the  travel  document  and  flight 
information)  via  a  central  router  to  the  authorities  responsible  for  carrying  out  checks  at  external 
borders,  with  necessary  information  on  persons  whom  the  carriers  will  transport  to  a  Schengen 
Member State that could be contained in  the  digital travel  credential.  In the future, carriers could 
collect  the  API  data  from  travellers’  digital  travel  credential  and  with  the  traveller’s  consent, 
increasing data accuracy and efficiency of border checks. 

24  Regulation  (EU)  2019/1157 of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on  strengthening  the 
security  of  identity  cards  of  Union  citizens  and  of  residence  documents  issued  to  Union  citizens  and  their  family 
members exercising their right of free movement, OJ L 188, 1 July 2019, p. 67. 
25 Agreement on the European Economic Area (OJ L 1, 3.1.1994, p. 3). As a result, the Regulation does not apply to 
Switzerland. 
26 Judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251. 
27 COM(2024) 316 final. 
28 Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation 
(EU) No 910/2014 as regards establishing the European Digital Identity Framework (OJ L, 2024/1183, 30.4.2024, ELI: 
http://data.europa.eu/eli/reg/2024/1183/oj). 
29 Council Directive 2004/82/EC on the obligation of carriers to communicate passenger data, to repealed and replaced 
by Proposal for a Regulation of the European Parliament and of the Council on the collection and transfer of advance 
passenger information (API) for enhancing and facilitating external border controls. 

10 

 
 
Finally, the initiative is also thematically linked to the Commission proposal on the digitalisation 
of the visa procedure30 on which political agreement was reached by co-legislators in June 2023. 
The proposal aims to digitalise the visa application procedure and to replace the visa sticker with a 
digital visa. 

1.3. 

Scope of the initiative 

The initiative focuses on travel documents (passports and identity cards) and their digitalisation for 
the purposes of facilitating travel and making border checks at the external borders of the Schengen 
area more efficient and effective with upstreaming the moment of carrying out checks against those 
documents.  This  impact  assessment  looks  at  the  options  for  and  the  impacts  of  the  use  of  digital 
travel credentials by citizens of EU Member States and Schengen Associated Countries as well as 
third country nationals.  This  impact  assessment focuses on the impacts  for border authorities and 
travellers are they are directly impacted by the initiative.  

As  mentioned  above,  air  carriers  will  already  be  obliged  through  the  revised  API  rules  to  use 
automated means to  collect  passenger information in  order to  increase security through improved 
data  quality.  The  digital  travel  credential,  while  offering  a  suitable  format  for  the  collection  of 
passenger  information  with  automated  means,  is  not  the  only  way  for  them  to  comply  with  the 
obligations of the revised API rules, and – as set out in more detail below – there is no advantage 
for  border  authorities  or  the  carrier  themselves  in  imposing  the  use  of  the  same  format  for  that 
purpose.  The  same  applies  to  the  possible  voluntary  use  of  digital  travel  credentials  by  other 
carriers involved in the transportation of passengers (via land or sea borders). Such use of the DTC 
by the carriers, therefore, does not fall within the scope of the initiative.  

2.  PROBLEM DEFINITION 

Both  EU  nationals  and  third  country  nationals  are  subject  to  border  checks  when  crossing  the 
external borders. These checks comprise verification of the identity and the nationality of persons, 
the  validity  and  authenticity  of  their  travel  documents  as  well  as  consultations  in  the  relevant 
databases,  in  particular  the  Schengen  Information  System,  Interpol’s  Stolen  and  Lost  Travel 
Documents  (SLTD)  database  as  well  as  national  databases31.  In  addition,  systematic  checks  for 
third  country  nationals  include  the  assessment  and  verification  that  the  entry  conditions  are 
fulfilled, e.g. concerning the validity and authenticity of visas or residence permits, justification of 
the purpose and conditions of the intended stay and means of subsistence. These checks are done 
physically  at  the  border  crossing  point  and  the  process  typically  starts  once  the  traveller  presents 
their travel document to a border guard or at the e-gate.  

European  tourism  is  steadily  recovering  from  the  impact  of  the  pandemic.  In  2023,  European 
tourism  demand  showed  a  strong  and  positive  trend.  Based  on  year-to-date  data,  international 

30 Proposal for a Regulation of the European Parliament and of the Council amending Regulations (EC) No 767/2008, 
(EC) No 810/2009 and (EU) 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. 
31  The  obligation  to  consult  the  SIS,  SLTD  and  national  databases  of  all  persons  crossing  the  external  borders  was 
introduced in 2017. 

11 

 
 
tourist  arrivals  for  Europe  were  12%  higher  than  in  2023,  and  6%  higher  than  in  201932.  Since 
March 2022, European air traffic embarked on a  consistent upward trajectory, gradually reaching 
and sustaining levels in the high 80% of the 2019 levels. It is estimated that air travel to Europe in 
2024 will surpass pre-pandemic levels by 5%. From 2021 to 2022, there was an increase of 234.4%, 
and  in  2023,  an  increase  of  17.7%  in  international  Revenue  Passenger  Kilometres,  which  is 
currently  standing  at  almost  2%  above  the  pre-pandemic  level33.  Therefore,  European  travel 
remains  resilient  despite  obstacles  (such  as  the  pandemic,  economic  obstacles  and  the  Russian 
invasion of Ukraine) and is expected to experience steady recovery and growth in the future34.  

Given  the  pressure  faced  at  the  external  borders  on  the  verification  processes35,  combined  with 
different  speeds  in  the  digital  transformation36  of  Member  States,  new  challenges  are  emerging 
from  the  current  situation.  They  include  security  risks  and  inefficient  border  management  as 
well as obstacles to smooth and facilitated travel across borders. The increase in air passenger 
flows has translated into a higher pressure on available human resources at some air border crossing 
points and a subsequent increase in passengers’ waiting time37.  

At a time when private sector solutions have emerged that enable citizens to enrol and create digital 
travel credentials on their mobile devices, some Member States  already started to get involved in 
national  digital  travel  credential  programmes.  Among  those  Member  States,  some  are  more 
advanced  in  digitalising  travel  documents,  especially  those  involved  in  EU-funded  digital  travel 
credential pilots, such as the Netherlands38, Finland and Croatia39.  

These  two  main  issues  linked  to  obstacles  to  smooth  travel  and  security  risks  have  different 
implications  in  the  context  of  the  Schengen  area,  which,  in  principle,  is  free  from  controls  at 
internal borders. 447.7 million EU citizens, along with third country nationals living in the EU or 
visiting the EU as tourists, exchange students or for business purposes, can freely move around the 
Schengen area without being subject to border checks40. Nowadays, all countries that are part of the 

and 

32  European  Travel  Commission,  “European  Tourism:  Trends  &  Prospects  Quarterly  Report  (Q2/2024)”,  July  2024, 
available online at: ETC-Quarterly-Report-Q2-2024_Public.pdf (etc-corporate.org) 
33  IATA,  “Air  Passenger  Market  Analysis”,  June  2022,  and  IATA,  “Air  Passenger  Market  Analysis”,  July  2023, 
available online at :  
https://www.iata.org/en/iata-repository/publications/economic-reports/air-passenger-monthly-analysis/ 
https://www.iata.org/en/iata-repository/publications/economic-reports/air-passenger-market-analysis-july-2023/. 
34  European  Travel  Commission,  “European  Tourism  2022  –  Trends  &  Prospects  (Q1/2022)”,  May  2022,  available 
online at:  https://etc-corporate.org/reports/European-tourism-2022-trends-prospects-q1-2022/  
35 SWD(2022) 422 final, p. 3 (Impact assessment on API). 
36  Digital  Economy  and  Society  Index  (DESI):  The  Digital  Economy  and  Society  Index  (DESI)  |  Shaping  Europe’s 
digital future (europa.eu). 
37 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement of checks against relevant databases at external borders, February 2020. 
38 Research Monitoring Report, eu-LISA, “Enabling Seamless Travel to the European Union“, December 2022, p.39, 
https://www.eulisa.europa.eu/Publications/Reports/eu-LISA%20-
online 
available 
%20Seamless%20Travel%20Report%202022.pdf 
39 Raja Rajavartiolaitos, “Finland and Croatia are testing digital travel credentials in external border traffic in a DTC 
Pilot 
https://raja.fi/-/suomi-ja-kroatia-kokeilevat-digitaalisen-
matkustusasiakirjan-kayttoa-ulkorajaliikenteessa-dtc-pilottiprojektissa?languageId=en_US 
40 
https://home-
affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en.  In  terms  of  border  checks,  although  the 
general rule enables any person, irrespective of their nationality, to cross the internal borders without being subjected to 
border  checks,  the  competent  national  authorities  can  still  perform  police  checks  as  long  as  such  checks  are  not 
equivalent  to  border  checks  (objective  and  non-systematic  conditions).  Also,  only  when  there  is  a  serious  threat  to 

03.02.2023, available 

Commission, 

“Schengen 

European 

available 

project”, 

Europa, 

Area”, 

online 

online 

at : 

at: 

at: 

12 

 
 
 
EU are also members of the Schengen area, except for Ireland, Cyprus, Bulgaria and Romania. The 
latter three, nevertheless, are already applying the Schengen acquis to a large extent41. Next to non-
Schengen EU countries, there are the four non-EU countries that are members of the Schengen 
area:  Switzerland,  Liechtenstein,  Norway,  and  Iceland42.  EU  citizens  and  the  nationals  of  these 
four third countries enjoy, based on EU law or international agreements, a right to freely move to 
the territory of all these 31 countries. 

Figure 1 Problem Tree  

2.1.  What are the problems (and their drivers)? 

Problem 1:  Obstacles to smooth and facilitated travel across borders  

Europa, 

public  policy  or  internal  security,  border  control  at  internal  borders  of  a  Schengen  country  may  exceptionally  and 
temporarily be reintroduced as a measure of last resort.  
41 
Area”, 
affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en 
42 
Area”, 
affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en 

Commission, 

Commission, 

https://home-

https://home-

“Schengen 

“Schengen 

European 

European 

available 

available 

Europa, 

online 

online 

at: 

at: 

13 

 
 
 
 
Some  obstacles,  like  especially  the  congestion  at  border-crossing  points  and  transport  hubs,  can 
hinder  smooth  and  facilitated  travel  across  borders  for  both  EU  nationals  and  third  country 
nationals.  

The  absence  of  digitalised  processes  or  the  only  partial  character  of  such  digitalised  processes, 
along with increasing passenger movements across borders, have resulted in longer waiting times 
at border-crossing points. Travellers are required to physically present their travel documents at 
all external border crossing points either to border authorities for manual verification or at e-gates. 
Even with the use of e-gates, a border authority official is required to supervise the process and to 
take a decision on admission or refusal of entry (or refusal to leave).  

When  EU  citizens  cross  the  Schengen  external  borders  while  travelling  to  and  from  the  EU 
Member States that have not abolished internal border controls, or while travelling to the Schengen 
area  from  a  third  country,  longer  queues  resulting  from  a  suboptimal  management  of  passenger 
flows may also place a burden on the exercise of these citizens’ right of free movement.  

Moreover, carriers transporting travellers in and out of the EU territory and the Schengen area, such 
as coaches, trains and airlines, face difficulties too and are impacted by traveller flows, the absence 
of  digitalised  processes  and  reliance  on  physical  interactions.  As  the  number  of  passengers 
travelling increases, the manual verification by border guards and carriers becomes a repetitive and 
time-consuming  process.  Similarly,  as  the  collection  and  transmission  of  advance  passenger 
information43  as  well  as  information  for  ETIAS  applications  is  largely  based  on  manually 
transcribed  or  self-declared  information,  it  can  lead  to  incomplete  or  incorrect  data,  having  a 
negative impact for passengers, carriers as well as authorities in terms of significant delays, fines or 
even refusals of entry. 

According  to  a  study  on  the  implementation  of  Regulation  (EU)  2017/458  as  regards  the 
reinforcement  of  checks  against  relevant  databases  at  external  borders,  EU  citizens  entering  the 
Schengen area experienced increased waiting times44, primarily at land and air borders, following 
the introduction of the reinforced checks in 2018. The study provided data on five Member States 
as concerned the changes in waiting time estimates. The changes compared to the situation before 
expanding the systematic checks to EU nationals ranged, at air borders, from 1 min (SE, FR) or 2 
min (AT) to 10 min (HR) and 30 min (PT). At land borders, only HR provided an estimate, which 
amounted to a 20-minute increase. Others provided more general assessments at “tripling” (BE) or 
“doubling” (HU) for all types of BCPs45. The overall perception or understanding of border guards 
is, according to the study, that overall waiting times have “significantly” or “somewhat” increased. 

Similarly,  processing  times  (verification  of 
travel  document  check,  database 
consultations)  per  passenger  increased  as  a  result  of  carrying  out  systematic  checks  on  EU 
nationals, with an EU average of an additional 16.2 seconds per passenger.  

identity, 

43  To  note  that  under  the  new  API  rules,  soon  to  be  adopted,  air  carriers  will  be  obliged  to  collect  API  data  by 
automated means. 
44 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement of checks against relevant databases at external borders, February 2020, p. 76. 
45 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement of checks against relevant databases at external borders, February 2020, p. 77. 

14 

 
 
Third  country nationals have been subject  to  thorough checks on entry and exit since  the entry 
into  force  of  the  Schengen  Borders  Code46.  This  includes,  among  other  things,  checks  on  travel 
documents,  verification  of  the  entry  conditions,  database  checks  as  well  as  verification  that  the 
person concerned has a valid visa or residence permit. With the future entry into operation of the 
Entry/Exit System, certain third country nationals47 are required to register additional information 
upon  arrival,  including  their  fingerprints  and  a  facial  image  taken  at  the  border  crossing  point, 
which will increase the amount of time for processing travellers, and, consequently, waiting times, 
and will have an impact on queue lengths and space requirements for transport hubs. According to 
the European Border and Coast Guard Agency (Frontex), the installation of pre-enrolment solutions 
can be very useful in scenarios where the majority of passengers are third country nationals to be 
registered into the Entry/Exit System48. 

Self-service  systems  are  already  envisaged  for  the  enrolment  of  data  by  third  country  nationals 
subject to EES49. Interaction with these ‘kiosks’ entails several steps from physically approaching 
the  device,  identification,  instructing  passengers,  asking  questions  related  to  entry  conditions, 
scanning  and  verifying  travel  documents  to  capturing  the  fingerprints  and  facial  images  of 
travellers. According to a Dutch study50, if advance remote enrolment of certain data, including the 
passport  data,  is  allowed,  the  overall  time  spent  interacting  with  the  physical  self-service  system 
can be reduced from 86 seconds to 67 seconds per passenger. 

Problem 2: Security risks and challenges to an efficient external border control  

Document fraud is a key enabler for the materialisation of risks that can impact various areas of 
the EU integrated border management components, such as the internal security of the EU and the 
functioning and security of the external borders. Document fraud is notably associated with cross-
border crime, migrant smuggling, irregular migration, hybrid threats and terrorism.  

In  2023,  EU  Member  States  and  Schengen  Associated  Countries  detected  a  total  of  17  424 
fraudsters  using,  or  in  possession  of,  22  395  fraudulent  documents51.  Fraudulent  passports 
accounted  for  38%  (8  674)  and  fraudulent  identity  cards  for  19%  (4  310)  of  all  fraudulent 
documents  detected  in  this  period,  constituting  the  two  most  used  documents  by  fraudsters.  In 
addition  to  physical  or  digital  alterations  in  otherwise  valid  travel  documents  (forgeries)  and 

46  Article  7  of  Regulation  (EC)  No  562/2006  of  the  European  Parliament  and  of  the  Council  of  15  March  2006 
establishing  a  Community  Code  on  the  rules  governing  the  movement  of  persons  across  borders  (Schengen  Borders 
Code), OJ L 105, 13.4.2006, p. 1. 
47  The  EES  applies  to  third  country  national  travellers  who  cross  the  external  borders  of  the  Schengen  area  and  are 
subject to a visa requirement, including those exempted from it and admitted for a short stay of up to 90 days in a 180-
day period. 
48 European Border and Coast Guard Report on Simulations – Findings for the Entry/Exit System, BCPs analyses 2020-
2022. 
49 Third country nationals holding a short-stay visa are subject to EES but they may not need to use self-service systems 
for  the  enrolment  of  data  (exceptions  for  those  whose  visas  are  issued  at  the  border)  as  their  biometric  data  were 
collected when they applied for a visa. 
50 McK Studie, Customer insights data analysis. 
51 Based on data reported by the European Border and Coast Guard Agency. Fraudulent documents is an umbrella term 
covering  forged  documents,  counterfeit  documents  as  well  as  authentic  documents  used  by  a  person  other  than  the 
rightful  holder  (impostor/lookalike  fraud).  Counterfeit  documents  refer  to  documents  that  were  unlawfully  produced 
from  scratch  to  closely  imitate  an  authentic  document.  Forged  documents  refers  to  documents  that  were  issued  by  a 
legitimate  authority,  but  were  unlawfully  altered  in  some  way,  e.g.  by  substitution  of  photo,  pages,  altered  data  or 
attacks on entry/exit stamps. In addition to passports and identity cards, the figures include residence permits, visas. 

15 

 
 
unlawfully produced/manufactured travel documents (counterfeits), lost, stolen or unlawfully given 
travel  documents  are  used  for  impostor  fraud  (or  lookalike  fraud),  where  the  fraudster  uses  an 
authentic  document  issued  to  someone  else.  Counterfeit  documents  accounted  for  58%,  forgeries 
for 12%, impostor fraud for 15% and fraudulently obtained documents for 9%.52.  

In order to ensure adequate security as well as interoperability of travel documents worldwide, the 
International  Civil  Aviation  Organization  (ICAO)53  developed  international  standards  for 
biometric  and  non-biometric  machine-readable  travel  documents.  Those  standards  provide 
specifications,  recommended  practices  and  guidance  on  areas  such  as  manufacturing,  issuance, 
authentication  and  security  characteristics.  The  EU  Passport  Regulation54,  which  establishes 
minimum  security  features  including  the  introduction  of  biometric  identifiers  for  passports  in  the 
EU,  rendered  the  ICAO  standards  mandatory  at  EU  level.  They  are  also  applicable  for  identity 
cards55.  On  a  global  level,  all  countries  apply  the  ICAO  standards  for  machine-readable  travel 
documents. There is currently no complete overview of how many of the 171 countries that issue 
biometric passports (with a chip) fully comply with the ICAO standards. 

Chips in travel documents are secured through various measures to prevent unauthorised access to 
the stored information and tampering as well as cloning. The chips utilise encryption techniques to 
protect the data, ensuring that the information can only be deciphered using specific cryptographic 
keys.  The  data  stored  on  chips  is  secured  by  access  control  mechanisms  so  that  only  authorised 
individuals  with  the  necessary  authentication  credentials  can  read  certain  data  (like  fingerprints). 
Communication between the passport chip and the inspection device is also secured through secure 
messaging  protocols.  The  data  stored  on  individual  chips  are  moreover  digitally  signed  by  the 
issuing authority using their individual signing certificates. Even one unauthorised minor alteration 
in the data changes the hash values when the chip is read, leading to an unsuccessful validation of 
the chip and its security components56. While physical travel documents and their security features 
can  be  counterfeited  or  forged  and  while  the  chips  may  be  cloned  or  created  from  scratch  and 
integrated  into  another  passport,  if  the  validation  of  the  chip  data  is  done  correctly  with  the 
necessary certificates, such manipulated chips and travel documents are easily detected.  

However, there is no guarantee that officials will systematically detect such cases of counterfeits, 
forgeries or other criminal activities with high certainty, due to various factors, such as pressure due 
to peaks in traveller traffic or infrastructural issues.   

Firstly, actual border checks are carried out only once the traveller arrives at the physical border-
crossing point and presents a physical travel document. Therefore, authorities are unable to verify 
in  advance  whether  the  person  concerned  (with  the  exception  of  visa  holders)  has  a  valid  and 
authentic travel document with them and, in case of third country nationals, whether they fulfil the 

ICAO,  Doc  Series, 

“Doc  9303  Machine  Readable  Travel  Documents”, 

52  Other  types  of  detected  documents  include:  pseudo/fantasy/camouflage  documents,  stolen  blank  documents  and 
uncategorised. 
53 
https://www.icao.int/publications/pages/publication.aspx?docnum=9303  
54 Council Regulation (EC) No 2252/2004 of 13 December 2004 on standards for security features and biometrics in 
passports and travel documents issued by Member States.  
55  Regulation  (EU)  2019/1157  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  on strengthening  the 
security  of  identity  cards  of  Union  citizens  and  of  residence  documents  issued  to  Union  citizens  and  their  family 
members exercising their right of free movement.  
56 See ICAO Doc 9303, Parts 9-12. 

available  online 

at: 

16 

 
 
entry  conditions.  This  is  due  to  a  lack  of  a  sufficient  legal  framework  enabling  border  guards  to 
carry out such checks in advance. Despite the checks carried out in the context of (future) ETIAS 
and  visa  application  processing,  border  authorities  need  to  verify  the  authenticity  of  travel 
documents and to verify that the entry conditions are still fulfilled at the moment the person reaches 
the  border  crossing  point,  as  a  significant  amount  of  time  may  have  passed  since  the  previous 
checks during the assessment of the visa or ETIAS application. Moreover, the ETIAS application 
process  does  not  enable  authorities  to  verify  the  authenticity  of  the  travel  document.  Similarly, 
although  API  (Advance  Passenger  Information)  data  collected  and  submitted  by  air  carriers  to 
border  authorities  of  the  destination  country  enable  the  authorities  to  carry  out  certain  checks  in 
advance,  including  the  consultation  of  several  databases,  it  does  not  allow  them  to  verify  the 
authenticity  of  travel  documents.  Moreover,  API  data  for  border  management  purposes  is 
predominantly collected in the context of Schengen-bound air travel57.  

While passenger volumes continue to increase and with authorities being required to carry out all 
checks  at  the  time  of  the  actual  border-crossing,  authorities’  capacity  to  manage  resources,  pre-
screen and focus on high-risk profiles and to detect irregular migration and cross-border crimes like 
trafficking in human beings is significantly reduced. 

Secondly,  although  border  authorities  are  required  to  verify  the  authenticity  and  integrity  of  chip 
data of biometric passports58 or identity cards, this may be at times skipped, due to travel peaks and 
technical malfunctions59, and border guards will, in these cases, rely more on a manual inspection 
of the document 60. However, even more common is the practice that despite the inspection system 
presenting  an  error  message  concerning  the  validation,  border  authorities  wave  through  the 
traveller,  thinking  that  this-or-that  type  of  travel  document  never  works  with  the  particular 
inspection  device.  In  fact,  there  may  be  several  reasons  for  the  unsuccessful  validation:  1)  the 
inspection  device  does  not  have  access  to  the  necessary  (public)  certificates  to  carry  out  the 
validation;  2)  there  has  been  a  technical  error  in  encoding  the  data  contained  in  the  chip  of  an 
otherwise  valid  and  authentic  document;  or  3)  the  chip  is  counterfeit  or  forged.  In  fact,  in  2022, 
there was a significant  increase in  the detections of fraudulent EU passports involving  the use of 
counterfeit  chips  or  tags.  It  is  particularly  worrying  when  fraudsters  become  aware  of  certain 
defects in the validation process, as this enables them to leverage the combination of the technical 
defect  and  the  practice  of  border  authorities  that  wave  through  holders  of  such  passports  without 
carrying out any additional investigations.  

2.2.  What are the problem drivers? 

The root causes of the two problems linked to facilitation and security are: 

▪  Increased chances of errors in capturing and transmitting required data (PD1):  

57 In 2020, 10 Member States also collected API data for sea borders and four for land borders. 
58  Second  subparagraph  of  Article  8(2),  second  subparagraph  of  Article  8(3)(a)(i)  and  second  subparagraph  of 
Article 8(3)(g)(i) of the Schengen Borders Code. 
59 This has been observed in several recent Schengen evaluations. 
60 Deficiencies have also been observed in the physical inspection of travel documents in several Member States during 
Schengen evaluations. This may be due to insufficient capacities particularly during peak times, lack of training as well 
as lack of inspection equipment. 

17 

 
 
The  collection  and  transmission  of  accurate  data  is  essential  for  the  management  of  external 
borders. This collection and transmission, in the case of third country nationals, applies in particular 
to self-declared data in ETIAS and visa applications. For EU nationals and third country nationals 
alike,  the  collection  and  transmission  applies  in  particular  to  advance  passenger  information 
collected and transmitted by air carriers and the actual checks based on those data. However, there 
are  increasing  chances  of  errors  in  capturing  and  transmitting  required  data,  which  can  lead  to 
security  risks  and  inefficient  border  control  management,  contributing  to  both  problems.  For 
carriers, the submission of erroneous data may lead to fines under carrier liability. 

▪  Possible  divergences  in  standards  in  the  implementation  of  digital  travel  credentials 

and varied levels in digital maturity (PD 2 and PD4):  

According  to  a  study  carried  out  by  the  European  Parliament  in  2019,  EU  citizens  are  becoming 
increasingly eager to embrace the digital transformation and expect that national governments cater 
for their digital needs61. Moreover, in IATA’s 2023 Global Passenger Survey62, 75% responded that 
they would rather use biometrics than traditional passports or boarding passes in international travel 
and  87%  of  respondents  were  willing  to  share  immigration  data  (e.g.  passport,  visa,  health 
questionnaire) to expedite the process.  

In  the  absence  of  a  common  reference  architecture,  there  is  a  risk  that  each  country  will  rely  on 
different  private  contractors  for  the  design,  development  and  implementation  of  various  tools  to 
reply  to  these  expectations.  As  a  result,  Member  States’  programmes  and  levels  of  security  will 
become  incompatible  with  each  other,  digital  fragmentation  will  increase  and  border  control 
management  across  the  EU  will  risk  being  negatively  impacted.  Moreover,  depending  on  which 
country EU citizens and third country nationals are travelling through, their travel experience might 
significantly differ (e.g. non-mutual  recognition  of the used digital travel  credentials), forcing  the 
traveller to use a variety of different digital tools, depending on which Member State he or she will 
be travelling to or through. This will increase the burden on him or her and, thus, also the risk of 
mistakes and the potential for frustration. 

These divergences and the lack of a common approach can increase the risk of fraud and reduce the 
ability  to  identify  fraud  cases,  as  opposed  to  a  common  digital  solution  used  by  all  the  Member 
States.  

While the level of convergence between the EU Member States is increasing, there is still a large 
gap between the EU’s frontrunners and those with the lowest level of digitalisation63. The failure of 
Member  States  to  make  concerted  efforts  to  meet  the  Digital  Decade  targets  can  entail  further 
fragmentation  in  the  way  each  Member  State  manages  its  border  control,  thereby  hampering  its 
efficiency  throughout  the  area  without  internal  border  controls.  In  addition,  such  differences  can 
impact negatively the travellers’ experience when travelling from one country to another.  

61  European  Parliament  Think  Tank,  “EU  policies  –  Delivering  for  citizens:  Digital  transformation”,  June  2019, 
available online at: https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2019)633171 . 
62  IATA,  Global  Passenger  Survey  2023,  press  release  available  online  at:  https://www.iata.org/en/pressroom/2023-
releases/2023-10-25-01/.  
63  Europa,  European  Commission,  “Shaping  Europe’s  digital  future”,  06.1.2023,  available  online  at:  https://digital-
strategy.ec.europa.eu/en/policies/desi. 

18 

 
 
▪  Reliance  on  physical  practices  and  peaks  in  border  crossings  put  pressure  on 

verification processes (PD3): 

Peak times in border crossings, combined with a full reliance on physical travel documents, can put 
significant pressure on border control and verification processes, leading to potential security risks 
and distressing travel experiences for passengers.  

When large numbers of people attempt to cross a border at the same time, border control staff must 
process a high volume of individuals in a short period64. Time pressure coupled with full reliance 
on  checks  of  physical  documents  on  the  spot  can  lead  to  rushed  or  inadequate  verification 
processes, which increase the likelihood of security breaches.  

It should be noted that not all travellers will be in the same situation when the EES will come into 
operation  as  certain  third  country  nationals  will  have  to  be  registered  upon  crossing  the  external 
borders of Member States using the system. Therefore, most third country nationals travelling to the 
Schengen area will be subject to the registration of their entry and exit data for short-term stays, as 
opposed to EU citizens and nationals of Schengen Associated Countries. 

In addition to the security risks, peaks in border crossings can make the travelling experience less 
satisfactory  for  passengers.  Long  queues  and  waiting  times  can  cause  frustration  and  discomfort, 
particularly for those with mobility issues or medical conditions or those travelling with infants.  

Overall,  peaks  in border  crossings  can  be  a  significant  challenge  for  staff  of  border  control 
authorities  as  well  as  for  the  carriers  and  the  transport  hub  operators,  leading  to  potential 
security risks and an unpleasant experience for travellers. Addressing these challenges requires 
a multifaceted approach that prioritises both security and customer service. 

2.3.  What are the effects?  

All the above-mentioned problems have several negative effects: 

▪  Area of freedom, security and justice is less safe  

The constraints imposed on border and screening authorities by a growing number of travellers, in 
particular regarding checks on the spot and the inability of clearing bona fides travellers ahead of 
travel,  create  the  risk  that  these  authorities  are  prevented  from  more  effectively  focusing  their 
resources  on  high-risk  travellers  and,  thus,  from  detecting  irregular  migration  and  cross-border 
crimes (e.g. human smuggling and trafficking networks).  Similarly, the border authorities may be 
prevented from efficiently uncovering cases of fraudulent physical documents, especially those of 
higher quality. According to Member States, some of the most common reasons for derogations to 
systematic  checks  against  relevant  databases  at  external  borders65  were  heavy  traffic  and  the 

64  Annex  to  the  Commission  Recommendation  establishing  a  common  "Practical  Handbook  for  Border  Guards 
(Schengen  Handbook)"  to be  used  by  Member  States'  competent  authorities  when  carrying  out  the  border  control  of 
persons  and  replacing  Recommendation  (C  (2019)  7131  final),  C(2022)  7591,  28.10.2022,  p.79,  available  online  at: 
https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf . 
65 See Article 8(2a) of the SBC. 

19 

 
 
 
 
intention to avoid excessive passenger waiting times66. Similarly, Member States may relax border 
checks  as  a  result  of  exceptional  and  unforeseen  circumstances67.  The  introduction  of  systematic 
checks  on  all  persons,  be  they  third  country  nationals  or  not,  led  to  an  increased  detection  and 
execution  of  SIS  alerts  for  arrest,  extradition  and  surrender  as  well  as  an  increased  detection  of 
individuals that are subject to entry bans related to criminal charges, and of a fraudulent usage of 
identity  documents.  In  some  Member  States,  the  introduction  of  systematic  checks  even  doubled 
the  relative  number  of  hits  in  several  databases68,  as  compared  to  the  targeted  checks  prior  to 
201769.  From  these  developments  it  follows  that  applying  derogations  or  relaxations  of  border 
checks creates a higher risk to security in the EU, with border crossing procedures being abused or 
wanted criminals crossing the borders undetected.  

Consequently, due to the nature of document fraud as an enabling crime, the presence of security 
threats may further increase, thereby making the area of freedom, security and justice less safe.  

▪  Practical limitations to free movement 

While all EU citizens enjoy  the right to move and reside freely  within the EU, they may need to 
cross the external borders of the Schengen area when travelling to and from the EU Member States 
that  have  not  yet  abolished  internal  border  controls,  when  travelling  to  a  third  country,  or  when 
travelling to the Schengen area from a third country. 

The  suboptimal  management  of  border  control,  in  the  face  of  increasing  passenger  movements 
across  borders,  entails  unnecessary  longer  manual  authentication  and  verification  processes  and 
hence,  longer  waiting  times.  This  suboptimal  use  of  resources  at  border-crossing  points  and 
transport  hubs  affects  the  proper  implementation  of  integrated  management  of  the  EU’s  external 
borders, as provided for in the Treaty70.  

More generally, for both EU nationals and third country nationals alike, the travel experience with 
delays can increase passenger frustration and affect the trust in the integrity of the Schengen area as 
a whole71.  

▪  Slowdown in the EU’s digital transition and goals 

Less  efficient  and  divergent  approaches  to  border  checks  and  travel  facilitation  may  also  lead  to 
fragmentation,  with  incompatible  solutions  being  deployed,  and  a  general  slowdown  of  shaping 
Europe’s digital future goals. These goals aim to open new opportunities for businesses, encourage 
the development  of trustworthy  technology  and foster an open and democratic society, ultimately 
by  making  sure  that  technology  improves  the  daily  lives  of  citizens.  The  COVID-19  crisis  has 

66 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement of checks against relevant databases at external borders, February 2020, p. 42. 
67 See Article 9 of the SBC. 
68 Hits can pertain e.g. to having an alert on refusal of entry and stay, being wanted for judicial processes or having a 
travel document that is reported as lost or stolen. 
69 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement of checks against relevant databases at external borders, February 2020, p. 54. 
70 TFEU, Article 77(1)(c).  
71  See  Eurobarometer  survey  on  the  digitalisation  of  travel  documents  and  facilitation  of  travel,  2023.  According  to 
SITA,  Passenger  IT  insights  2023,  48%  out  of  6448  respondents  experienced  long  waiting  times  and  congestion  at 
airports.  

20 

 
 
emphasized  the  significant  role  that  digital  technologies  play  in  today’s  lives  and  has  accelerated 
the digital transition with the introduction and uptake of remote (digital) interactions in the space of 
travel, health, commerce, education and work. It also confirmed how important it is for the EU to 
rely on its own digital solutions rather than being dependent on those coming from other regions of 
the world72, while ensuring global interoperability. 

Examples of the effects as observed during several recent Schengen evaluations 

The increase in and a poor management of passenger flows, and the lack of personnel during peak 
times combined with the inability to carry out checks in advance has led  to EU citizens having to 
line up with third country national travellers at the border crossing points, resulting in long queues 
and excessive waiting times of more than one hour. 

Several  border  crossing  points  have  been  affected  by  technical  problems  and  malfunctions  of  the 
border check system, leading to authorities not carrying out systematic checks and not verifying the 
authenticity of travel documents. On some occasions, even the verification of the traveller’s identity 
has been skipped, and, coupled with high passenger flows, authorities have resorted to relaxations 
of border checks altogether. 

In several Member States, the software used for border checks and for checking travel documents 
was unable to verify the authenticity of travel documents, giving error messages on almost all travel 
documents. Despite this, travellers were waved through. 

Furthermore, in several Member States, API data is not used in an efficient way. Therefore, the aim 
of  improving  border  controls  and  combating  illegal  immigration  and  cross-border  crime  by  the 
transmission of advance passenger data currently is not achieved. 

In  one  case,  no  border  checks  on  flights  departing  to  a  third  country  were  performed  due  to  a 
shortage  of  staff.  Moreover,  there  was  no  follow-up  in  case  a  fraudulent  document  was  detected 
upon entry. 

These findings underline the  problems  preventing a  smooth travel  experience  as well as  the 
risks to security and of inefficient border control that adversely affect the internal security of 
the  EU  and  the  Schengen  area  as  a  whole  and  that  create  practical  obstacles  to  freedom  of 
movement. 

2.4.  What are the impacts on the stakeholders concerned? 

The effects concern different actors at their respective levels: 

▪  Travellers  are  affected  by  longer  waiting  times  than  necessary  at  border  crossing  points, 
due to their inability to submit data up front, which would allow the authorities to carry out 
certain checks in advance. Some travellers may even be discouraged from travelling due to 
the requirements for entry73. Individual citizens are also negatively impacted by the security 
risks posed by fraudsters and by cross-border criminal activity, the detection of which could 

72 Digital Europe, work programme 2021-2022, C(2021) 7914 final, 10 November 2021, p.3. 
73 According to IATA’s Global Passenger Survey 2023, 36% of travellers have been discouraged from travelling due to 
immigration requirements and 65% of respondents considered that the process complexity is the main deterrent. 

21 

 
 
be  made  more  efficient  by  allowing  for  advance  checks  on  the  basis  of  digital  travel 
credentials. 

▪  Border and law enforcement authorities are impacted by the increase in time-consuming 
manual  checks  on  the  spot,  due  to  the  increased  number  of  travellers,  which  reduce  the 
ability of the competent authorities to focus on high-risk travellers.  

▪  Fraudsters  and  criminals  leverage  the  shortcomings  and  take  advantage  of  the  current 

situation. 

2.5.  How likely is the problem to persist? 

An  absence  of  or  only  partially  digitalised  processes  would  require  competent  authorities  to 
continue  carrying  out  the  border  checks  manually  on  the  spot,  entailing  potentially  inconsistent, 
repeated and long  “pain  points” for travellers, thereby hampering  the smooth  crossing of persons 
across well-managed borders.  

Furthermore,  with  the  methods  of  fraudsters  getting  consistently  more  sophisticated,  it  will  also 
further reduce security and safety in the area of free movement without internal border control. In 
particular,  the  efficiency  of  border  checks  would  be  negatively  impacted  as  border  authorities 
would  be  less  capable  of  efficiently  identifying  fraudulent  documents,  cross-border  criminal 
activities and illegal immigration, especially in light of the increasing passenger flows. 

the 

issue  from 

the  angle  of  digital 

Looking  at 
transformation,  without  a  common 
regulation/reference architecture, Member States and industry would keep developing (or not) their 
own digital solutions that are not compatible with one another. This is likely to increase the costs 
for  the  Member  States  and  could,  at  the  same  time,  ultimately  damage  the  coherence  and 
effectiveness of the common EU integrated border management and have a negative impact on the 
integrity of the external borders as well as internal security.  

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

Article  77(2)(b)  TFEU  empowers  the  EU  to  develop  measures  concerning  the  checks  to  which 
persons  crossing  external  borders  are  subject.  Article  77(2)(d)  TFEU  empowers  the  EU  to  adopt 
measures for the gradual establishment of an integrated management system for external borders. 

Article  77(3)  TFEU  confers  on  the  EU  a  competence  to  adopt  provisions  on  passports,  identity 
cards, residence permits or any other such document intended to facilitate the exercise of the right 
to move and reside freely within the territory of the Member States guaranteed in Article 20(2)(a) 
TFEU74. 

74 

Judgment of 21 March 2024, Landeshauptstadt Wiesbaden, C-61/22, ECLI:EU:C:2024:251, paragraph 54. 

22 

 
 
 
3.2. 

Subsidiarity: Necessity of EU action 

The  EU  is  committed  to  facilitating  the  free  movement  of  persons  within  an  area  of  freedom, 
security  and  justice  which,  according  to  Article  4  TFEU,  is  an  area  of  shared  competence.  The 
shortcomings described above are inextricably related to existing legislation, notably the Schengen 
acquis concerning passports as well as border checks and EU legislation on identity cards. The set-
up  of  an  integrated  and  more  uniform  border  management  requires  coordinated  measures  and  a 
common approach at EU level. A common approach to digitalising travel documents is still missing 
and  results  in  problems  across  Member  States.  National  measures  are  subject  to  the  obvious 
limitation that their direct benefits are largely or exclusively confined to a single Member State (or 
several  Member  States  in  case  of  data  exchange  and  other  forms  of  cooperation),  whereas 
addressing systemic problems in relation to free movement clearly requires action with an EU-wide 
dimension, because of the intrinsic cross-border nature of these problems.  

Moreover,  the  current  EU  legal  framework  does  not  allow  for  the  use  of  digital  solutions  for 
verifying the authenticity and integrity of travel documents in border checks or in other situations 
of free movement. Instead, the current rules provide, in a mandatory way, for a check of physical 
travel  documents.  Therefore,  Member  States  themselves  cannot  effectively  introduce  a  uniform 
format for digital travel credentials and facilitate cross-border mobility. The problems elaborated on 
in the previous sections are unlikely to disappear in the near future and they are directly related to 
the current legal provisions.  

The  need  for  a  uniform  European  approach  is  confirmed  by  the  targeted  consultation  of  relevant 
Council  preparatory  bodies’  representatives  carried  out:  96%  of  Member  State  representatives 
believe  that  a  uniform  approach  across  EU  Member  States  is  essential  or  very  essential.  82%  of 
respondents consider a truly integrated management of borders and facilitation tools within the EU 
(without overlapping legislations and processes related to border management bringing operational 
inefficiencies) as essential or very essential. 

3.3. 

Subsidiarity: Added value of EU action 

EU  action  will  help  preventing  that  Member  States  and/or  private  actors  develop  individual 
solutions,  leading  to  a  fragmentation  and  possible  conflicts  with  the  EU  legal  framework. 
Moreover,  joint  action  at  EU  level  will  allow  the  Union  to  shape  future  global  standards  in  this 
area.  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 individual travellers. Only 
at EU level, can changes be implemented in a way that would lead to the benefits illustrated in this 
assessment. Objectives would therefore be better achieved through action at Union level.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The general objectives of the initiative are to contribute to: 

GO1: A safer area of freedom, security and justice; 

GO2:  EU  policy  on  integrated  border  management  and  more  efficient  and  effective  border 
checks; 

23 

 
GO3: Facilitated free movement of persons. 

4.2. 

Specific objectives 

In order to achieve the general objectives, the following specific objectives should be addressed: 

SO1:  To  increase  security  in  the  Schengen  area  and  the  efficiency  of  external  border 
management: 

▪  Establish a uniform standard for DTCs for the external borders in a coordinated way by 
all  Member  States,  fostering  the  future  interoperability  and  the  opportunities  for 
cooperation;  

▪  Allow  for  the  submission  of  a  DTC  by  the  traveller  in  a  secure  and  timely  manner 
ahead  of  his  or  her  trip,  increasing  also  the  reliability  of  the  data  submitted  to  the 
border control authorities; 

▪  Allow border control authorities to carry out advance checks against such data in order 

to reduce bottlenecks and time spent at the border crossing point; 

▪  Reach  a  minimum  level  of  digital  maturity  among  all  Member  States  in  the  area  of 

border management;  

SO2: To allow for a smoother and faster border crossing for travellers. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

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

Maintaining the status quo or baseline scenario analysed below would have short-, mid- and long-
term  travel-  and security-related impacts.  Having  in  mind the current  trend of digitalisation in all 
spheres of life, including international travel and migration, as well as the possibilities to address 
the problem drivers brought about by digital solutions, the cost of no action at EU level in the space 
of digitalisation of travel documents and travel facilitation are already visible and would continue to 
increase  if  the  status  quo  were  to  continue.  The  ability  of  competent  authorities  to  process 
increasing  flows of travellers in an effective and efficient manner would be hampered, leading to 
further security risks as well as congestion at border-crossing points, including longer waiting times 
as well as confusion and frustration for travellers.  

Without EU action, Member States would possibly develop (or not) their own national solutions for 
leveraging  digital  data  for  making  border  checks  more  efficient  and  effective,  resulting  in  a 
fragmented  landscape  of  technical  implementations,  different  levels  of  digitalisation  and 
security, which could lead to decreased security at the external borders as well as prolonged waiting 
times and less convenient procedures for individual travellers. Given that the external borders of the 
Schengen area are becoming smarter and more digitalised, new legal requirements for identification 
are being enforced. Furthermore, as further possibilities are emerging in the eIDAS framework, it is 
highly  likely  that  Member  States  will  digitalise  travel  documents  within  their  own 
competencies, and several Member States are already leveraging the chip data from passports and 
identity cards for national purposes, while some have explicitly prohibited it.  

24 

 
 
A digital solution implemented for EU citizens by one Member State may not be interoperable with 
the one chosen in another Member State, thereby creating practical obstacles to the exercise of the 
right of free movement, in particular where this situation should result in entry being refused to the 
EU citizen. Moreover, such fragmentation would severely jeopardize the aim of introducing a truly 
integrated management system for external borders. 

Next  to  the  Member  States’  initiatives,  industry  and  associations  would  continue  to  develop 
proprietary  or  transport-mode  specific  solutions  at  regional  or  international  level,  which  the  EU 
cannot necessarily influence, in the absence of EU-wide standards.  

Such divergences in standards will lead to the need for travellers to use a variety of apps or other 
digital solutions when travelling to and across the Schengen area and – possibly combined with the 
absence  of  digital  solutions  in  some  Member  States  –  can  be  expected  to  result  in  significant 
confusion  among  travellers  as  to  whether  the  specific  technological  solution  they  are  using  is 
accepted by the Member State of destination/departure. 

Existing national facilitation programmes  

The current legal framework75 allows Member States to establish national facilitation programmes 
on a voluntary basis, in order to allow pre-vetted third country nationals to benefit from derogations 
upon  entry  from  certain  aspects  of  thorough  border  checks.  The  derogations,  however,  do  not 
pertain to the verification of the authenticity and integrity of travel documents or for pre-registering 
biometric  data  for  speeding  up  controls  of  third  country  nationals  at  border-crossing  points. 
Similarly, no facilitation programmes for EU nationals making use of digital travel credential data 
are  provided  for  in  the  current  acquis.  The  requirement  to  carry  out  border  checks,  including  the 
verification  of  the  authenticity  and  integrity  of  travel  documents,  at  the  actual  border-crossing 
point,  is  common  to  all  Member  States  and  concerning  both  EU  nationals  and  third  country 
nationals, as provided in the Schengen Borders Code. 

Digital travel credentials 

Under  EU  law,  Member  States  have  an  obligation  to  issue  passports  or  identity  cards  to  their 
nationals76. However, the current legal framework does not provide for the possibility for Member 
States to issue or use these documents in a digital format. Instead, EU law requires them to issue 
them in a physical form. Moreover, the legal framework concerning the issuance of documents and 
the carrying out of border checks does not acknowledge the existence of a digital travel credential 
or digital travel credential based on a physical travel document, i.e. the solution chosen by ICAO 
for its DTC. Any additional exploitation of digital data therefore would need to be based on purely 
national rules that have to comply with the existing acquis. 

Finally,  in  the  absence  of  a  legally  accepted  standard  for  digital  travel  credentials  in  the  area  of 
international  travel,  the  travel  industry  (e.g.  carriers  using  any  mode  of  transport,  transport  hub 

75 Regulation (EU) 2225/2017. 
76 Article 4(3) of Directive 2004/38/EC of the European Parliament and of the Council of 29 April 2004 on the right of 
citizens  of  the  Union  and  their  family  members  to  move  and  reside  freely  within  the  territory  of  the  Member  States 
amending  Regulation  (EEC)  No  1612/68  and  repealing  Directives  64/221/EEC,  68/360/EEC,  72/194/EEC, 
73/148/EEC, 75/34/EEC, 75/35/EEC, 90/364/EEC, 90/365/EEC and 93/96/EEC (Text with EEA relevance), OJ L 158, 
30.4.2004, p. 77. 

25 

 
 
operators and accommodation providers) has no possibility to integrate such documents into their 
processes as there is no legal merit attached to them. This is relevant e.g. in the case of air and sea 
carriers in fulfilling their obligation to check the travel documents of passengers or establishments 
providing accommodation and their obligation to confirm identity of accommodated persons.  

5.2.  Description of the policy options 

5.2.1.  General definition and policy changes 

The  impact  assessment  evaluates  three  different  policy  options,  with  varying  levels  of  EU 
intervention  in  the  current  processes  concerning  border  checks  and  the  validation  of  travel 
documents.  

Option  1  (O1):  Implement  the  ICAO  DTC  standard  (optional)  with  travel  facilitation, 
automated  border  control  or  manual  booths  (optional)  and  transition  period.  This  option 
allows Member States to make available digital travel credentials and to facilitate the border checks 
of persons with such digital travel credentials. It would remove legal obstacles for Member States 
to  use,  at  their  discretion,  digital  travel  credential  data  for  border  check  purposes  and  would  be 
based on existing international standards. 

Option  2  (O2):  Implement  the  ICAO  DTC  standard  (mandatory)  with  travel  facilitation, 
automated  border  control  or  manual  booths  (optional)  and  transition  period.  This  option 
obliges Member States to make available  digital travel  credentials  and  allows  them  to  implement 
measures at  border crossing  points for the use of  such digital travel  credentials.  It  would  remove 
legal obstacles for Member States to use, at their discretion, digital travel credential data for border 
check purposes and would be based on existing international standards. 

Option  3  (O3):  Implement  the  ICAO  DTC  standard  (mandatory)  with  travel  facilitation, 
automated  border  control  or  manual  booths  (mandatory)  and  transition  period.  This  option 
obliges  Member  States  to  make  available  digital  travel  credentials  and  to  implement  measures  at 
border crossing points for the use of digital travel credentials. It would remove legal obstacles for 
Member States to use digital travel credential data for border check purposes, and it would establish 
a harmonised approach to the use of such digital documents across Member States. 

Explanation of building blocks 

All policy options have certain common building blocks or sub-elements. The legal instrument for 
all policy options should be a regulation, since they all entail amendments and additions to existing 
EU acquis, notably to the regulations concerning travel documents and border checks. A “soft law” 
approach  (exchange  of  good  practices,  recommendations,  training,  workshops  etc.)  was  ruled  out 
from  the  outset  as  the  current  legal  framework  prevents  the  use  of  digital  travel  credentials  for 
facilitating travel and for carrying out border checks.  

Each policy option also proposes a transition period77.  

77  94%  of  Member  States  surveyed  responded  that  their  Member  State  would  be  successful  in  introducing  DTCs  for 
travel facilitation with a gradual transition period. 

26 

 
 
It should be noted that the policy options only pertain to the use of digital travel credentials in a 
border-crossing context and in the course of border checks. However, by establishing a uniform 
format  for  digital  travel  credentials,  these  documents  could,  in  addition,  be  integrated  into  the 
processes  concerning  API  data  collection  by  air  carriers,  ETIAS  and  visa  applications  as  well  as 
possible third-party use cases (e.g. by air, land and sea carriers), in accordance with the applicable 
law  and  commercial  relationships.  Moreover,  EU  citizens’  digital  travel  credentials  can  cater  for 
several additional use cases under national law (e.g. proving identity). 

Moreover,  all  options  consider  the  ICAO  digital  travel  credential  Type  1  as  the  preferred 
standard  for  reasons  of  global  interoperability  as  well  as  technical  maturity.  It  is  an  existing 
standard,  endorsed  by  ICAO  –  the  body  responsible  for  setting  international  specifications  and 
standards for travel documents – that will most likely become the go-to option also for non-EU and 
non-Schengen countries developing digital travel credentials.  

According  to  this  standard,  the  digital  document  is  derived  from  an  existing  travel  document  by 
copying  the  data  stored  on  the  electronic  chip  (except  for  the  fingerprints)  into  an  application 
hosted on a device. This can be done using the mobile phone or e.g. a self-service system installed 
at border-crossing points or other dedicated locations.  The copy (DTC) could also be created and 
submitted  to  the  holder’s  digital  application  by  the  travel  document  issuing  authority,  in 
conjunction with issuing a new physical travel document.  

The policy choices are neutral as to how this creation or derivation of the credential is carried out 
for EU citizens, allowing Member States to choose from one or several  methods, as long as these 
methods  meet  certain  security  requirements,  e.g.,  including  the  verification  of  the  authenticity  of 
the original physical travel document and the verification of the person’s identity by matching their 
live  facial  image  to  the  facial  image  stored  in  the  chip  of  the  travel  document.  For  third  country 
nationals, the creation or derivation of the digital travel credential would have to be centralised in a 
common EU solution (see below) as these third country nationals do not have Member State-issued 
digital identity wallets compliant with EU specifications. 

The  traveller  can  then  submit  the  digital  travel  credential  to  the  relevant  authorities  via  an 
application.  The  competent  border  authorities  receive  the  data  and  can  carry  out  the  necessary 
checks  against  databases  and  validate  the  authenticity  of  the  travel  document.  For  third  country 
nationals, it can also verify the conditions of entry and stay before the person reaches the border-
crossing point, meaning that checks can be done even before issuing a travel authorisation or visa, 
thus  reducing  the  number  of  refusals  of  entry  at  the  border.  The  necessary  checks  are  done  in 
advance and the accepted travellers can pass through the border-crossing point without needing to 
present  their  travel  document  to  a  border  guard.  They  may  continue  directly  to  the  automated 
border  gates  or  manual  booths  supported  by  facial  recognition  capabilities,  which  will  match  the 
traveller’s face with the facial image submitted as part of the digital travel credential. At this point, 
and at least for border checks on entry, the chip of the physical travel document chip could be read 
at the gate to check whether the traveller carries the physical travel document. During this step, the 
device  conducts  active  or  chip  authentication/clone  detection  of  the  travel  document’s  chip.  This 
procedure brings down the inspection time from currently 6.2 seconds to 2.9 seconds per traveller78. 

78 Testing times for demonstrations reported by the editor of the ICAO DTC Technical Report. Further testing is carried 
out by the Netherlands, Finland and Croatia with real passengers in a real border-crossing context. 

27 

 
 
There  is  no  need  to  open  a  passport  as  the  inspection  device  does  not  need  to  read  the  machine-
readable zone to gain access to the contents of the chip, as is the case today. This phase could be 
skipped  during  border  checks  on  exit.  Moreover,  additional  time  is  saved  since  database  checks 
may  not  necessarily  need  to  be  carried  out  at  this  point  since  they  have  already  been  done  in 
advance. 

ICAO DTC Types 2 and 3 differ from Type 1 notably with their lesser reliance on the underlying 
physical travel document. In Types 2 and 3, the virtual component, meaning the digital copy of the 
chip data of current travel documents remains the same. However, the physical component, whose 
verification ensures that the document is not a clone, takes another (e.g., mobile device) form. The 
physical component needs to have cryptographic and communication capabilities, just like the chip 
of  a  physical  travel  document  does.  In  Type  2,  the  issuing  authority  still  issues  an  underlying 
physical travel document on which the DTC type 2 is based, and that physical document acts as a 
back-up. In Type 3, the DTC is issued and digitally signed by the issuing authority as in Type 2, but 
without an underlying physical travel document. The physical component specifications needed for 
ICAO DTC Types 2 and 3 have not been finalised. 

In  addition  to  the  ICAO  DTC  Types,  industry  has  developed  its  own  standards  for  digitalising 
several parts of the travel continuum, including leveraging the data on travel document chips (e.g., 
IATA  OneID).  These  are  often  referred  to  also  as  “digital  travel  credentials”  or  alternatively 
“verifiable  credentials”.  The  main  added  value  of  these  standards  for  industry,  such  as  airline 
carriers  or  airport  operators,  is  the  fact  that  they  may  cater  for  “selective  disclosure”,  which  the 
ICAO DTC does not. In short, these verifiable credentials can be designed and used in a way that 
certain  sensitive  data  that  is  not  needed  (e.g.,  social  security  number)  is  also  not  collected  or 
submitted to the relying party. 

Most  stakeholders  consulted  across  the  board  indicated  that  the  ICAO  DTC  Type  1  is  the  most 
realistic  option  to  implement  digital  travel  credentials  in  the  EU  from  a  regulatory  and  technical 
perspective. However, the initiative should be drafted in a way so as to enable the transition from 
Type  1  to  Type  2  once  the  technical  standards  evolve.  During  the  targeted  consultations,  all 
respondents  maintained  that  compliance  with  ICAO  standards  for  digital  travel  credentials  was 
essential  in  the  context  of  external  border  management.  Also,  in  all  policy  options,  both  EU 
citizens  and  third  country  nationals  are  included  in  the  scope.  By  including  third  country 
nationals within the scope of the initiative, Member States could further improve the efficiency and 
effectiveness of checks on travel documents, facilitate bona fide travel and contribute increasingly 
to the security of the external borders and internal security of the Union.  

At the same time, EU citizens and third country nationals should not be required to obtain and 
hold  a  digital  travel  credential.  This  option,  too,  has  been  ruled  out  from  the  start  as  being 
disproportionate  to  the  objectives  to  be  achieved.  Also  for  reasons  of  inclusivity  and  non-
discrimination,  having  a  DTC  should  not  be  mandatory.  Moreover,  the  results  of  the  public 
consultation carried out in preparation of this impact assessment do not support making this 
a  mandatory  requirement,  although  according  to  the  Special  Eurobarometer,  68%  of 
Europeans  are  in  favour  of  using  DTCs  for  international  travel79.  Therefore,  in  all  policy 

79  Special  Eurobarometer  536,  Digitalisation  of  travel  documents  and  facilitation  of  travel,  report  published  27 
September 2023. 

28 

 
 
options, it would be up to individual persons to choose whether they wish to obtain and use DTCs, 
acknowledging  that there may be several  reasons for a person not  wanting  or being  able  to  use a 
DTC. In addition, steps should be taken to ensure that travel remains fully possible for persons not 
in possession of a DTC, even if they will not enjoy the facilitation resulting from the use of DTCs.  

With regard to the derivation of the DTC from the existing travel document and its submission to 
the  competent  authorities,  all  policy  options  envisage  a  central  EU  solution  to  ensure  a 
harmonised  level  of  security,  integrity  and  convenience.  Without  a  common  technical  solution, 
each Member State would be required to develop their own solutions and travellers would have to 
have and use multiple applications depending on the Member State responsible for carrying out the 
border check. Moreover, 66% of the Europeans and 76% of the Member State authorities surveyed 
would  prefer  having  one  single  application  at  EU  level.  At  the  same  time,  none  of  the  policy 
options entail a centralised database for storing digital travel credential data as the central EU 
solution  would  only  act  as  a  router,  transferring  the  DTC  submitted  by  the  traveller  to  the 
competent  authority,  based  on  information  provided  by  the  traveller.  In  any  event,  existing  IT 
infrastructure should be considered for reasons of technical feasibility, ease of implementation and 
financial costs. Taking into consideration the ongoing work of eu-LISA on developing several  IT 
systems  as  well  as  their inter-dependencies  that  also  impact  this  central  EU  solution,  the  Agency 
estimates that this DTC solution could enter into operation in 2029, which also supports the need 
for a reasonable transition period. 

The  central  EU  system  should  include  the  functionality  to  store  the  DTC  (for  EU  citizens)  in  a 
digital identity wallet compliant with EU specifications.  

The  main  difference  in  the  three  policy  options  therefore  relates  to  the  level  of  flexibility 
enjoyed  by  the  Member  States  concerning  1)  the  possibility  for  citizens  to  have  DTCs  (as  some 
have explicitly  prohibited the access  to  the chip  data) and 2) allowing  travellers to  use DTCs for 
cross-border travel. A combination of policy options could also be envisaged, i.e. allowing Member 
States to opt-in for a certain period (as in O1 or O2) before being obliged to do so (as in O3). 

The  following  section  describes  the  policy  options,  closely  linking  them  to  the  drivers  of  the 
problems and the identified objectives. 

Full reliance on physical documents 

All  options  would  enable  Member  States  to  leverage  digital  travel  credential  data,  including 
biometric  data,  for  verification  purposes.  They  would  equally  allow  Member  States  to  digitalise 
parts  of  the  border  check  process,  notably  the  verification  of  the  traveller’s  identity,  and  of  the 
authenticity and integrity of the travel document, as well as ensure a smoother travel experience by 
removing  the  requirement  to  inspect  physical  travel  documents  in  detail  at  the  border-crossing 
points. Each policy option would therefore allow EU citizens and third country nationals to use a 
digital  travel  credential  when  going  through  border  checks,  but  with  varying  degrees  of 
harmonisation. O1 would leave it up to Member States to decide if and where DTCs could be used 
while O2 would enable and O3 would oblige Member States to create separate lanes or otherwise 
dedicated traveller processing for users of DTCs. 

Each  policy  option  would  also  establish  a  uniform  definition  of  a  DTC  at  EU  level.  This  would 
create the possibility of integrating the DTCs into existing immigration processes, like EES, ETIAS 
and  visa  applications  or  the  collection  of  API  data.  This  would  also  enable  carriers  and  other 

29 

 
stakeholders to develop integrations into their systems, where the DTC could be used for booking, 
ticketing, baggage reconciliation and other travel-related services. Currently, these services – each 
of which requires travel document data and verification of identity – are based on either manually 
inserted data or the physical scanning or inspection of the travel document.  

However, despite creating an EU-wide framework for digital travel  credentials, all policy options 
would require travellers to carry their physical travel document with them since certain checks may 
need  to  be  carried  out  on  it.  Similarly,  third  countries  are  unlikely  to  accept  travellers  without  a 
physical travel document – at least in the near future.  

All  policy  options  would  support  the  general  objectives  of  complementing  the  security  of  travel 
documents  and  enable  governments  to  receive  relevant  data  in  advance  to  reinforce  the 
effectiveness of border checks. Each policy option would also give travellers the opportunity for a 
more seamless  travel  experience and facilitate the exercise of the right to  free movement  when it 
involves the crossing of an external border of the Schengen area. The extent to which these goals 
are achieved by the respective options varies due to the differences in whether Member States are 
obliged to implement DTCs at the external borders or not. 

Finally,  in  terms  of  investing  in  European  digital  capacities  and  shaping  Europe’s  digital 
transformation as well as ensuring global interoperability, all options would be based on the ICAO 
DTC technical standard. Countries worldwide already implement the ICAO standards for physical 
travel  documents  and  will  likely  implement  the  ICAO  DTC  standards  for  digitalising  travel 
documents for international travel purposes.  

Increasing chances of errors in capturing and transmitting required data 

Passenger data is  collected and submitted at  various  touchpoints  during international  travel.  Each 
policy option would enable the automatic and accurate capture and transmission of required travel 
document data based on the DTC. All options can therefore support the objectives of making the 
Schengen  area  more  secure,  improving  the  efficiency  of  integrated  border  management  while 
making the travel journey for individuals more certain by eliminating errors and incompleteness of 
manually transcribed or self-declared passenger data.  

Possible divergences in standards in the implementation of digital travel credentials 

All policy options would essentially harmonise the standard for DTCs and the way in which they 
can be used in a border-crossing environment. The only difference between the options relates to 
whether Member States are allowed or obliged to do so.  

Peaks in border crossings putting pressure on verification processes 

O1  and  O2  would  potentially  tackle  the  problem  driver  concerning  peaks  in  border  crossings,  by 
allowing  Member  States  to  leverage  the  digital  travel  credential  data  through  pre-checks  and  an 
easier passage of travellers using digital travel credentials, but without an obligation to do so. O3 
entails mandatory facilitations for those using a DTC.  

Each  policy  option  would  also  enable  the  integration  of  DTCs  and  the  pre-submission  of  certain 
data  into  existing  migration  and  border  processes,  including  the  Entry/Exit  System,  therefore 
reducing the time spent by each traveller registering their data at border-crossing points. Under O3, 

30 

 
these integrations would be mandatory (if the third country national chooses to use a DTC), while 
for O1 and O2, this would be up to the Member States’ discretion. 

Varied levels of digital maturity among Member States in the area of border control 

Each  policy  option  would  establish  a  uniform  standard  for  the  DTCs  used  for  border  crossing 
purposes  in  the  Member  States.  However,  O1  and  O2  would  merely  allow  Member  States  to 
implement  DTCs  at  their  external  borders,  which  would  likely  lead  to  some  Member  States  not 
implementing  them,  leading  to  further  divergences.  O3  would  oblige  them  to  do  so,  therefore 
reducing  even  further  the  varied  levels  of  digital  maturity  or  traveller  confusion  and  ensure  a 
harmonised application of the DTC use cases in the context of external borders. 

5.3.  Options discarded at an early stage 

A “soft law” approach (exchange of good practices, recommendations, training, workshops etc.) 
was  ruled  out  from  the  outset  as  the  current  legal  framework  prevents  the  use  of  digital  travel 
credentials for facilitating travel and for carrying out border checks. Therefore, legislative changes 
are necessary. 

Creating  a  new  EU  standard  for  digital  travel  credentials  that  is  not  ICAO-compliant  has 
been excluded. ICAO already started its work in 2016 to digitalise travel documents with a view to 
facilitating air travel. All Member States currently use the ICAO standard for physical travel 
documents and it is the only standard that ensures global interoperability. 94% of Member States 
surveyed in the written consultation opined that a uniform approach across the EU is essential and 
all deemed that adherence to ICAO standards is very essential. If the EU created a new standard for 
digital  travel  credentials,  such  travel  documents  would  not  be  interoperable  with  current  systems 
deployed in the EU and globally. 

Implementing  the  ICAO  DTC  standard  and  enabling  border  checks  without  automated 
border  control  or  manual  booths,  i.e.  relying  fully  on  seamless  biometric  matching  on  the 
move  using  biometric  corridors  has  also  been  excluded.  Similar  to  e-gates  or  manual  booths 
equipped  with  facial  recognition  hardware,  biometric  corridors  use  biometric  data  to  authenticate 
travellers. However, instead of having to pass through an actual gate where the electronic identity 
document  is  read,  biometric  corridors  allow  travellers  to  walk  straight  through  the  border  checks 
without  presenting  a  document  on  the  reader  or  without  stopping  to  interact  with  a  facial 
recognition camera. This is possible because travellers submit their DTC, including biometric data, 
prior to their arrival to the border authorities. As is the case with O1 to O3, the border authorities 
can  verify  the  authenticity  and  integrity  of  the  travel  document  in  advance  as  well  as  carry  out 
certain other checks in support of the border check process. Although the Commission has already 
funded  research  involving  biometric  corridors,  allowing  D4FLY80  to  develop  a  prototype  of  a 
biometric  identity  verification  corridor  which  makes  identity  checks  on  the  move  possible81,   the 
biometric corridor will not be assessed further in this impact assessment. It is currently technically, 

80 D4FLY, Detecting Document Fraud and Identity on the Fly, available online at: https://d4fly.eu/. 
81 CORIDS EU research result, “Smart tools streamline identity verification at border crossing points“, (2022) available 
at:  https://cordis.europa.eu/article/id/442740-smart-tools-streamline-identity-verification-at-border-crossing-
online 
points.  

31 

 
 
legally as well as operationally unfeasible to envisage biometric corridors for checking all travellers 
with a digital travel credential. 

Finally,  the  option  of  obliging  EU  nationals  and  third  country  nationals  to  use  a  DTC  when 
crossing external borders was excluded for reasons of inclusivity, non-discrimination as well as 
the opinions expressed in the public consultation. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

6.1.  Economic impact 

6.1.1.  Impact on EU institutions and agencies 

As regards the economic impact, each option would have an impact on eu-LISA that would need 
to  establish  a  central  solution  for  the  creation  of  DTCs  and  their  submission  to  the  competent 
authorities. 

An application enabling EU citizens and third country nationals to derive the DTC from an existing 
passport  or  identity  card  (for  EU  citizens  only)  and  to  submit  it  to  the  competent  Member  State 
would  have  to  be  developed  and  maintained  centrally,  in  order  to  ensure  interoperability  across 
Member States and for reasons of cost-efficiency.  

In  order  to  submit  the  data  to  the  competent  Member  State  in  a  secure  way,  existing  IT  systems 
should be leveraged to the extent possible. Certain components of the API Router, as provided in 
the new API rules, could be re-purposed for allowing  for a secure transfer of data entered by the 
individual  traveller  through  the  customer-facing  application  to  the  competent  authority.  For  eu-
LISA, it was estimated that an additional budget of around EUR 49.5 million (EUR 6 million under 
current MFF) would be needed for the development, maintenance and  operations of the technical 
solution.  Furthermore  around  20 FTEs  (full-time  equivalents)  will  be  required  between  2027  and 
2030  to  ensure  that  eu-LISA  has  the  necessary  resources  to  perform  the  tasks  attributed  to  it  in 
developing the EU-wide application.  

These costs for the development are more or less the same with all policy options. However, costs 
related  to  the  maintenance  and  additional  services,  such  as  customer  service  and  data  centre 
capacity, grow incrementally from O1 to O3, in view of the increased uptake of DTCs by travellers 
in O2 and O3.  

6.1.2.  Impact on Member States 

As  regards  the  impact  on  Member  States,  in  terms  of  administrative  and  IT  costs,  O1  and  O2 
would not entail any additional costs if they chose not to implement DTCs at their external borders. 
It they did, the additional costs would be essentially the same as in O3.  

Since a central EU solution would be available for the derivation of DTCs, Member States would 
not need to invest in additional hardware or software for this component under any of the options. 
However, existing hardware and software would need to be updated to be able to handle DTCs at 
the  external  borders.  Interviewed  border  authorities  do  not  expect  this  to  be  associated  with  high 
costs,  since  existing  systems  are  able  to  handle  DTCs  due  to  the  backwards  compatibility  of  the 

32 

 
DTC standard. Expected one-off investments pertain to server and storage capacity to temporarily 
store  DTCs  submitted  by  travellers  (EUR  250  00082),  an  integration  into existing  national  border 
management systems  (EUR 300 000 to 700 000 per Member State83), upgrade or procurement of 
hardware84  to  process  DTCs  and  support  facial  recognition  as  well  as  training  of  personnel 
(EUR 30 000 per Member State). With the entry into operation of the EES, Member States should 
already have in place the necessary hardware and software for facial recognition at border crossing 
points.  To  account  for  changes  in  national  setups,  differences  in  technological  maturity  and 
capacities as well as for reasonable overhead, it is estimated that an average of EUR 2 million per 
Member  State  is  required  to  implement  DTCs  at  their  external  borders  (see  Annex  4  for  more 
details). 

Recurrent benefits for Member States include making checks on travel documents during travel 
authorisation and visa application processing and border crossings more efficient, improvements in 
the data quality as well as time saved for border guard personnel on each traveller. Upstreaming the 
checks on the travel document on the basis of the DTC and of persons against different databases 
significantly  decreases  the  time  it  takes  to  check  a  traveller  at  the  border,  when  comparing  to 
checking travellers in the current border check process. Based on statistics from automated border 
control log data and statistics on border checks at manual booths at entry and exit, the average time 
varies  between  30  seconds  and  90  seconds,  depending  on  the  nationality85.  For  travellers  using a 
DTC,  the  average  time  for  the  check  at  the  actual  border  (verification  of  identity  and  proof  of 
carrying the travel document) was 8.8 seconds86. If the reading of the physical travel document is 
skipped  at  exit,  the  average  time  for  the  border  check  at  the  actual  border  was  between  2  and  4 
seconds (verification of identity). Moreover, being able to pre-vet travellers using DTCs allows the 
border authorities to better focus on risk profiles and detect criminals, terrorists as well as victims 
of  human  trafficking  more  effectively.  The  time  and  correspondingly  money  saved  by  Member 
States  depends  on  the  level  of  uptake  of  DTCs.  If  1  in  10  travellers  used  DTCs,  the  financial 
savings  compared  to  the  baseline  scenario  are  8%,  whereas  if  8  in  10  travellers  used  DTCs,  the 
savings would add up to 63%. The economic impact can therefore be rated as positive, albeit it is 
impossible to accurately quantify this in financial terms (see Annex 4 for more details).  

82 Estimated cost according to the Finnish Border Guard for a centralised implementation of additional server capacity 
to host DTCs and process facial images. 
83  In  the  context  of  the  DTC  pilot  project,  Croatian  authorities  estimated  an  integration  cost  of  EUR  300  000.  The 
Finnish Border Guard estimated such an integration to cost EUR 575 000, based on costs of previous integrations into 
national border control applications. 
84 E.g. a single NFC reader needed to read the chip in a travel document costs no more than EUR 300.  
85 Statistics provided by the Finnish Border Guard  in the context of the DTC pilot project. The cohorts included EU 
citizens (the majority being Finnish nationals) and visa-exempt third country nationals using both manual booths and e-
gates. The times for e-gates include entering the e-gate, reading of the passport and its validation, facial recognition as 
well as the consultation of the various databases. The timer stops when the person has passed through the e-gate. The 
duration is also impacted by external factors such as slow movement of some persons, lack of rapid access to the travel 
document (e.g. passport at the bottom of the traveller’s bag) and border checks for minors. These average times only 
take into account the cases where no issues were encountered during the document check or verification of identity as 
they would dramatically increase and distort the average times.  
86 Statistics provided by the Finnish Border Guard in the context of the DTC pilot project. This cohort includes Finnish 
nationals. 

33 

 
 
6.1.3.  Impact on EU citizens 

Under each option, the use of DTCs would be voluntary for EU citizens. The creation and use of a 
DTC  with  the  central  EU  application  would  be  free  of  charge.  If  Member  States  decided  to 
integrate the creation of DTCs into the process of issuing new travel documents upon application, 
national law on application fees applies87.  

EU nationals would be able to reuse their DTCs for their travels, resulting in a one-time investment 
in  terms  of  time  spent  for  each  individual  travel  document.  Depending  on  the  technical  and 
organisational  choices,  it  is  estimated  that  for  all  policy  options  it  would  be  no  longer  than  1-3 
minutes to derive a DTC from an existing travel document88. Owing to the quicker processing of 
travellers using a DTC, also EU nationals who decide to continue using physical travel documents 
will benefit from the accelerated procedures through reduced waiting times at the border for those 
using a DTC. These beneficial impacts increase incrementally from O1 to O3. 

With  regard  to  the  main  concerns  expressed  by  stakeholders  in  the  public  consultation  and 
Eurobarometer  survey,  including  risks  associated  with  data  security/protection,  software  failures 
and device problems89, each option addresses them in an adequate and similar way owing primarily 
to  the  requirement  of  common  technical  standards,  the  establishment  of  a  common  EU  technical 
solution  and  the  applicable  rules  on  data  protection  (see  point  6.2.2.  on  data  protection  for  more 
details). Moreover, due to the voluntary nature of the use of DTCs and the fact that physical travel 
documents  are  still  used,  software  or  device  failures  will  not  negatively  affect  the  traveller’s 
eligibility to cross external borders as they will have a physical travel document to fall back on. The 
risks associated with potential data leaks need to be addressed with high security standards and the 
use  of  technical  methods  for  the  secure  transmission  of  personal  data  through  the  common  EU 
technical solution. 

6.1.4.  Impact on third country nationals 

Under each option, the use of DTCs would be voluntary for third country nationals. The creation 
and use of a  DTC with  the central  EU application would be  free of charge. This  would also not 
have an effect on the fees concerning ETIAS or visa applications. 

Similar  to  EU  citizens,  it  is  estimated  that  for  all  policy  options  it  would  be  no  longer  than  1-3 
minutes  to  derive  a  DTC  from  an  existing  travel  document.  Owing  to  the  quicker  processing  of 
travellers  using  a  DTC, also  third  country  nationals  who  decide  to  continue  using  physical  travel 
documents  will  benefit  from  the  accelerated  procedures.  Due  to  the  possibility  of  pre-enrolling 
additional  data  required  by  the  EES,  instead  of  enrolling  those  data  at  the  border  crossing  point, 
additional time would be saved. These beneficial impacts increase incrementally from O1 to O3. 

87 According to Passport-collector.com, the price of EU and Schengen Associated Country passports vary between EUR 
22 and EUR 264. https://www.passport-collector.com/global-passport-fees/  
88 For example, in the Finnish DTC pilot project, DTC users are required to register with the police for deriving their 
DTC  from  their  passport.  This  takes  a  maximum  of  2-3  minutes.  In  the  Dutch  and  Croatian  DTC  project 
implementations, users can derive their DTC unsupervised and remotely, taking only about a minute to complete. 
89 See Annex 2 for more details. 

34 

 
 
6.1.5.  Impact on industry 

Three  types  of  enterprises  could  be  affected  by  the  implementation  of  DTCs,  notably  those 
involved  in  the  production  of  travel  documents,  those  involved  in  the  provision  of 
infrastructure,  software  and  services  for  border  management  as  well  as  transport  hub 
operators and carriers. However, none of the options envisage any additional financial burden on 
them as the initiative does not impose any obligations on them concerning the introduction of DTCs 
in their workflows.  

Several  private  enterprises  are  involved  in  the  production  of  travel  documents  in  the  EU.  The 
derivation of the ICAO DTC Type 1 would not change the current issuing process of physical travel 
documents.  

There are some enterprises involved in the management of large border control points at airports 
and  seaports90.  There  may  also  be  cooperation  with  private  enterprises  regarding  security  and 
passenger flow control at the airport.  No costs will arise from this initiative for enterprises in the 
field  of  security-related  services  and  other  services  in  the  context  of  digital  travel  and  border 
control  management,  unless  individual  Member  States  or  authorities  would  choose  to  outsource 
some  of  the  activities  to  such  enterprises.  This  can,  however,  not  be  predicted  at  this  stage  and 
would, in any case, in turn have a positive financial impact on those enterprises. 

Carriers91 are currently involved in the collection and transmission of passenger data and conduct 
document checks, in line with their legal obligations under EU and national law.  

At check-in, air carriers check passenger information and travel documents, create API and send it 
to border authorities. There are approximately 1000 air carriers who operate flights to, from and/or 
within  the  EU92.  Under  the  revised  rules  on  API93,  air  carriers  will  be  obliged  to  collect  the  API 
data using “automated means”.  

Air carriers are expected to benefit significantly from the improved data quality facilitated by the 
use  of  digitalised  travel  documents,  both  in  terms  of  less  administrative  burden  as  well  as  less 
penalties for the submission of erroneous API data. In the context of the impact assessment for the 
proposal  on  the  API  Regulation(s),  it  was  estimated  that  sanctions  for  non-compliance  and 
transmission of erroneous API data correspond to a maximum amount of EUR 80 million per year.  

90 In the Netherlands, at the largest border control point (Amsterdam Airport Schiphol), there are several public private 
partnerships with the airport, for example for the implementation of the Entry/Exit System (EES). 
91 Air carriers are obliged to collect and transmit advance passenger information according to the API Directive and the 
future API Regulation; maritime carriers are required to provide information on passengers to the European Maritime 
single  window  in  accordance  with  Regulation  (EU)  2019/1239  of  the  European  Parliament  and  of  the  Council of  20 
June 2019 establishing a European Maritime Single Window environment and repealing Directive 2010/65/EU, OJ L 
198, 25.7.2019, p. 64 and the Schengen Borders Code. Some Member States require, under national law, land carriers 
to submit passenger information. Under the rules on carrier liability, air and sea carriers are required to check  that the 
travellers have the necessary travel documents. 
92 Commission Staff Working Document Impact Assessment Report Proposal for a Regulation of the European 
Parliament and of the Council on the collection and transfer of advance passenger information (API) for enhancing and 
facilitating external border controls SWD(2022) 422 final, 13 December 2022. 
93 The envisaged entry into force of the new API Regulation(s) is 2027. 

35 

 
 
At the same time, a standardisation (through this initiative) of the technical format to be used in that 
area  is  neither  necessary  nor  advantageous,  as  the  check-in  and  onboarding  process  goes,  for  the 
traveller, through the specific software of the carrier, and is not impacted by the technical solution 
for DTCs inspected at external borders.  

During  the  consultation  activities,  industry  representatives  (IATA)  underlined  the  importance  of 
ensuring  the  peaceful  co-existence  of  the  ICAO  DTC  standard  –  for  official/authority  purposes  – 
and  industry  standards,  which  commercial  actors  may  rely  on  in  engaging  with  their  customers, 
while fulfilling their obligations both in relation to the collection and provision of data to competent 
authorities  on  the  one  hand,  and  to  the  respect  of  the  right  to  data  protection  and  privacy  on  the 
other. 

It is already envisaged that air carriers could integrate into their mobile applications the possibility 
e.g., of optically scanning with a smartphone the machine-readable data of the travel document or 
retrieving  the  necessary  data  elements  from  the  chip  of  the  travel  document  or  retrieving  the 
necessary  data  from  the  travellers’  digital  identity  wallet  that  already  contains  an  attribute  with 
those data. Such methods of providing data could also be used by air carriers when implementing 
their  obligations  stemming  from  the  API  Regulations.  While  these  features  are  not  directly 
dependent  on  the  ICAO  DTC  or  this  initiative,  establishing  a  common  EU  standard  (the  ICAO 
DTC) could complement the API Regulations. The main focus of this initiative is on the creation of 
DTCs and their use for the purpose of crossing external borders and of carrying out border checks, 
but as it would standardise the use of DTCs at external borders in all Member States, including the 
possibility to store the DTC in the EUDIW, it would also enable and facilitate the use of DTCs for 
other purposes, e.g., the automated collection of API data.  

Therefore, while not within the scope of this initiative here, Annexes 3 and 4 nevertheless look at 
potential  impacts  of  any  voluntary  DTC  implementations  that  have  as  an  objective  to  allow  for 
quicker and more accurate processing, in order to demonstrate in more detail how the DTC will be 
situated in the overall framework of already existing travel regulations. 

There  are  no  direct  impacts  for  SMEs  (outside  of  the  travel  domain).  Despite  time  savings  for 
individual  travellers,  including  business  persons,  any  indirect  impact  on  SMEs,  for  whom  these 
business persons might be travelling, is too remote to measure at this point.  

Due  to  the  difficulty  to  quantify  in  financial  terms  the  possible  indirect  benefits  to  both  large 
companies and SMEs, the ex-post evaluation should explore these benefits in more detail. 

6.2. 

Social impact 

6.2.1.  Impact on security 

O1  to  O3  would  introduce  DTCs  at  the  external  borders  with  varying  levels  of  obligation,  and 
therefore, amount of uptake. The implementation of DTCs under each policy option would enable 
the  border  authorities  to  carry  out  advance  checks  on  travel  documents,  reduce  bottlenecks  at 
border crossing points during peaks and plan their resources and operations more effectively.  For 
land  borders,  the  introduction  of  DTCs  would  allow  authorities  for  the  first  time  to  know  the 
identity of those travelling with DTCs in advance, as – contrary to air borders – there is currently 
no advance sharing of data on travellers  crossing  land borders. For sea  borders, the DTC would 
expand the current  scope of travellers known in advance,  as in  particular travellers on ferries are 

36 

 
excluded  from  current  systems  on  advance  traveller  information94.  However,  also  air  borders 
would benefit from each policy option, since border authorities are not obliged to carry out checks 
on the basis of API data received from air carriers. Similarly, they would not be obliged to do so on 
the basis of O1 and O2. With O3, border authorities at all types of border crossing points would be 
obliged  to  carry  out  advance  checks  against  the  pre-submitted  DTC  and  travel  data  and  to 
effectively ‘pre-clear’ or ‘pre-flag’ travellers for expedited entry/exit or a second line inspection. 

The expected increased security brought by each policy option relies on the fact that several checks, 
including the verification of the authenticity and integrity of the travel document, can be carried out 
reliably in advance of travel. Traffic across border crossing points is not stable but is rather marked 
by  troughs  and  peaks.  Correspondingly,  the  shortcomings  currently  observed  in  Schengen 
evaluations that are often linked to the fact that border authorities lack the capabilities to carry out 
systematic  checks  on  all  travellers  on  the  spot  especially  during  peak  times  of  travel  could  be 
remedied. With the introduction of DTCs, these checks can be carried out in advance, providing the 
authorities with more time to focus on risk profiles and carry out systematic checks on the travellers 
that did not submit their DTC, with varying degrees of uptake of DTCs per policy option. This is 
expected to bring benefits in terms of improved detection of cross-border criminal activities at all 
types of border crossing points. 

O3 would have the biggest impact on these aspects as the Member States would be obliged to allow 
both EU national and third country national travellers to submit their DTCs for advance checks. O3 
would distribute the benefits of the introduction of DTCs at the external borders to each Schengen 
country.  

The  risks  associated  with  the  use  of  DTCs  remain  the  same  as  with  the  use  of  physical  travel 
documents.  Due  to  the  cryptographic  link  between  the  DTC  (Type  1)  and  the  physical  travel 
document  on  which  it  is  based,  authorities  are  able  to  detect  clones.  As  long  as  the  inspection 
systems  deployed  by  authorities  have  the  necessary  certificates  to  validate  the  authenticity  and 
integrity of travel documents, including digital ones, the main risk associated with their use pertains 
to  look-alike  fraud  (impostor  fraud).  In  addition  to  having  facial  images  in  travel  documents  and 
DTCs,  travel  documents  issued  by  Member  States  continue  to  contain  fingerprints,  while  DTCs 
under  the  ICAO  DTC  Type  1  standard  do  not.  Fingerprints  of  third-country  nationals  will  be 
collected and stored in the Entry/Exit system following its start of operations. An effective measure 
to counter look-alike fraud, is for border authorities to carry out a match of this additional biometric 
data against the live fingerprints of the person. 

6.2.2.  Protection of personal data 

First,  in  terms  of  protection  of  personal  data  and  the  purposes  of  processing,  it  should  be 
recalled  that  border  authorities  already  process  personal  data  of  persons  crossing  the  external 
borders,  as  do  issuing  authorities  when  issuing  travel  documents.  Secondly,  it  should  be  stressed 
that the amount of personal  data processed  under  each option  does not change  compared to 
the status quo. It is only the temporal element of data processing that changes, by upstreaming the 

94  Maritime  carriers  are  required  to  provide  information  on  passengers  to  the  European  Maritime  single  window  in 
accordance  with  Regulation  (EU)  2019/1239  of  the  European  Parliament  and  of  the  Council  of  20  June  2019 
establishing  a  European  Maritime  Single  Window  environment  and  repealing  Directive  2010/65/EU,  OJ  L  198, 
25.7.2019, p. 64. This does not apply e.g. to ferries. 

37 

 
 
verification  of  the  authenticity  and  integrity  of  the  travel  document  and  the  consultation  of 
databases.  Both  the  purposes  of  processing  and  the  categories  of  personal  data  processed 
remain unchanged. For third country nationals, part of the assessment and verification of the entry 
conditions could similarly be done in advance of the person actually arriving at the border crossing 
point. 

An overarching benefit of all three policy options is that they would improve the data quality and 
make it easier to identify travellers correctly.   

Despite  the  use  of  a  central  EU  solution  under  each  option,  the  DTC  would  not  be  centrally 
stored  nor  would  there  be  any  new  EU  database  on  passports  or  identity  cards.  Once  the 
credential is created/derived from an existing travel document, it would be stored on the person’s 
device. Data subjects therefore remain in control of their own data and choose if and when to use it. 
If the person chooses to use it for an advance check and facilitated travel, they can submit it via the 
application to the competent authorities. While it is difficult to ascertain the exact roles before the 
adoption of the proposal, it is likely that Member States would be considered joint controllers in the 
sense of Article 26 of Regulation (EU) 2016/679 (the General Data Protection Regulation, GDPR), 
while  the  EU  agencies  responsible  for  developing  the  IT  infrastructure  would  likely  be  data 
processors in the sense of Article 3(12) of Regulation (EU) 2018/1725.  

Appropriate  safeguards,  such  as  encryption  of  personal  data  and  cybersecurity  measures, 
should  be  employed  to  prevent  data  leaks  and  breaches  and  to  protect  against  cyberattacks  and 
software applications that run automated tasks. 

The facilitated travel use case for both EU nationals and third country nationals under  all options 
requires the temporary storage of the pre-submitted DTC submitted by the user in a local database 
in the competent Member State. This temporary database/gallery would be populated with the facial 
images that are contained in the pre-submitted DTCs. This is necessary to biometrically match the 
traveller to  the pre-submitted DTC  as  he or she presents  him/herself at  the border crossing point. 
This entails a one-to-few match with a view to verifying the identity of the person, as opposed to a 
one-to-many biometric  matching  for identifying an individual.  Once the border check has been 
carried out, the data should be deleted from the temporary database. 

Under  all  options,  the  EU  system  would  introduce  uniform  data  processing  practices  that  would 
apply to all Member States. However, under O1 and O2 it would be up to individual Member States 
to  decide  whether  they  allow  persons  to  submit  their  DTC  in  advance  and  benefit  from  travel 
facilitations. O3 would oblige all Member States to do so. All options would nonetheless have the 
benefit of establishing a uniform format for the DTC in itself, ensuring its compatibility across the 
EU as well as the necessary security elements to the DTC and the EU-wide application, to protect 
the data from unlawful use, data leaks and cyberattacks. 

The  use  of  DTCs  would  be  voluntary  for  individuals  in  all  options.  Therefore,  in  addition  to 
border authorities having the legal basis under both EU and national law to process personal data, 
including  biometric  data,  in  the  context  of  border  checks,  individual  travellers  would  provide 
their consent to the processing and the temporary storage of their DTC in the local database of 
the competent authority. Consent may at any time be revoked without affecting the person’s right to 
travel or cross borders.  

38 

 
This  issuance  and  creation  of  DTCs  will  lead  to  the  processing  of  personal  data  (including 
biometric  data,  namely  the  facial  image  of  the  holder  of  the  DTC).  The  obligation  to  include  a 
facial  image  in  the  DTC  issued  on  the  basis  of  identity  cards  constitutes  a  limitation  to  both  the 
right  to  respect  for  private  life  and  the  right  to  the  protection  of  personal  data95.  Limitations  on 
those rights must be provided for by law and must respect the essence of those rights. In addition, in 
compliance  with  the  principle  of  proportionality,  such  limitations  may  be  made  only  if  they  are 
necessary and genuinely meet objectives of general interest recognised by the Union or the need to 
protect the rights of others96. 

In this context, the applicable EU legislation97, notably the provisions on the protection of personal 
data in the context of physical passports and identity cards, would apply. The limitations, as well as 
the  conditions  for  application  and  scope  of  those  limitations,  will  thus  be  laid  down  in  EU 
legislation.  The  obligation  to  include  the  facial  image  of  the  holder  does  not  adversely  affect  the 
essence of the fundamental rights enshrined in Articles 7 and 8 of the Charter, as the information 
provided by the facial image does not, in itself, make it possible to have an overview of the private 
and family life of data subjects98. 

The inclusion of the facial image in the DTC is intended to enable the holder of that credential to be 
reliably identified by comparing their facial image to that in the DTC when the DTC is presented, 
and thus to combat document fraud, which is an objective of general interest recognised by the EU, 
as also confirmed by the Court of Justice99.  

The  inclusion  of  the  facial  image  in  the  DTC  is  appropriate  for  attaining  the  general-interest 
objective of combating document fraud, as it is a means to reliably verify the identity of the holder 
of the DTC, and thereby to reduce the risk of fraud.  

This is not called into question by the fact that DTCs do not, unlike physical passports or identity 
cards, include the fingerprints of the holder, because DTCs are used in combination with a physical 
document rather than replacing them. If they have doubts as to the authenticity of the DTC or the 
identity of the holder, competent  authorities retain  the possibility to  use the fingerprints stored in 
the  chip  of  the  passport  or  identity  card.  There  are  currently  no  standards  for  the  inclusion  of 
fingerprints in DTCs, and due to the cryptographic protection of fingerprints, it is in any event not 
possible to extract them from the chip of the passport or identity card. 

95/46/EC 

(General  Data  Protection  Regulation) 

95 Judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251, paragraphs 73 to 74. 
96 Judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251, paragraph 76. 
97  Regulation  (EU)  2016/679  of  the  European  Parliament  and  of  the  Council  of  27  April  2016  on  the  protection  of 
natural persons with regard to the processing of personal data  and on the free movement of such data, and repealing 
1,  ELI: 
Directive 
http://data.europa.eu/eli/reg/2016/679/oj) and Directive (EU) 2016/680 of the European Parliament and of the Council 
of  27  April  2016  on  the  protection  of  natural  persons  with  regard  to  the  processing  of  personal  data  by  competent 
authorities  for  the  purposes  of  the  prevention,  investigation,  detection  or  prosecution  of  criminal  offences  or  the 
execution of  criminal  penalties,  and on  the  free  movement  of  such  data,  and  repealing Council  Framework  Decision 
2008/977/JHA (OJ L 119, 4.5.2016, p. 89, ELI: http://data.europa.eu/eli/dir/2016/680/oj). 
98 See also judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251, paragraphs 80 
to 81. 
99 Judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251, paragraph 87 and case-
law cited. 

4.5.2016, 

(OJ  L 

119, 

p. 

39 

 
 
The inclusion of the facial image is also necessary to attain the general interest pursued. Without its 
inclusion, the DTC would only contain biographic data of the holder (such as name, date of birth, 
etc.), which is not a reliable and effective means of identification. 

In addition,  DTCs will not  contain personal  data that are not  already contained in  the chip  of the 
passport or identity card on the basis of which it is issued. In fact, they will contain fewer personal 
data, given that the DTC does not contain the fingerprints of the holder. 

As  already  noted  by  the  Court  of  Justice  in  Landeshauptstadt  Wiesbaden  on  physical  identity 
cards100, the limitations resulting from the inclusion of such biometric data are not – having regard 
to the nature of the data at issue, the nature of the processing operations, the manner in which they 
are  carried  out  and  the  safeguards  laid  down  –  of  a  seriousness  that  is  disproportionate  when 
compared  with  the  significance  of  the  objective  pursued.  Accordingly,  such  a  measure  must  be 
regarded as being based on a fair balance between, on the one hand, those objectives  and, on the 
other,  the  fundamental  rights  involved.  As  a  result,  the  limitations  on  the  exercise  of  the  rights 
guaranteed in Articles 7 and 8 of the Charter are not contrary to the principle of proportionality. 

Under all options, the necessity to carry out a data protection impact assessment should be carefully 
considered by the competent authorities, in light of Article 35 of the GDPR. 

None of the options envisage international data transfers within the meaning of the GDPR. 

6.2.3.  Protection of fundamental rights 

In  terms  of  impacts  on  fundamental  rights  other  than  the  right  to  privacy  and  the  protection  of 
personal data, none of the options would affect the protection of fundamental rights negatively. O1 
to O3 would make the use of DTCs voluntary for individuals, therefore allowing people to choose 
between  having  or  not  a  DTC  and  between  using  it  or  not.  Some  persons  may  be  unwilling  or 
unable  to  use  a  DTC  due  to  personal  reasons,  low  IT  literacy,  disabilities  or  e.g.  not  owning  a 
device  necessary  for  its  use.  Each  policy  option  would  allow  persons  to  undergo  border  checks 
within  the  current  framework  and  they  too  would  potentially  benefit  from  shorter  waiting  times, 
due  to  the  fact  that  others  have  opted  in  to  use  the  DTC,  freeing  up  capacities  and  shortening 
queues at border crossing points. Therefore, the principles of non-discrimination and inclusivity are 
respected in each policy option. 

With  regard  to  EU  citizens  and  their  exercise  of  the  right  to  free  movement,  O3  would  oblige 
Member  States  to  facilitate  the  travel  of  DTC  users,  while  O1  and  O2  would  leave  it  up  to 
individual Member States to decide. Overall, all options are expected to have a positive impact on 
the practical exercise of the right to free movement, albeit to a varying extent. 

Similarly,  regarding  the  detection  of  cross-border  crime  and  of  crimes  like  child  abduction,  O3 
would  enable  border  authorities  to  carry  out  several  checks  in  advance  of  persons  arriving  at  the 
border crossing point and to be better prepared to deal with those cases, while in O1 and O2, the 
use of DTCs would be dependent on the Member State. 

100 
125. 

Judgment of 21 March 2024, C-61/22, Landeshauptstadt Wiesbaden, ECLI:EU:C:2024:251, paragraphs  106-

40 

 
 
Any  possible  negative  outcome  regarding  the  use  of  DTCs  under  the  options,  e.g.  concerning 
refusal of entry at the border, data breach or unlawful use of the DTC would be subject to the 
already applicable remedies under EU and national law. 

6.3.  Environmental impact 

No  significant environmental  impacts are  expected  from  this  initiative.  The  initiative  is  not 
expected to  have an impact  on the volume of travel as none of the policy options would have an 
impact  on  the  availability  of  travel  e.g.,  by  virtue  of  an  increased  frequency  of  scheduled  routes, 
lower prices or lesser immigration-related requirements. The identified policy options will as such 
not  affect  the  emissions  of  greenhouse  gases  in  the  atmosphere  by  transport  operators,  or  the 
anticipated  demand  for  passenger  transportation.  DTCs  under  O2  and  O3  will  not  fully  replace 
physical  travel  documents.  Despite  some  additional  digital  data  processing,  the  identified  policy 
options  will  not  as  such  affect  the  emissions  of  greenhouse  gases  in  the  atmosphere.  Moreover, 
ensuring  a  centralised  solution  for  the  creation  and  submission  of  DTCs,  as  envisaged  under  all 
policy  options,  will  lead  to  lesser  data  centre  capacity  needs  than  the  sum  of  all  capacities  the 
Member States would need to secure individually.  

7.  HOW DO THE OPTIONS COMPARE? 

To determine the preferred option, the policy options have been assessed and compared against the 
baseline scenario 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; 

▪  Coherence, i.e., the complementarity, overlaps and gaps in the proposed policy options with 

regard to existing initiatives and systems; 

▪  Proportionality, i.e., the extent to which each policy option is limited to what is necessary to 

achieve the objectives. 

7.1.  Effectiveness 

For each policy option, an assessment was carried out of the expected effectiveness in achieving the 
policy objectives compared to the baseline scenario, addressing the advantages and disadvantages 
with a scoring of -3 to +3, ranging from very negative impact to very positive impact. The different 
criteria  are  assessed  in  how  they  help  attain  the  general  and  specific  objectives.  The  uptake 
percentages on the use of DTCs per policy option is  projected based on the availability or not  of 
DTCs (ranging from a few to all Member States making DTCs available along with the associated 
travel facilitations) and the results of the stakeholder consultations. 

Given that all policy options contain similar characteristics with varying combinations of voluntary 
and  mandatory  implementation,  the  effectiveness  of  the  options  vary  in  degree  when  compared 
against  the  baseline.  However,  all  options  entail  an  improvement  compared  to  the  baseline  by 
ensuring,  at  least,  under  O1,  that  the  same  (global)  standard  is  used  if  Member  States  decide  to 
implement DTCs (limited positive impact 0.5). With mandatory implementation under O2 and O3, 
i.e. creating the availability for all EU citizens to  have a DTC, both  options are effective in  their 
contribution  to  digital  development  across  the  EU  and  for  fostering  trust  between  the  Member 

41 

 
States  through  a  harmonised  framework.  However,  only  O3  would  ensure  a  fully  harmonised 
approach to the use of DTCs at the external borders, bringing the most added value, effectiveness 
and  consistency  (positive  impact  1.5)  as  opposed  to  O2  with  voluntary  use  of  DTCs  at  external 
borders (medium positive impact 1.0).  

For  O1  and  O2,  travel  facilitation  provisions  with  the  use  of  DTCs  is  voluntary  for  the  Member 
States.  Without  the  commitment  to  undertake  the  facilitation  for  travel  with  DTCs,  the  outcome 
would be fragmented, leading to only limited security and facilitation benefits in practice, due to an 
only partial implementation of the measures  at the external borders. If only a handful of Member 
States  implement  DTCs  at  their  external  borders,  the  objective  of  smoother  travel  is  severely 
hampered,  which  potentially  will  have  a  negative  impact  on  the  overall  uptake  of  DTCs  among 
travellers, since there will be less reason to “opt-in”. 

Table 1: Overview of the effectiveness assessment 

Option 

Advantages 

Disadvantages 

Score  

(-3 to +3) 

Baseline: 

• 

The  EU  and  its  Member  States  can  wait  for  know-

• 

Potential for lost or delayed opportunities linked 

0 

Status quo 

how and implementation lessons learned from other 

to  the  digitalisation  of  travel  documents  and  the 

countries regarding the implementation of DTCs and 

facilitation of travel 

the facilitation of travel before working on their own 

solutions 

• 

Potential interoperability problems regarding 

seamless travel 

O1:  

• 

Implementation  of  ICAO  Type  1  DTC  as  the 

• 

Lowest  level  of  uptake  of  DTCs  (0-10%)  and 

0.5 

common  standard  across 

the  Member  States, 

measures  to  facilitate  travel,  resulting  in  lower 

allowing  Member  States  to  decide  if  citizens  may 

effectiveness gains across key indicators 

have a DTC (GO1-3, SO1-2) 

• 

Enhanced  quality  of  passenger  data,  improving 

across  the  Schengen  area,  given  the  fact  that 

border  efficiency  of  border  checks  and  security 

some  Member  States  might  use  the  DTC  while 

• 

Lowest  level  of  harmonisation  and  uniformity 

(GO1-2, SO1) 

• 

Faster  border  checks  for  both  EU  travellers  and 

TCNs  would  result  in  lower  waiting  times  (GO3, 

SO2) 

others  will  not.  This  is  likely  to  result  in 

significant  fragmentation  across  the  Schengen 

area,  limiting the potential benefits of DTCs and 

the facilitation of travel 

• 

Lowest level of digital maturity in the Schengen 

• 

Enhanced digital  maturity  across  the  Schengen area 

compared to the baseline (GO2, SO1-2) 

border checking process 

O2:  

• 

The  mandatory  implementation  of  DTCs  results  in 

•  Medium  level  of  uptake  of  DTCs  (15-25%)  and 

1  

the same benefits as  O1, but to a greater extent due 

measures  to  facilitate  travel  by  travellers  can  be 

to increased uptake (GO1-3, SO1-2) 

expected, as the benefits from using the DTC are 

•  Harmonisation  and  uniformity  across 

the  EU 

regarding  the  implementation  of  DTCs  (GO1-3, 

reduced,  compared  to  O3.  This  reduced  uptake 

will  result  in  lower  effectiveness  gains  across 

key indicators  

42 

 
  
SO1-2) 

•  Medium  level  of  harmonisation  and  uniformity 

across  the  Schengen  area,  still  resulting  in 

significant  fragmentation  limiting  the  potential 

benefits of DTCs and the facilitation of travel 

•  Medium level of digital maturity in the Schengen 

border checking process 

O3:  

• 

The  mandatory 

implementation  of  DTCs  and 

1.5 

facilitation  of  travel  results  in  the  same  type  of 

benefits  as  O1  and  O2,  but  to  the  highest  possible 

degree across the three options, given the maximum 

uptake (60% +) (GO1-3, SO1-2). However, a higher 

score  is  not  warranted  as  an  even  higher  uptake 

could  be  achieved  by  making  the  use  of  DTCs 

mandatory.  

•  O3  is  the  only  option  with  a  complete  level  of 

harmonisation and uniformity across the EU for both 

the implementation of Digital Travel Credentials and 

the facilitation of travel (GO1-3, SO1-2) 

7.2.  Efficiency 

This  section  compares  the  estimated  costs  and  benefits  of  the  policy  options  for  the  different 
stakeholders. Not all potential costs or benefits are quantifiable. For example, cumulative savings in 
time  for  the  authorities  carrying  out  border  checks  ultimately  means  more  efficient  resource 
management and increased security. However, it is nearly impossible to quantify these savings in 
money due to differences between the responsible national authorities in organisational setups and 
in  staff  costs,  and  due  to  the  nature  of  the  recurrent  benefits,  particularly  regarding  increased 
security through better detection of cross-border crime and document fraud. Similarly, the possible 
procurement  of  infrastructure  to  process  DTCs  for  border  crossing  points  would  vary  from  one 
Member State and from  one border crossing point to the next, depending on existing capabilities, 
contractual relationships and choice of technical implementation. Also in this respect, it is therefore 
not possible to provide absolute amounts (see Annexes 3 and 4). 

An  assessment  was  carried  out  of  the  expected  efficiency  of  each  policy  option,  addressing  the 
advantages and disadvantages with a scoring of -3 to +3, ranging from very negative impact to very 
positive  impact.  In  terms  of  additional  investments  for  border-crossing  points,  O1  and  O2  would 
not oblige any since Member States could opt-in and allow the use of DTCs for crossing external 
borders. In fact, O1 and O2 would not envisage any additional costs for Member States, as while 
the ‘issuance’ of DTCs would be voluntary in O1 and mandatory in O2, even in the latter, Member 
States would only have to allow persons to have DTCs (i.e. legally allow them to do so), but there 
would  be  no  requirement  to  integrate  them  into  technical  procedures  operated  by  the  Member 
States, like border checks. O3 would envisage the greatest implementation costs for Member States 
owing  to  its  mandatory  nature,  i.e.  obliging  Member  States  to  ensure  that  their  border  crossing 

43 

 
 
 
points  are  capable  of  handling  DTCs  and  building  the  necessary  integrations  into  the  central  EU 
system. On the other hand, O3 also bears the highest recurrent benefits for Member States with the 
highest uptake of DTC use and economies of scale.  

For eu-LISA, all policy options are similar in terms of financial impact.  The level of maintenance 
and data centre capabilities may need to be adjusted as the user volume increases, which also mean 
incrementally higher costs from O1 to O3. Despite the costs associated with the development and 
maintenance  of  such  an  application  at  EU  level,  it  is  highly  likely  that  the  costs  would  be 
significantly higher if individual Member States were to create local solutions, not to mention the 
difficulties  with  regard  to  interoperability  and  user  experience  if  travellers  need  multiple 
applications depending on the Member State of travel. 

Table 2: Overview of the efficiency assessment 

Option 

Advantage 

Disadvantage 

Score 

Baseline  •  No costs associated with the 

implementation of DTCs or the 
facilitation of travel, which 
primarily entails one-off costs 

O1 

•  Significant recurrent benefits due 

to the improvement in data quality  

•  Significant recurrent benefits for 
Member States that decide to 
implement DTCs and facilitate 
travel 

•  Lack of recurrent benefits 
for Member States given 
the administrative burden 
associated with border 
checks 

•  Relatively lower benefits 
given the lowest level of 
uptake across the three 
Policy Options  

0 

0.5 

O2 

•  Significant recurrent benefits due 

•  Relatively higher 

1 

to the improvement in data quality  

•  Significant recurrent benefits for 
Member States that decide to 
facilitate travel with DTCs 

implementation costs 
(estimated at EUR 2 
million per MS) given the 
increased uptake 
compared to O1 

•  Lower recurrent benefits 
for enterprises and 
Member States compared 
to O3 

O3 

•  Highest recurrent benefits due to 
the improvement in data quality  

•  Highest recurrent benefits for 

Member States due to the highest 
level of uptake 

•  Higher implementation 

1.5 

costs (estimated at EUR 2 
million per MS) across 
the options due to the 
highest degree of uptake  

44 

 
 
 
 
 
7.3.  Coherence 

The different policy options were designed to improve, harmonise and facilitate travel to and from 
the  Schengen  area.  More  specifically,  they  aim  to  ensure  a  smoother,  more  secure  and  reliable 
journey for travellers, border authorities and ultimately the whole Schengen area. The integration of 
the measures envisaged under the different policy options with existing systems (legal framework, 
technical systems, operational implementation) at international, EU and national level is therefore 
essential for effectively developing this policy area. This section on coherence considers the extent 
of  complementarity,  overlaps  and  gaps  relative  to  existing  systems  relevant  for  this  impact 
assessment. 

Coherence at international level 

Given the global use of as well as the dependence on ICAO standards and specifications for travel 
documents, all policy options rely on the already existing ICAO standards for DTCs, making them 
compatible  with  existing  international  travel  documents.  The  verification  of  DTCs  relies  on  the 
same technology,  notably public key infrastructures, as is  the case  for physical  travel  documents. 
Outside  the  EU,  the  ICAO  DTC  standards  have  already  been  employed  in  international  pilot 
projects, e.g. in Canada and Aruba. 

O1, consisting of a voluntary introduction and voluntary use of DTCs, bears the risk that Member 
States will not follow the international trend of digitalisation in this sphere, leading to a low uptake 
of the DTC in the Schengen area overall, as the benefits for travellers are limited. This would, in 
the  longer  run,  be  likely  to  create  a  divergence  in  the  level  of  digitalisation  as  well  as  travel 
facilitation between the Schengen area and third countries. O2, while ensuring that people can have 
DTCs that are digitally compatible, bears the risk that, due to limited advantages linked to the use 
in some Member States, again a gap in acceptance and use between the situation in the Schengen 
area  and  that  at  international  level  with  appear  in  the  longer  run.  O3,  obliging  Member  States  to 
accept  DTCs  in  international  travel,  ensures  compatibility  in  the  area  of  digitalisation  of  travel 
documents  and  travel  facilitation,  makes  it  the  most  coherent  policy  option  in  relation  to  the 
international level. 

Finally,  with  the  inclusion  of  TCNs  in  the  scope  of  all  policy  options,  all  options  significantly 
contribute to the acceptance of use of DTCs globally. Being the first to adopt legislation on the use 
of DTCs in international travel, the EU can moreover set an example for other countries that intend 
to implement digital identity and digital travel credential schemes for international travel purposes, 
and has thus the chance to shape future internationally used solutions.  

Coherence at European level 

The  coherence  of  the  policy  options  at  European  level  is  assessed  from  a  legal  and  technical 
perspective. The legal framework in this context involves Council Regulation (EC) No 2252/2004 
(the  Passport  Regulation),  Regulation  (EU)  2019/1157  on  identity  cards101  and  Regulation  (EU) 
2016/399  (the  Schengen  Borders  Code).  The  assessment  from  the  technical  perspective  will 
consider existing and planned EU initiatives in the area of external borders and digital identity. 

101 As well as its possible future replacement, following the Commission’s proposal for a new Regulation, COM(2024) 
316 final. 

45 

 
 
All  policy  options  remain  largely  interoperable  with  existing  legislation  as  they  assume  the 
introduction of the ICAO DTC standard. However, it would be necessary to amend or complement 
existing  EU  law  on  passports  and  identity  to  provide  for  the  issuance,  technical  standards, 
verification  and  use  of  DTCs  for  official  purposes,  such  as  in  the  context  of  border  checks. 
Therefore, for O1, the legislation should include an obligation that if Member States decide to the 
creation and/or use of DTCs, it must be an ICAO-compliant DTC. For O2-O3, the legislation would 
need  to  oblige  the  Member  States  to  provide,  upon  request,  ICAO-compliant  DTCs  to  their 
nationals.  

For O1 and O2 it would be voluntary, and for O3 mandatory to facilitate external border crossings 
with  the  use  of  DTCs.  Therefore,  each  policy  option  would  require  a  targeted  amendment  of  the 
Schengen Borders Code to enable border authorities to carry out pre-arrival border checks based 
on  the  DTC  data  submitted  by  travellers,  and  to  acknowledge  the  legal  nature  of  DTCs  in  that 
context (“may” vs “shall” clause). As a well-functioning Schengen area relies on  uniform criteria 
on controls on entry and exit at the common external borders, O3 provides the most coherence, as it 
would  facilitate  the  crossing  of  the  external  borders  for  all  travellers  using  DTCs  throughout  the 
entire Schengen area.  

From  a  technical  perspective,  all  options  can  support  the  implementation  of  several  existing  or 
planned initiatives in  the space of digital identity and border management.  The EUDIW  requires 
electronic attestations (e.g., e-prescriptions, mobile driving licence) for it to bring value – otherwise 
it  is  an  empty  wallet.  The  DTCs  of  EU  nationals  could  be  stored  on  the  EUDIW,  making  them 
accessible and convenient to use across the EU, owing to the mandatory and EU-compatible nature 
of  the  EUDIW.  All  policy  options  are  coherent  with  the  Digital  Identity  Regulation,  but  the 
intensity in the use of DTCs varies between the three options. O1 assumes a voluntary introduction 
of  DTCs,  generating  the  least  synergy  of  the  three  policy  options.  O2  assumes  a  mandatory 
introduction of DTCs, i.e. that any citizen can have one, bears a larger uptake of DTCs and more 
synergies  with  the  digital  identity  framework.  O3,  in  addition  to  assuming  the  mandatory 
introduction of DTCs, would also create a legally sound and harmonised use case of DTCs (the pre-
arrival  border  check  and  facilitated  travel),  therefore  increasing  their  uptake  and  generating  the 
greatest synergies with the proposed European identity framework across all Member States. 

The  immigration  procedures  at  EU  level,  notably  consisting  of  travel  authorisations,  visas  and 
residence permits, as well as the large-scale IT systems that support the implementation of the EU 
acquis  in  the  area  of  borders  and  immigration,  rely  on  physical  travel  document  data.  During 
various data collection and application phases, data is manually entered. By integrating DTCs into 
the workflows concerning visa or ETIAS applications, pre-registration of data for EES or collection 
of API data, the collection of travel document data can be further automated, ensuring its accuracy 
and integrity. Moreover, with the use of DTCs in these processes,  the validity and authenticity of 
travel  documents  can  be  checked  in  advance,  which  is  currently  not  the  case.  For  example,  visa 
applicants who are already known to the authorities (previous visa history and record in VIS) could 
potentially  apply  for  a  subsequent  visa  even  with  a  new  passport  without  appearing  in  person  to 
present it, which is not the case envisaged under the Commission proposal on the digitalisation of 
the  visa  procedure.  There  is  an  already  existing  (mobile  and  desktop)  application  for  submitting 
ETIAS applications and Frontex is currently developing a pilot application for the purpose of pre-
registering data for EES. The functionality of deriving the DTC from an existing travel document 
can be added to those applications with relative ease. 

46 

 
The ranking of the options is similar as above in relation to the Digital Identity Regulation, with O3 
offering the most coherence from a technical perspective. It would allow travellers with DTCs to 
interact with these existing (or planned) processes in a more effective and efficient way, reducing 
the number of physical touchpoints and interactions and ensuring a harmonised approach across the 
Member States. O1 and O2 would lead to situations where one Member State would accept a TCN 
traveller’s DTC for the purpose of pre-registering data for EES while another would not, creating 
wide discrepancies as well as confusion.  

Coherence at national level 

From  a  national  perspective,  the  introduction  of  DTCs  does  not  require  any  major  legislative 
changes  at  the  national  level.  Some  Member  States  have  restricted  the  access  to  the  chip  data  of 
travel  documents  to  certain  categories  of  persons  or  for  certain  purposes  only.  From  a  legal 
perspective, O1 would be most coherent as it would leave it up to Member States to decide whether 
or not to introduce DTCs in the first place, while O2 and O3 would require at least some changes at 
national  level.  O3  would  be  least  coherent  with  the  national  legislative  framework  since  it 
envisages the most amendments of all policy options, owing to its mandatory nature. 

The introduction and use of DTCs has technical implications for Member States, in particular with 
regard to adjusting border checking equipment and systems to cater for DTCs. However, as stated 
above  in  relation  to  financial  impacts,  these  changes  are  not  major  due  to  the  interoperability  of 
DTCs with current inspection devices, and therefore all policy options can be considered coherent 
with the existing infrastructure. More technical and operational changes are however envisaged for 
the reception of DTC data submitted via the EU application and their processing (pre-arrival border 
checks). Technically, O1 would be most coherent with the status quo as no changes are forced on 
Member  States.  O2,  presuming  the  mandatory  introduction  of  DTCs  and  their  voluntary  use 
(depending on Member State) at the external borders does not entail any mandatory changes to the 
national  border  systems  either,  making  it  more  coherent  with  the  current  situation  than  O3, 
requiring the most changes out of all policy options.  

Despite the impact on national systems, 65% of Member States surveyed answered that it should be 
mandatory  to  accept  DTCs,  and  71%  responded  that  it  should  be  mandatory  to  enable  the  use  of 
DTCs for facilitated travel. 

The following table summarises the advantages and disadvantages of each policy option compared 
to the baseline with respect to the coherence assessment. 

Table 3 Coherence of the Policy options 

Option 

Advantages 

Disadvantage 

Score  

(-3 to +3) 

Baseline 

Coherent by definition 

 Coherent by definition 

0 

O1  

• 

Coherent  with  ICAO  Travel  Document  Standards 

• 

Limited  digitalisation  of  travel  document 

2 

47 

 
  
and including TCNs 

information in the EU 

• 

Largely coherent with EU legislation 

• 

Requires legal changes at EU level 

• 

Coherent  with  EU  technical  systems  (albeit  the 

• 

Impacts the legal systems of those Member 

lowest level of potential for synergies with ongoing 

States  which choose to opt in 

initiatives) 

• 

Coherent with national technical systems 

O2 

• 

Coherent  with  ICAO  Travel  Document  Standards 

• 

Limited  digitalisation  of  travel  document 

 1 

and including TCNs 

information in the EU 

• 

Coherent  with  EU  technical  systems  (and  medium 

• 

Requires  legal  changes  at  EU  level  and 

potential for synergies) 

impacts Member States’ legal systems  

• 

Requires  changes  in  national  technical 

systems 

O3 

• 

Coherent  with  ICAO  Travel  Document  Standards 

• 

Requires  most  legal  changes  at  EU  level 

2 

and including TCNs 

and impacts Member States’ legal systems 

• 

Coherent  in  relation  to  international  initiatives  on 

• 

Requires  most 

changes 

in  national 

digitalisation of travel document information 

technical systems 

• 

Coherent  with  EU  technical  systems  (and  high 

potential for synergies) 

7.4. 

Proportionality 

Under this criterion, the aim is to assess the extent to which each policy option is limited to what is 
necessary to achieve the objectives of the initiative. This includes determining whether the scope of 
the  option  targets  aspects  that  could  not  be  achieved  without  EU  intervention,  establishing  if  the 
option  would  be  sufficiently  effective  and  estimating  whether  the  option  would  be  as  simple  as 
possible to achieve the objectives. 

If the EU does not implement any of the policy options, the problems described above in detail will 
continue to exist. The current processes rely on checks at physical BCPs only once travellers arrive, 
without the possibility for advance checks to pre-clear travellers. The lack of a common approach 
to this issue – allowing pre-arrival checks and smoother travel – hampers the effective management 
of the common external borders. This applies to all policy options. 

Compared to the baseline scenario, all options are considered better. Implementing the ICAO DTC 
standard  is  crucial  for  global  interoperability  and  for  contributing  to  the  specific  objectives. 
However, O2 and O3 with the mandatory introduction of DTCs would strengthen the harmonised 
framework on controls at entry and exit and promote trust between Member States, while O1 may 
result in weaker measures and limited gains in terms of security and facilitation benefits. O3 offers 
a more holistic and coordinated approach owing to its mandatory nature, maximising both border 

48 

 
  
security and facilitation benefits, therefore being the most effective of the options in attaining the 
objectives of the initiative. 

As  to  the  simplicity  of  the  solution,  O2  is  estimated  to  have  the  highest  degree  of  ambiguity 
associated  with  its  implementation.  The  inconsistency  between  the  mandatory  implementation  of 
DTCs (everyone can have one) and voluntary facilitation of DTC users (you can only use a DTC in 
some  Member  States),  can  create  confusion  and  wide  discrepancies  in  travel.  Both  O1  and  O2 
would lead to a fragmented legal situation across the EU. However, when comparing O1 and O3 
against the baseline scenario, O1 is the simplest in that it allows Member States to opt in or out. O3 
would  require  the  most  changes  in  terms  of  legislative,  technical  and  operational  aspects, 
warranting also a proportionate transition period to allow all Member States to have the necessary 
technological maturity to integrate the use of DTCs in their national systems and legal frameworks. 
O1 can be considered the simplest option from a regulatory perspective. 

The table below summarises the advantages and disadvantages of each policy option with respect to 
proportionality.  

Table 4: Overview of the proportionality assessment 

Option 

Advantage 

Disadvantage 

Score 

Baseline 

• 

Proportionate by default 

• 

Proportionate by default 

0 

• 

It is the simplest option to implement from a 

• 

Lowest level of achievement of 

regulatory perspective, entailing a fully 

objectives 

voluntary nature allowing Member States the 

O1 

option to opt in or not 

• 

Clear added value of EU action  

•  Generally proportionate 

• 

It provides significant improvement to the 

• 

Complicated option from a regulatory 

current situation  

• 

Clear added value of EU action  

•  Generally proportionate provides significant 

improvement to the current situation  

perspective, entailing a mix between 

mandatory implementation of DTCs 

and voluntary facilitation of travel, 

with the highest level of ambiguity 

• 

Lower level of achievement of 

objectives compared to O3 

•  Highest level of achievement of the objectives 

•  Most complicated option from a purely 

per the assessment of the effectiveness criteria  

regulatory and technical perspective 

• 

Clear added value of EU action  

•  Generally proportionate 

O2 

O3 

1.5 

1 

2 

49 

 
 
7.5. 

Summary of assessment 

Based  on  the  more  detailed  assessment  of  each  criterion,  the  table  below  presents  the  scores  for 
each policy option per criterion. All criteria were given the same weight (1) in this evaluation.   

Table 5: Summary table of the assessment 

Performance values 

Main assessment 

criterion 

Effectiveness 

Efficiency 

Coherence 

Proportionality  

Total score 

Baseline 
scenario (always 
0) 

Policy Option 1  Policy Option 2  Policy Option 

0 

0 

0 

0 

0 

0.5 

0.5 

2 

1.5 

4.5 

1 

1 

1 

1 

4 

3 

1.5 

1.5 

2 

2 

7 

8.  PREFERRED OPTION 

The  preferred  option  is  eventually  O3  after  a  suitable  transition  period,  while  allowing  Member 
States to ‘opt-in’ as in O2 during that transition period, namely  a) enabling EU citizens and third 
country  nationals  to  derive  their  DTCs  from  existing  ICAO-compliant  travel  documents;  b)  
allowing them to use DTCs for the purposes of crossing the external borders in the Member States 
that choose to implement DTCs during a transition period; and c) allowing them to use DTCs for 
the  purposes  of  crossing  the  external  borders  in  all  Member  States  after  a  reasonable  transition 
period and once the common EU technical solution is ready. Before the start of operations of the 
common  EU  technical  solution,  and  during  the  transition  period,  Member  States  could,  based  on 
national  implementations,  enable  travellers  to  create  and  submit  DTCs  for  external  border 
management purposes. The preferred option of combining O2 and O3 would therefore remove legal 
obstacles  for  the  early  adopter  Member  States  to  start  implementing  DTCs  at  their  borders 
immediately.  However,  for  reasons  of  ensuring  a  single  technical  gateway  in  the  longer  term,  a 
common  EU  technical  solution  should  be  used  by  all  Member  States,  also  for  the  benefit  of 
individual travellers, once it is operational. 

Consequently,  the  preferred  option  obliges  Member  States  to  allow  their  citizens  to  use  the  chip 
data in their national passports and identity cards for this purpose, and first enables and then obliges 
them  to  put  in  place  legal,  technical  and  operational  measures  for  carrying  out  pre-arrival  border 
checks for all persons using a DTC. The preferred option would also mandate eu-LISA to develop 
technical  solutions  allowing  individuals  to  derive  the  DTC  and  to  submit  it  to  the  competent 
Member  State.  It  should  be  noted  that  the  preferred  option  will  not  replace  physical  travel 
documents with digital ones and that physical travel documents will continue to co-exist. Finally, it 

50 

 
 
 
should  also  be  borne  in  mind  that  the  preferred  option  does  not  entail  the  most  far-reaching 
intervention  from  the  options  initially  considered,  since  the  option  of  fully  seamless  travel 
(biometric verification on the move) was excluded. 

8.1.  Benefits  of  the  preferred  option  for  the  digitalisation  of  travel  documents  and 

facilitation of travel 

The  preferred  option  brings  the  most  benefits  in  terms  of  facilitated  travel  across  the  external 
Schengen borders as well as increased security in the EU. The combined effect of allowing persons 
to have and to use DTCs across the Member States, after a transition period, ensures a coherent and 
systematic  approach,  promoting  high  standards  and  mutual  trust  among  the  Member  States.  The 
preferred  option  contributes  to  the  highest  possible  uptake  of  DTCs,  while  maintaining  their 
voluntary  nature  for  travellers,  and  therefore  ensures  highest  synergies  with  existing  and  planned 
initiatives, such as the EES, ETIAS, API and migration processes. Similarly, this higher uptake also 
leads  to  more  significant  gains  in  terms  of  shorter  waiting  times  as  more  travellers  can  be  pre-
cleared, resulting in higher accumulative savings as well as more accurate data. These elements in 
terms  of  increased  security  as  well  as  the  ability  to  better  manage  external  borders  and  facilitate 
travel  contribute  most  to  the  general  objectives  related  to  a  safer  area  of  freedom,  security  and 
justice  (General  Objective  1),  EU  policy  on  integrated  border  management  (GO2)  and  the 
facilitated  free  movement  of  persons  (GO3).  The  preferred  option  is  also  most  suitable  for 
increasing and ensuring an adequate level of digital maturity across the Member States (SO1).  

The  standardisation  of  the  DTC  and  its  use  for  external  border  management  across  the  Member 
States  would  also  bring  further  benefits,  such  as  increased  efficiency  for  carriers  on  a  voluntary 
basis  as  they  could  integrate  DTCs  into  their  current  workflows  on  passenger  management, 
contributing  to  the  facilitated  free  movement  of  persons  (GO3)  and  allowing  for  a  smoother  and 
faster  border  crossing  for  travellers  (SO2).  However,  it  would  not  oblige  carriers  or  other  third 
parties  to  process  DTC  data  or  to  invest  in  hardware/software  for  doing  so.  The  preferred  option 
would  merely  enable  them  to  do  so,  e.g.  fulfilling  their  obligations  under  carrier  liability  by 
inspecting  a  DTC  instead  of  a  physical  travel  document  and  by  using  a  DTC  for  fulfilling  their 
obligation under the revised API rules on the automatic collection of API data.  

The  preferred  option  also  enables  further  use  cases  of  DTCs  for  EU  citizens,  by  establishing  an 
attribute for the digital identity wallet that can be used for e.g. proving one’s identity within the EU, 
and  possibly  abroad,  depending  on  the  acceptance  by  third  countries.  As  compared  to  the  other 
options,  the  preferred  option  would  guarantee  that  citizens  of  the  EU  and  Schengen  Associated 
Countries have a right to obtain a DTC based on their travel document that is accepted throughout 
the  EU  and  Schengen  Associated  Countries  in  particular  when  exercising  free  movement  rights 
(GO3 and SO2). 

8.2. 

Potential disadvantages of the preferred option 

The  preferred  option  envisages  some  potential  disadvantages,  owing  to  its  eventual  mandatory 
nature.  It  bears  the  highest  cost  of  implementation  for  Member  States  and  the  most  intensive 
legislative and technical intervention at Member State level, while the financial impact for the EU 
institutions  is  more  or  less  the  same  under  each  policy  option.  Despite  the  higher  degree  of 
interference with the legal and technical frameworks at national level, the preferred option ensures 
the highest level of coherence with the EU legal framework, enabling the integration of DTCs into 
several  flows.  Some  of  the  potential  disadvantages,  such  as  implementation  costs  and  technical 

51 

 
complexity  of  integrating  DTCs  into  national  border  management  systems,  can  be  offset  or 
mitigated by granting appropriate transition periods.  

8.3.  Application of the ‘one in, on out’ approach 

The  preferred  option  has  the  potential  to  significantly  improve  the  border  check  processes,  by 
upstreaming the checks on persons and their travel documents. This benefits both border authorities 
as well as individual travellers. In terms of adjustment costs and administrative costs for businesses 
and  citizens,  the  preferred  option  does  not  entail  any.  While  the  preferred  option  would  oblige 
Member  States  competent  authorities  to  put  in  the  place  the  required  technical  capabilities  for 
processing DTCs in their border management processes, no obligations are envisaged for individual 
businesses or citizens. 

8.4.  REFIT (simplification and improved efficiency) 

According  to  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).  The  proposal, 
based on this impact assessment, will consist of new legislation amending existing procedures, in 
order  to  carry  out  border  checks  and  the  technical  specifications  of  travel  documents  issued  by 
Member  States.  It  will  be  implemented  by  amending  Regulation  (EU)  2016/399,  Council 
Regulation (EC) No 2252/2004 and Regulation (EU) 2019/1157.  

While this initiative has not been subject to the REFIT initiative, it will reduce the overall burden 
on Member States by increasing the effectiveness and efficiency of external border management as 
referred  to  in  Chapter  7.  The  introduction  of  a  uniform  format  for  DTCs  will  moreover  create 
opportunities  e.g. to carriers, and alleviate their administrative costs and burden. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will ensure that necessary measures are in place to monitor the functioning of the 
proposed  measures  and  to  evaluate  them  against  the  policy  objectives  of this  initiative.  Since  the 
measures for using DTCs under the preferred option would be mandatory for Member States after a 
transition period, collecting data on their use and added value would be facilitated.  

The  specific  objectives  against  which  the  measures  will  be  evaluated  pertain  to  1)  increased 
security  of  the  Schengen  area  and  increased  efficiency  of  external  border  management,  and  2)  a 
smoother  and  facilitated  travel  experience  for  all  travellers.  Monitoring  and  evaluating  the 
attainment  of  these  objectives  as  well  as  the  general  objectives  will  include  the  following 
indicators: 

-  Number of DTCs derived from existing travel documents; 

-  Number of travellers using DTCs/number of pre-arrival border checks; 

-  Average  time  per  border  check  after  the  implementation  of  DTCs  (from  the  border 

authority and traveller perspective); 

-  Number of security breaches (especially cases of identified counterfeit and forgery; and 

cases of identified trans-border crimes); 

52 

 
-  Number of errors found in travel document data; 

-  Number  of  flights  delayed  or  cancelled/refused  border  crossings  or  boardings  due  to 

peak times and long processing times or data errors; 

-  Level  of  digital  maturity  across  Member  States:  ability  to  process  DTCs  at  external 

borders and leveraging DTCs for border management;  

-  Costs for Member States and eu-LISA associated with implementation; 

-  Cost savings for authorities; 

-  Use  of  DTCs  by  other  stakeholders,  including  by  carriers  for  business  management 

purposes and for collection of API data; 

-  Feedback satisfaction surveys. 

In addition to data provided by Member States, the IT tools to be developed at EU level that enable 
the  creation  and  submission  of  the  DTCs  should  support  the  monitoring  and  evaluation  by 
collecting statistics  on the basis of log  data  (no personal  data),  disaggregated at  EU and Member 
State  levels.  The  customer-facing  application  should  also  allow  the  collection  of  feedback  from 
users.  These  data  would  feed  into  a  separate  ex-post  evaluation  and  report  that  the  Commission 
would present to the European Parliament and the Council five years after the entry into force of 
the  regulation.  Furthermore,  the  Schengen  Handbook  (Practical  Handbook  for  Border  Guards102) 
should  be  updated  to  address  the  changes  in  the  legal  framework  and  provide  relevant 
guidelines/recommendations  to  Member  States  on  the  implementation  of  DTCs  in  the  context  of 
external border management.  

The implementation of the measures under this initiative, including data protection aspects, would 
also  be  monitored  and  evaluated  in  the  context  of  the  Schengen  evaluation  and  monitoring 
mechanism. Similarly, the implementation of the initiative would be addressed in the annual State 
of Schengen Reports as well as the accompanying tools, such as the Schengen Barometer and the 
Schengen  Scoreboard.  At  the  same  time,  the  Commission  should  closely  monitor  global 
developments  in  travel  and  the  digitalisation  of  travel  documents  to  ensure  interoperability, 
reciprocity and competitiveness.  

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

53 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The  lead  DG  is  the  Directorate-General  for  Migration  and  Home  Affairs  (DG  HOME)  for  the 
preparation of this initiative and the work on the impact assessment. The agenda planning reference 
is PLAN/2022/860. The Directorate-General for Justice and Consumers (DG JUST) is associated to 
the  initiative  concerning  the  digitalisation  of  identity  cards.  The  initiative  is  listed  in  the 
Commission Work Programme 2023.  

2.  ORGANISATION AND TIMING 

The  inter-service  steering  group  for  the  impact  assessment  was  set  up  in  August  2022,  with 
participation  of  the  following  Directorates-General:  Secretariat-General  (SG),  Justice  and 
Consumers  (JUST),  Mobility  and  Transport  (MOVE),  Communications  Networks,  Content  and 
Technology  (CNECT),  Internal  Market,  Industry,  Entrepreneurship  and  SMEs  (GROW)  and 
Budget  (BUDG).  The  call  for  evidence,  launching  this  impact  assessment,  was  published  on  8 
September  2022.  In  the  Schengen  strategy  of  2021,  the  Commission  announced  its  intention  to 
adopt  a  legislative  proposal  on  the  digitalisation  of  travel  documents  and  facilitation  of  travel  in 
2023. 

3.  CONSULTATION OF THE RSB 

On  15  November  2023,  DG  HOME  submitted  the  present  impact  assessment  report  to  the 
Regulatory  Scrutiny  Board.  Following  a  written  procedure  in  December  2023,  the  Regulatory 
Scrutiny Board issued a positive opinion on the report on 15 December 2023. 

4.  EVIDENCE, SOURCES AND QUALITY 

This impact assessment is notably based on the study on the digitalisation of travel documents and 
facilitation of travel, carried out by Deloitte as external contractor for the Commission, and on the 
multiple  consultations  and  interviews  conducted  in  that  context.  The  external  study  assessed  the 
problems  related  to  security  risks  and  challenges  to  efficient  border  control  and  to  smooth  and 
facilitated  travel  across  the  external  borders.  The  goal  was  to  consider  the  optimal  way  to  make 
travel  experiences  smoother  and  border  management  more  secure  by  leveraging  digital  tools  to 
respond to  increasing  traveller volumes and  current  challenges in  the domain  of border  checks at 
external borders.  

The  data  already  collected  in  the  context  of  the  still  ongoing,  EU  (co)-funded  pilot  projects  on 
digital travel credentials implemented by the Netherlands, Finland and Croatia have also been used 
to exemplify the benefits of digital solutions as well as the elements that need to be addressed, e.g. 
regarding technical implementation as well as fundamental rights guarantees.  

A special Eurobarometer survey was carried out  in  2023  to  collect  public views on the initiative. 
Finally,  data  from  previous  studies  and  Commission  reports,  including  impact  assessments  and 
Schengen evaluations have also been used in this impact assessment. 

54 

 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

This  annex  provides  a  synopsis  report  of  all  stakeholder  consultation  activities  undertaken  in  the 
context of this impact assessment. 

1.  CONSULTATION STRATEGY 

The  objective  of  the  consultation  activities  was  to  gather  data  and  stakeholders’  views  in  the 
context  of  preparations  of  the  legislative  proposal  on  the  digitalisation  of  travel  documents  and 
facilitation of travel. The consultation activities aimed at collecting views on several issues and the 
suggested  EU  intervention,  as  well  as  opinions,  ideas  and  concerns  about  the  various  available 
options, solutions and impacts. The activities also sought to collect objective data, information and 
evidence  on  how  the  proposed  solutions  would impact  the  relevant  stakeholders.  As  part  of  their 
study on the digitalisation of travel documents and facilitation of travel, Deloitte conducted several 
consultation activities, feeding into this impact assessment.  

The consultation process included: 

▪  Consultations  with  Member  States’  relevant  authorities,  several  Commission  services  and 
EU  agencies  as  well  as  industry  and  international  organisations  through  surveys, 
questionnaires and interviews 

▪  Public  consultation  on  a  possible  legislative  initiative  on  the  digitalisation  of  travel 

documents and facilitation of travel 

▪  A Special Eurobarometer survey on the digitalisation of travel documents and facilitation of 

travel 

2.  CONSULTATION ACTIVITIES 

This section provides an overview of the different consultation activities carried out and their main 
findings. The analyses of the various activities and further details can be found in the Deloitte study 
as well as the Special Eurobarometer 536 Report103. 

2.1. 

Strategic interviews with key decision makers and key experts 

Seven  strategic  interviews  were  conducted  with  representatives  of  DG  HOME,  DG  JUST, 
DG MOVE, DG CNECT and DG GROW in a semi-structured format. These interviews served to 
develop  the  initiative  and  obtain  more  information  about  the  needs,  priorities,  challenges  and 
objectives  of  this  EU  policy  initiative.  An  overview  of  the  key  stakeholders  at  national,  EU  and 
international  level  was  also  shaped  during  these  interviews.  These  interviews  supported  the 
identification of relevant issues and problem drivers affecting each set of stakeholders. 

103 https://europa.eu/eurobarometer/surveys/detail/2967.  

55 

 
 
 
2.2.  Targeted consultations 

Targeted consultations were conducted to obtain in-depth insights about the different aspects of the 
proposed policy options and to discuss the impacts of those options.  

Written  questionnaires  were  sent  to  Member  States’  representatives  in  the  Council  Frontiers 
Working Party as well as the Article 6 Committee and Free Movement Expert Group. The aim of 
the  written  questionnaire  was  to  collect  information  on  individual  persons’  and  Member  States’ 
views on current practices with regard to biometric passport issuance and inspection, participation 
in digital identity schemes, the potential of DTC as well as readiness and willingness to implement 
DTCs for external border checks.  

All respondents said it was very essential to ensure adherence to international (ICAO) standards on 
digital travel credentials. 65% of respondents said that it should be mandatory to accept  DTCs in 
the  EU,  while  71%  thought  that  it  should  be  mandatory  to  facilitate  the  travel  of  persons  with  a 
DTC. 

As to  the creation of DTCs,  77% opined that  this should be  done  under a  common EU technical 
solution.  Finally,  94%  of  respondents  thought  their  Member  State  would  be  successful  in 
introducing DTCs for external border-crossings if a gradual transition period were to be provided 
for.  

2.3. 

In depth-interviews 

In depth-interviews were organised with  several Commission officials, EU agencies (Frontex, eu-
LISA and the Fundamental Rights Agency), national travel document issuing authorities, national 
border  control  and  border  policy  authorities,  international  organisations  and  associations 
(International  Civil  Aviation  Organization,  International  Air  Transport  Association  and  World 
Travel  and  Tourism  Council)  as  well  as  experts  from  the  private  industry  and  Canada  Border 
Services Agency.  Interviewees were selected based on  a match between the expertise or practical 
experience  of  the  person  and  the  information  needs  for  carrying  out  the  study  and  the  impact 
assessment.  

In particular, the interviews gathered crucial information to conduct the feasibility assessment and 
the  multi-criteria  assessment.  For  example,  the  interviews  with  the  individual  Member  States 
provided information on the size of the effort to adjust the current border management equipment, 
the percentage of errors contained in submitted passenger information and the average waiting time 
of  third  country  nationals.  The  countries  interviewed  were:  Croatia,  Estonia,  Finland,  Germany, 
Greece, the Netherlands, Poland, Spain, Sweden (and France – from the ICAO perspective).  

The interviews with the European agencies provided important insights on the technical feasibility 
of introducing DTCs and how this initiative could synergise with other (ongoing) initiatives such as 
ETIAS,  EES  and  the  EUDIW.  The  EU  agencies  particularly  highlighted  the  importance  of 
including privacy and data considerations from the design phase onwards.  

56 

 
Lastly, during the interviews with the international organisations, most of the considerations in the 
problem  tree  about  the  potential  of  DTCs  in  the  fields  of  improved  security  and  seamless  travel 
were confirmed.  

Other topics such as ongoing initiatives and/or pilot projects in certain countries, organisations and 
associations were also discussed. 

2.4. 

Public consultation 

The  survey  was  available  from  5  April  to  28  June  2023  and  received  6  754  replies  in  total.  The 
survey aimed at collecting information on the proposed digitalisation of travel credentials and travel 
facilitation.  The  survey  included  questions  on  different  aspects,  e.g.  the  advantages  and 
disadvantages  of  digitalising  travel  documents  and  of  facilitating  the  travel  process,  the  potential 
main obstacles/drawbacks, as well as the protection of personal data. 

The number of responses per country were: AT: 573, BE: 123, BG: 22, CH: 37, CY: 7, CZ: 37, DE: 
3 920, DK: 12, EE: 7, EL: 38, ES: 114,   FI: 26, FR: 472, HR: 37, HU: 24, IS: 0, IE: 36, IT: 300, 
LI: 0, LT: 10, LU: 35, LV: 5, MT: 4, NL: 74, NO: 6, PL: 72, PT: 41, RO: 45, SE: 26, SK: 524, SI: 
6.  Additionally,  individuals  from  several  other  countries  replied  to  the  survey  as  well,  including 
Turkey (3 respondents), India (4 respondents), and the United States (9 respondents).  

respondents  were  EU  citizens,  with  some 

in 
The  majority  of 
companies/business  associations,  one  in  an  environmental  organisation,  and  ten  others  in  non-
governmental  organisations.  Of  the  respondents,  some  worked  in  academia,  whilst  others  were 
active in the trade or environment sectors. 

individuals  working 

Campaigning and sentiment analysis 

Given  the  large  number  of  responses,  predominantly  from  Germany,  Austria,  and  Slovakia  with 
respectively 58%, 8% and 8% of the replies, the likelihood of a targeted campaign to influence the 
outcome of the public consultation was assessed.  

The  analysis  showed  that  the  time  of  submission  of  the  answers  to  the  survey  was  spread  over  a 
long  period,  with  a  consistent  increase  in  answers  over  the  3-month  duration  of  the  public 
consultation. A saturated window of submission could indicate a campaign, but there was no such 
window indicated, as replies came in consistently over the entire runtime of the survey.  

Based  on  the  indicators  utilised,  it  was  hard  to  determine  whether  the  public  consultation  was 
targeted  by  a  campaign,  or  whether  the  topic  of  the  digitalisation  of  travel  documents  and  the 
facilitation of travel is merely a topic that sparks a lot of debate. As a result, it was impossible to 
rule  out  the  possibility  of  a  campaign  or  that  some  responses  were  part  of  one.  If  there  was  a 
campaign, the source of the campaign could not at this point be identified.  

DG HOME received a considerable  number of letters by post with replies to the questions of the 
public  consultation  which  were  all  provided  on  the  same  form  where  only  the  address  had  to  be 
inserted.  

57 

 
Keeping these elements in mind, a sentiment analysis was carried out for the open-ended questions 
(questions  15  and  22),  in  order  to  more  accurately  assess  the  input  received  by  EU  citizens  and 
organisations on the matter given the vast number of replies. The answers to some questions were 
also  analysed  without  the  Austrian  and  German  responses,  to  further  assess  the  possibility  of 
campaigning  and  potentially  correct  the  results.  Both  approaches  nevertheless  revealed  a  rather 
general negative sentiment overall. However, the results of the Special Eurobarometer, targeting a 
wider audience, produced vastly different results to very similar questions. 

Summary of results 

The opinions of the respondents to the public consultation were largely negative with regard to the 
use  of  DTCs,  and  their  willingness  to  use  DTCs  when  crossing  external  borders.  83%  of 
respondents thought that the possibilities of using DTCs were not important or not at all important, 
while  12%  said  they  were  either  very  important  or  important.  When  asked  about  whether  DTCs 
could  facilitate  the  border  check  procedure,  72%  answered  negatively.  Similarly,  58%  of  the 
respondents indicated that it would not be at all useful to be able to leverage digital passports for 
other  administrative  procedures,  with  another  19%  indicating  that  this  would  not  be  useful.  Only 
12%  of  respondents  would  consider  using  a  DTC  if  it  were  available,  while  6%  said  they  would 
consider  this  under  certain  conditions.  As  motivations  for  the  lack  of  uptake,  respondents 
highlighted primarily data protection and privacy concerns, as well as  an overall satisfaction with 
the  current  processes.  Concerning  travel  habits,  85%  of  respondents  had  travelled  outside  the 
Schengen area in the last five years, most frequently for tourism (51%), visiting family and friends 
(12%)  and  for  professional  purposes  (11%).  With  regard  to  ownership  of  a  mobile  device  that  is 
less than five years old and that could be used for travel purposes, 56% of respondents responded to 
having  one.  The  challenges  associated  with  the  benefits  of  introducing  DTCs  were  not  seen  as 
important by a majority of respondents. For example, long waiting times were not challenging at all 
or  not  challenging  for  78%  of  respondents  and  inconvenient  travel  experience  due  to  physical 
checks were not challenging at all or not challenging for 81%.  

The  call  for  evidence  was  open  for  feedback  between  8  September  and  6  October  2022  and 
attracted 360 responses. A majority of the opinions expressed were largely negative, mirroring the 
results and reasons of the later public consultation.  

2.5. 

Special Eurobarometer 

The special Eurobarometer survey EBS 539 was carried out between 10 May and 5 June 2023 and 
covered  26 358  interviews  in  the  27  EU  Member  States.  The  total  EU  results  were  weighted 
according to the size of the population of each country. The survey explored EU citizens’ views and 
perceptions  of  travel  policies  related  to  travel  facilitation,  including  the  introduction  and  use  of 
DTCs. It also provided a snapshot of Europeans’ extra-Schengen travel habits. 

While  some  divergence  could  be  observed  between  individual  Member  States,  the  results  were 
overall  positive.  Similarly,  socio-demographic  data  showed  consistent  answer  patterns  on  most 
questions. Main discrepancies could be observed on the perceptions of DTCs.  

Most  Europeans  considered  that  it  is  important  to  accelerate  border  procedures  and  to  enhance 
cooperation  between  the  EU  and  its  Member  States  on  extra-Schengen  travel.  77%  of  Europeans 

58 

 
supported the idea of the EU taking action to mitigate obstacles for extra-Schengen travel and for 
accelerating border procedures.  

Having  been  given  the  description  of  DTCs  and  how  they  can  be  used,  two  thirds  (67%)  of 
Europeans had a positive perception about DTCs and among those, 22% thought very positively 
about them. On the opposite, one quarter (26%) of Europeans had a negative opinion about them. 
Opinions  were  most  positive  amongst  younger  respondents,  students,  managers  and  other  white-
collar workers, frequent travellers and those who have a positive view of the EU in general. On the 
other side, perceptions were least positive amongst those who hold a negative view about the EU, 
who do not travel and those who left full-time education at the age of 15 or before. Nonetheless, 
68%  of  Europeans  were  in  favour  of  using  digital  travel  credentials  for  extra-Schengen 
travel, while 28% opposed their use. While support among older respondents was lower, still 54% 
of  respondents  aged  55  or  more,  and  50%  of  retirees  were  in  favour  of  using  DTCs  for  extra-
Schengen travel. 

From  the  various  concerns  mentioned,  almost  half  (49%)  of  Europeans  considered  that  software 
failures were the most important concern related to the use of digital travel credentials. Concerns 
regarding data protection, device problems and cyberattacks were also raised. 

The positive results of the survey are interesting in view of the largely negative feedback collected 
in  the  public  consultation,  also  taking  into  account  the  larger  and  more  representative  sample 
population  and  the  fact  that  the  survey  is  more  immune  to  campaigning  as  it  targets  people  at 
random. 

3.  CONCLUSIONS 

In regard to the overall digitalisation of travel documents, most consulted stakeholders throughout 
the  impact  assessment  and  study  expressed  a  positive  sentiment  towards  the  initiative,  as 
highlighted during the strategic interviews, written questionnaire, and in-depth interviews as well as 
the  Special  Eurobarometer  survey.  Solely  the  sentiment  expressed  by  citizens  and  other 
stakeholders  within  the  Public  Consultation  was  negative,  and  this  is  contradicted  by  the  Special 
Eurobarometer results on the same matter. Across the consulted stakeholders, opinions whether the 
implementation  of  DTCs  should  be  mandatory  or  voluntary  were  mixed.  The  consensus  was 
nevertheless that the uptake and use by citizens should be voluntary at all times.  

The assessment of the added value of the digitalisation of travel documents was generally positive 
as well across the different consultation activities, apart from - again - the Public Consultation. Key 
elements referred to included the improved data quality and the implementation of seamless travel 
associated with DTCs.  

Generally,  most  stakeholders  across  the  board  indicated  that  ICAO’s  Type  1  DTC  is  the  most 
realistic  option  to  implement  digital  travel  credentials  in  the  EU  from  a  regulatory  and  technical 
perspective,  although  a  significant  number  of  stakeholders  across  the  different  consultation 
activities noted some downsides with the solution as well.  

For the facilitation of travel and the implementation of measures to facilitate the use of DTCs, most 
stakeholders were generally positive about the facilitation in their Member States. Nevertheless, it 

59 

 
should be noted that a significant number of stakeholders across the different consultation activities 
expressed a relatively low level of digitalisation in existing border check procedures, lowering the 
readiness to  implement  required measures  in  the  short-term.  Nearly all stakeholders indicated the 
need for a transition  period if  DTCs would be implemented. Mirroring the sentiment towards the 
implementation  of  DTCs,  the  consulted  stakeholders  were  also  divided  on  the  mandatory  or 
voluntary facilitation of travel, with a majority in favour of mandatory acceptance.  

60 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The  initiative  primarily  benefits  individuals,  Member  States’  authorities  and  society  at  large  by 
facilitating cross-border travel and free movement and by improving security at the external borders 
and the internal security of the EU. 

1.1. 

Individuals 

The initiative would enable individual travellers (both EU citizens and third country nationals) to 
use DTCs for external border crossing purposes. This brings benefits in terms of less time spent at 
border crossing points and less hassle due to misspelled or incorrect manually declared data. Errors 
in  self-declared  data  can  lead  to  additional  waiting  time  or  even  refusals  of  entry  or  a  refusal  to 
board a transport vehicle. 

As the initiative would establish a legal standard for the DTC, its uses could be incorporated into 
national systems, particularly with the rollout of digital identity and the EUDIW. EU citizens could 
better leverage the chip data in their passport or identity card for secure identification in both online 
and physical transactions. 

A clear impact of the initiative on waiting times at the border was difficult to ascertain, but based 
on results from the ongoing DTC pilot projects, the processing time of pre-cleared DTC travellers 
(EU citizens) decreased  significantly from  between 30 and 90 seconds to less than 9 seconds per 
traveller. This impact is multiplied with the eventual uptake of DTCs, resulting in shorter queuing 
times even for those travellers that will not use the DTC themselves, but whose monetary value is at 
this point impossible to evaluate. 

The  initiative  will  also  benefit  individuals,  if  carriers  (e.g.,  airlines,  coaches,  trains  and  ships) 
integrate  the  processing  of  DTCs  into  their  booking  and  check-in  systems.  This  could  allow 
passengers  to  undergo  certain  checks  –  that  are  currently  done  physically  at  transport  hubs,  e.g., 
during  check-in,  baggage  drop  or  boarding  –  fully  remotely  and  save  additional  time  with  less 
hassle, too. 

Since the use of a DTC would be voluntary and free of charge for individuals, no financial costs are 
envisaged. The only investment required from individuals would relate to the time it takes to derive 
a DTC from the traveller’s existing passport or identity card, which could be done remotely. 

In terms of the initiative’s implications on personal data and privacy of DTC users, the amount and 
extent of processing of personal data remains unchanged. The time of processing the personal data 
of  travellers  would  be  upstreamed  in  the  context  of  advance  checks,  as  opposed  to  the  border 
authorities  processing  that  same  personal  data  once  the  traveller  arrives  at  the  physical  border 
crossing  point.  Owing  to  the  voluntary  nature  of  the  use  of  DTCs  and  the  possibility  to  undergo 
border checks as they are currently carried out ensures inclusivity and non-discrimination. Finally, 
the  remedies  in  place  for  refusals  of  entry,  data  breaches  or  other  unlawful  activity  remain 
unchanged and governed by existing EU and national law. 

61 

 
1.2.  Member States’ national authorities 

1.2.1.  Border management authorities 

The  initiative  would  benefit  mostly  the  authorities  competent  for  carrying  out  border  checks  at 
external  borders.  Receiving  DTC  data,  and  certain  additional  data  for  third  country  nationals, 
upfront, would enable the authorities to verify the authenticity and integrity of travel documents as 
well as consult the relevant databases before the traveller arrives at the border crossing point more 
efficiently  than  today.  This  would  allow  better  management  of  resources  and  better  detection  of 
high-risk travellers and fraudulent documents, since several travellers would have been pre-cleared 
and quickly processed at the border crossing point.   

1.2.2.  Visa, ETIAS and other authorities 

While the initiative focuses on the use of DTCs for crossing external borders, the introduction of a 
legal definition for DTC could also serve to benefit authorities responsible for processing visa and 
ETIAS  applications  and  enable  them  to  verify  the  authenticity  and  integrity  of  travel  documents 
(remotely) used by applicants. This also applies to e.g. immigration authorities processing residence 
permit applications submitted by third country nationals in a third country.  

1.3. 

eu-LISA 

The  European  Union  Agency  for  the  Operational  Management  of  Large-Scale  IT  Systems  in  the 
Area  of  Freedom,  Security  and  Justice  (eu-LISA)  will  be  involved  in  the  development  and 
maintenance of a  common customer-facing  mobile  application for the derivation of the DTC and 
for  pre-registering  certain  data  that  is  required  for  entry  or  exit,  depending  on  the  profile  of  the 
traveller  (EU  citizen,  TCN  family  member  of  an  EU  citizen,  visa-free  TCN,  visa-required  TCN 
etc.).  eu-LISA  will  also  develop  and  maintain  the  services  related  to  the  customer-facing  mobile 
application (e.g. facial recognition, liveness check and presentation attack detection, verification of 
authenticity  and  integrity  of  document)  as  well  as  the  central  EU-level  components  to  streamline 
the transmission of the DTC data by individual users of the application to the Member State he or 
she intends to cross the external border in. The development of these technical components should 
seek  to  build  upon  existing  capabilities  already  set  up  at  EU  level  by  eu-LISA  to  the  extent 
possible. 

If  the  legislative  changes  were  to  be  adopted  by  2025,  eu-LISA  would  start  working  on  the 
preparation  and  development  of  these  technical  components  as  of  2026,  to  ensure  the  entry  into 
operation in 2029.  

1.4.  Other entities 

The  initiative  would  not  oblige  e.g.  carriers  or  security  operators  in  airports,  seaports  or  other 
transport  hubs  to  process  DTCs.  However,  the  initiative  would  enable  them  to  do  so,  bringing 
multiple benefits. The automated collection of API data, as provided for in the API proposal, could 
be based on a DTC. This would allow carriers to ensure the authenticity and integrity of the travel 
document used by travellers, resulting in fewer refusals of entry and  subsequent costs in terms of 
returning persons whose entry has been refused or due to  fines under carriers’ liability. Transport 
operators can also leverage the DTC data in their check-in systems, reduce the amount of physical 
transactions  with  passengers  and  better  manage  their  personnel.  Similarly,  by  obliging  Member 
States  to  allow  individuals  to  have  a  DTC,  it  creates  countless  opportunities  for  other  entities 
offering services, where identification/verification of identity is absolutely necessary (e.g., banking, 
purchase of age-controlled goods, registering at a municipality). 

62 

 
2.  SUMMARY OF COSTS104 AND BENEFITS 

The overview of benefits and costs of the preferred option is indicated below. 

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

Description 

effectiveness 
Increased 
and  efficiency  of  border 
checks:  rules  on  the  use  of 
DTCs  across  the  external 
borders will be harmonised  

facilitation: 

Travel 
all 
travellers will be allowed to 
benefit  from  certain  travel 
facilitations  by  using  the 
DTC  for  the  purposes  of 
crossing  external  borders  of 
any Member State 

Amount 

Direct benefits 

Comments 

The  preferred  option  brings  direct  benefits  in 
terms  of  increased  security  in  the  EU  through 
increased  effectiveness  and  efficiency of border 
checks. The combined effect of allowing persons 
to  have  and  to  use  DTCs  across  the  Member 
States  ensures  a  coherent  and  systematic 
approach,  promoting  high  standards  and  mutual 
trust  among  the  Member  States.  The  preferred 
option contributes to the highest possible uptake 
of DTCs.  

Similarly as above, the higher uptake envisaged 
under  the  preferred  option  also  leads  to  more 
significant  gains  in  terms  of  shorter  waiting 
times  as  more  travellers  can  be  pre-cleared, 
resulting in higher accumulative savings as well 
as  more  accurate  data.  Travellers  will  need  to 
invest  time  (1-3  minutes)  ahead  of  travel  for 
creating/submitting the DTC and relevant travel 
data. 

These  benefits  will  likely  bring  significant 
economic benefits too, since border checks 
can  be  more  effective  and  even  ‘remotely’ 
carried out,  leading to savings in resources 
needed  to  especially  cover  peak  times  of 
travel.  However, 
are 
impossible  to  accurately  quantify  at  this 
time. (See Annex 4 for more details) 

savings 

such 

Similar  to  above,  being  cleared  quicker  in 
the border check processes adds up and has 
a  positive  economic  impact  that  cannot  at 
this  time  be  quantified,  although  some 
inspiration  may  be  drawn  from  a  previous 
study concerning time losses. Following the 
introduction  in  2018  of  systematic  checks 
on all persons crossing the external borders, 
the time losses suffered by passengers as a 
result of increased waiting times at all types 
of  borders  were  estimated  to  be  between 
EUR  97.9  million  and  EUR  1.27  billion 
(depending  on 
the  assumed  waiting 
time).105 

Integration  of  DTC  into 
other  border  systems  and 
immigration processes 

Envisaging  the  highest  uptake  of  DTCs,  the 
preferred  option  ensures  highest  synergies  with 
existing and planned initiatives, such as the EES, 
ETIAS, API and migration processes. 

Indirect benefits 

integrations  may 

e.g. 
Some 
amending  an 
implementing  act,  while 
others  may  be  possible  without  any 
additional regulatory intervention. 

require 

Digital identity 

The  preferred  also  enables  further  use  cases  of   

104 All cost estimates for Member States are based on general estimates provided by Member States in the context of the 
DTC pilot projects and are therefore approximate only and not necessarily directly applicable to other Member States. 
The final costs depend on the existing infrastructure and software and technical implementation choices at the level of 
individual  border  crossing  points.  For  eu-LISA,  the  cost  estimations  are  based  on  prior  experience  with  EES/ETIAS 
Web  Services  projects.  Moreover,  it  is  important  to  emphasise  that  while  there  is  no  legislation  in  place,  the  precise 
technical  functionalities and therefore actual costs may vary, taking also into account fluctuations in prices,  inflation 
etc. 
105 Assessment of the implementation of Regulation (EU) 2017/458 amending Regulation (EU) 2016/399 as regards the 
reinforcement  of  checks  against  relevant  databases  at  external  borders,  February  2020,  p.  91.  The  time  costs  to 
passengers with additional waiting time were calculated based on 1) incremental waiting time per passenger, 2) the total 
number of passengers and 3) the value of time per passenger. The value of time refers to the money travellers would be 
willing to pay to avoid waiting that time when travelling or the compensation they would require having to wait that 
time while travelling. The optimistic scenario considered an additional waiting time of one minute per traveller, while 
the pessimistic scenario considered an additional waiting time of 13 minutes per traveller. 

63 

 
  
 
Carriers’ 
liability 
carrier applications 

and 

DTCs by EU citizens by establishing an attribute 
for the digital identity wallet that can be used for 
e.g.  proving  one’s  identity  within  the  EU,  and 
possibly abroad, depending on the acceptance by 
third  countries.  As  compared  to  the  other 
options,  it  would  guarantee  that  all  EU  citizens 
have  a  right  to  obtain  a  DTC  based  on  their 
travel  document  that  is  accepted  throughout  the 
EU. 

The  standardisation  of  the  DTC  would  allow 
carriers, on a voluntary basis, to integrate DTCs 
into 
their  current  workflows  on  passenger 
management  during  sales,  ticketing,  check-in, 
baggage  reconciliation  and  boarding.  However, 
it would not oblige carriers or other third parties 
to  process  DTC  data  or 
in 
hardware/software  for  doing  so.  The  preferred 
option would merely enable them to do so, also 
e.g.  fulfilling  their  obligations  under  carrier 
liability  by  inspecting  a  DTC  instead  of  a 
physical  travel  document.  Reduced  fines  due  to 
improvement  of  data  quality  could  add  up  to 
EUR 80 million per year. 

invest 

to 

Carriers willing to implement  digital travel 
credentials  (whether  based  on  the  DTC  or 
another standard) would potentially need to 
adjust their check-in processes to allow for 
the use of digital travel credentials. In order 
to  gain  access  to  the  chip  data  of  a  travel 
document  (and  derive  the  DTC),  it  is 
necessary first to read the machine-readable 
zone 
the  document.  The 
estimated  one-off  costs  for  airlines  to 
include this capability in their online check-
in  applications  (web-based  or  smartphone 
app-based) amount to EUR 200 000, based 
on estimates received from the air industry. 
These costs are already accounted for under 
the API proposal and its impact assessment.  

(MRZ)  of 

(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of individual 
actions/obligations of the preferred option are aggregated together); (2) Please indicate in the comments column which 
stakeholder  group  is  the  main  recipient  of  the  benefit;(3)  For  reductions  in  regulatory  costs,  please  describe  in  the 
comments  column  the  details  as  to  how  the  saving  arises  (e.g.  reductions  in  adjustment  costs,  administrative  costs, 
regulatory charges, enforcement costs, etc.;);.  

II. Overview of costs – Preferred option (EUR million, recurrent per year, per Member State) 

Citizens/Consumers 

Businesses 

Member States 

eu-LISA 

One-off  Recurrent  One-off 

Recurrent  One-off  Recurrent  One-off 

Recurrent 

Preferred 
option   

Direct 
adjustment 
costs 

Direct 
administrativ
e costs 

Direct 
regulatory 
fees and 
charges 

Direct 
enforcement 
costs 

Indirect costs 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

2 

0 

49.5 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

0 

0 

0 

0 

- 

0 

0 

0 

0 

0 

0 

0 

0 

0 

64 

 
 
 
 
 
 
III. Application of the ‘one in, one out’ approach – Preferred option(s) 

One-off 

Recurrent 

Total 

[M€] 

(annualised total net present 
value over the relevant period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed administrative 
burdens (OUTs) 

Net administrative 
burdens* 

Adjustment costs** 

Citizens 

New administrative 
burdens (INs) 

Removed administrative 
burdens (OUTs) 

Net administrative 
burdens* 

Adjustment costs** 

Total administrative 
burdens*** 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

(*) Net administrative burdens = INs – OUTs;  
(**)  Adjustment  costs  falling  under  the  scope  of  the  OIOO  approach  are  the  same  as  reported  in  Table  2  above.  Non-
annualised values;  
(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens. 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

IV. Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

e.g. 
SDG 
responsible 
and production 

no. 
– 
12 
consumption, 

The  use  of  DTCs  is  not  expected  to  contribute 
significantly  to  increased  travel  and  tourism.  No 
significant is therefore expected. 

65 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1. 

INTRODUCTION 

This  annex  provides  a  summary  of  the  methodological  approach  taken  to  estimate  the  financial 
costs  of  the  preferred  option  presented  in  this  impact  assessment.  Since  the  initiative  and  the 
preferred  option  only  cause  costs  for  Member  States  and  eu-LISA,  other  stakeholders  are  not 
considered in this annex, although they will have the possibility to leverage DTCs in their processes 
(e.g.,  airlines  using  DTCs  to  collect  API  data  by  automated  means  or  to  facilitate  check-in  or 
baggage reconciliation and more generally individual service-providers for verifying identity in any 
context). 

The underlying assumptions are based on data collection from individual Member States currently 
carrying out pilot activities to test the implementation of DTCs. Further assumptions with regard to 
the central technical solution to be developed by eu-LISA are based on a  high-level requirements 
mapping exercise. 

It should be noted that the cost estimates presented in this impact assessment report vary from the 
estimates presented in the external study that attempted to, among other things, quantify the savings 
associated with a quicker throughput of travellers through borders and increased security and better 
management  of  resources.  The  external  study  also  considered  as  relevant  the  costs  for  carriers  in 
integrating DTCs in their respective processes, while none of the options  entail any costs for them, 
neither directly nor indirectly. Moreover, the external study was done before the DTC pilot projects 
were operational and before the high-level requirements of the central EU application were drafted. 
Therefore, several assumptions made in the study are no longer relevant. 

2.  MEMBER STATE AUTHORITIES 

Member  States  authorities  competent  for  border  management  already  carry  out  border  checks  at 
external  borders.  However,  there  is  no  reliable  data  about  how  much  a  single  border  check 
transaction  costs.  Such  costs  include  staff  costs  (salaries,  payroll  taxes),  border  management 
infrastructure/hardware  investments  and  maintenance  (like  e-gates,  manual  booths,  inspection 
devices), software licences and general property management (whether rented or owned).  

In the course of the EU (co)-funded DTC pilot projects, Croatia and Finland have estimated certain 
costs  relevant  for  the  implementation  of  DTCs  in  a  full-production  mode  as  opposed  to  a  pilot 
setting.  While  the  available  funding  from  the  Border  Management  and  Visa  Instrument  (BMVI) 
was  EUR 2.3  million  (95%  of  total  cost)  for  these  pilots,  this  amount  is  not  in  itself  accurate  to 
evaluate  the  actual  costs  associated  with  the  implementation  of  DTCs  on  a  larger  “production” 
scale. 

Based  on  data  from  previous  projects  and  experiences  with  integrating  systems  into  the  national 
border  management  application,  Croatia  and  Finland  estimated  the  cost  of  integrating  DTCs  into 
their  national  systems  at  between  EUR  300  000  and  EUR  575  000.  To  account  for  possible 

66 

 
 
differences in Member States’ systems, the one-off cost for this integration is estimated at EUR 700 
000. 

Furthermore,  server  capacity  may  need  to  be  upgraded  at  Member  States’  level  in  order  to 
temporarily  store  DTCs/facial  images.  Again,  technical  implementation  decisions  at  the  national 
level  (e.g.  centralised  server  and  storage  vs.  decentralised  storage  at  each  border  crossing  point) 
may  significantly  impact  the  costs  associated  with  the  one-off  investment  for  increasing  server 
capacity. According to the Finnish Border Guard, a centralised implementation of additional server 
capacity  to  host  DTCs  and  to  process  facial  images  could  cost  EUR  250  000.  Depending  on  the 
traffic, border crossing points may need more or less capacity. 

Most border crossing points should already be equipped with facial recognition capabilities with the 
soon  entry  into  operation  of  the  EES.  Most  Member  States  have  already  installed  and  used 
automated border control systems and e-gates at their external borders for border check purposes. 
As such, no additional costs are necessarily expected from the implementation of DTCs, but again, 
individual implementation choices will have a significant impact on possible investment needs. For 
example, if a Member State chooses to establish separate processing lanes for travellers with DTCs 
with dedicated equipment, the costs may be lower compared to adapting all lanes and refitting them 
with  DTC  capabilities.  For  the  Finnish  DTC  pilot  project,  the  cost  of  establishing  one  dedicated 
lane was EUR 2 500, including a PC, facial recognition capabilities and a NFC reader. However, 
the cost of a single new e-gate is around EUR 40 000. Due to the near impossibility of providing an 
accurate  estimate  of  the  costs  for  equipping  lanes  with  DTC  capabilities,  the  one-off  cost  per 
Member  State  is  set  at  EUR  1  million106,  while  it should  be  highlighted  that  the  costs  will  differ 
widely between Member States due to the amount of border crossing points, traveller volume and 
implementation choices. 

Training personnel on how to handle and accept DTCs is not expected to be a significant cost factor 
for Member States. Based on the costs for training border management personnel to learn about the 
EES  (which  is  more  complicated  than  Digital  Travel  Credentials),  the  maximum  cost  for 
developing  training  materials  (e.g.  an  e-learning  tool)  is  estimated  at  EUR  30  000  per  Member 
State.  

Based  on  the  above,  and  to  factor  in  differences  in  the  national  systems  and  to  account  for  a 
reasonable  overhead,  the  one-off  cost  per  Member  State  is  evaluated  at  approximately  EUR  2 
million. 

However, those costs will be offset by the recurring benefits associated with increased security and 
a more efficient use of resources for carrying out border checks.  

The  following  tables  present  scenarios  based  on  uptake  of  DTCs  (percentage  of  persons  crossing 
the external borders with a DTC at 0% 10%, 35%, 60% and 80%) as well as time and money saved 

106 EUR 1 million would allow a Member State to procure and install up to 25 new  e-gates or re-fit several existing 
ones to handle DTCs. 

67 

 
 
annually  according  to  average  EU  hourly  labour  costs  in  2022107  of  EUR  30.5.  The  percentages 
representing the uptake of DTCs by travellers progress from status quo (0%) and (10%) pessimistic 
to  very  optimistic  (80%),  motivated  by  the  results  of  the  public  consultation  and  Eurobarometer 
survey. The scenarios only  consider EU citizens due to  the multiplicity of factors that impact  the 
average border check time on third country nationals108. The scenarios also optimistically consider 
that only 65% of border checks are carried out at manual booths (1 booth one border guard), while 
the remaining 35 % of border checks are carried out with e-gates (allowing a single border guard to 
supervise the operation of up to four e-gates at once). The duration of a border check at a manual 
booth  is  set  at  30  seconds,  at  e-gate  at  25  seconds  and  a  check  with  DTC  at  8.8  seconds.  Since 
checks on exit with a DTC can exclude the physical check of the travel document, the duration of a 
DTC  check  goes  down  to  2-4  seconds.  Taking  a  conservative  approach,  and  considering  that  the 
share of checks on exit and entry in the scenarios is 50/50, the average time for a border check with 
a DTC is then set at 6.4 seconds (50% at 8.8 seconds upon entry and 50% at 4 seconds upon exit). 
This means that the introduction of DTCs should lead to a reduction of the time needed for a border 
check at the airport between 8 and 63% on average depending on the uptake of DTCs, as shown in 
the two tables. 

Finally,  all  scenarios  below  focus  on  border  checks  at  air  borders  due  to  the  more  controlled 
environment  as  well  as  the  fact  that  the  pilot  projects  have  been  carried  out  at  airports.  Border 
checks at sea and land borders are subject to more variability due to the different setups as well as 
the differences in infrastructure and take more time than checks at air borders in the current setup. 
Use of DTCs also by TCNs and at all types of border crossing points should therefore lead to 
even greater cost savings than those presented below. 

The first table represents the situation at a medium-sized airport where 7 million border checks are 
carried out annually, 4.55 million at manual inspection lanes and 2.45 million at e-gates. 

DTC uptake % 
Travellers non-DTC, time in h 
Travellers DTC, time in h 
Entire time in h 
Cost in EUR 
Saving compared to scenario 0 in 
EUR 
Saving compared to scenario 0  

Scenario 
0 
0% 
42,170 
0 
42,170 

Scenario 
1 
10% 
37,953 
918 
38,871 
1,286,200  1,185,600 

Scenario 
2 
35% 
27,411 
3,212 
30,623 
934,000 

Scenario 
3 
60% 
16,868 
5,507 
22,375 
682,400 

Scenario 
4 
80% 
8,434 
7,342 
15,776 
481,200 

100,600 
8% 

352,200 
27% 

603,800 
47% 

805,000 
63% 

107  Employee  compensation  including  wages,  salaries  in  cash  and  in  kind,  employer’s  social  security  contributions, 
vocational training costs, other expenditure costs such as recruitment costs, spending on work clothes and employment 
taxes  regarded  as  labour  costs,  minus  any  subsidies  received.  Total  labour  cost  divided by  corresponding  number  of 
hours worked. Source: Eurostat: .  
108  E.g.,  whether  persons  enjoy free  movement  rights,  whether  persons  are  subject  to  EES,  whether  they  are  already 
registered in EES or not, whether there are additional queries to be made with regard to entry conditions etc. 

68 

 
  
  
  
 
 
The  second  table  represents  the  scenario  based  on  2022  where  approximately  360  million  border 
checks were carried out at external air borders, 234 million at manual  lanes and 126 million at e-
gates109. 

DTC uptake % 
Travellers non-DTC, time in h 
Travellers DTC, time in h 
Entire time in h 

Cost in EUR 
Saving compared to scenario 0 
in EUR 
Saving compared to scenario 0 % 

0 

47,200 

Scenario 
1 
10% 

Scenario 
0 
0% 

Scenario 
2 
35% 
2,168,750  1,951,875  1,409,688 
165,200 

Scenario 
3 
60% 
867,500 
283,200 
2,168,750  1,999,075  1,574,888  1,150,700 
35,096,40
66,146,90
0 
0 
31,050,50
0 
47% 

48,034,10
0 
18,112,80
0 
27% 

5,175,100 
8% 

60,971,80
0 

Scenario 
4 
80% 
433,750 
377,600 
811,350 
24,746,20
0 
41,400,70
0 
63% 

While the times and costs estimated above only relate to the activity of carrying out border checks 
actively on persons, and exclude time spent e.g. on training, patrolling and other activities carried 
out in between flights and passenger flows, the tables provide a general idea about the cumulative 
savings that can be achieved as the uptake of DTCs increases. 

The estimates of the time savings presented above are therefore based on the interim results of the 
pilot  projects  using  the  DTC  at  airports.  Since  65%  of  the  border  crossings  in  2023  were  at  air 
borders, it can be expected that this type of border crossing point also represents the highest uptake 
of  DTCs.  However,  the  time  savings  at  both  sea  (4%  of  crossings)  and  land  borders  (31%  of 
crossings)  are  expected  to  be  similar  or  even  greater  than  those  at  air  borders.  Sea  borders  with 
frequent traffic, similar to air borders, are generally controlled environments and are set up indoors 
with multiple lanes with either manual booths or e-gates for carrying out border checks. The actual 
border  check  process  is  moreover  the  same  for  all  types  of  border  crossing  points,  but  for  land 
borders, may include added complexity. Drivers, their passengers and bus patrons may be required 
to  exit  their  vehicles  for  border  control,  especially  following  the  entry  into  operation  of  the 
Entry/Exit  System  for  third-country  nationals  to  enrol  their  personal  data  (passport  data,  facial 
image,  fingerprint,  travel  data  and  entry  questionnaire).  If  DTCs  were  introduced  to  these  flows, 
allowing travellers to pre-enrol several pieces of data required for the system, additional time will 
be saved as they would not necessarily need to exit the vehicle and enrol their data at a self-service 
system  (kiosk)  or  at  the  manual  booth.  This  is  due  to  the  fact  that  they  have  successfully  pre-
submitted their DTC along with the necessary travel information to the border guards, and a simple 
verification of the identity of traveller would be sufficient at the actual time of crossing the border. 

Based on the above, the cumulative effects of the time saved at sea borders can be expected to be 
similar  to  that  of  air  borders,  but  even  greater  for  land  borders.  However,  before  the  entry  into 

109 However, as stated above, it should be noted that this is a highly optimistic scenario as several Member States had 
not yet deployed e-gates and the share of border checks at e-gates was in reality significantly lower. Moreover, under 
this scenario, 100% of travellers are processed in the EU nationals’ workflow. 

69 

 
  
  
  
 
 
operation of the Entry/Exit System and before DTCs have been piloted particularly at land borders, 
it  is  not  possible  to  provide  precise  estimates  of  the  potentially  increased  time  savings  at  land 
borders. These recurrent benefits should be examined in detail in the ex-post evaluation.  

3.  EU-LISA 

The methodology for eu-LISA’s cost estimate for the development and maintenance of the mobile 
application for creating and transmitting DTCs is based on a high-level requirements mapping, that 
sets out the basic functionalities of the application.  

Table 1 – High-level requirements for the “EU Digital Travel application” 

Requirement 

Further Description  

INCLUDED (In-Scope) 

Requirement 1 

Creation of ICAO DTC virtual component: User to extract the data from their 
ICAO  doc  9303  compliant  eMRTD  (ePassport  or  EU  identity  card)  by  first 
scanning with optical character recognition the machine readable zone (MRZ) or 
manually inserting the card access number (CAN). This is necessary for the key 
agreement protocol, to generate session keys and to access the chip.  

Requirement 2 

Requirement 3 

Requirement 4 

Document verification: Once the chip data has been copied, the Travel EU app 
should carry out passive authentication (PA: check all individual hashes of data 
groups and hash of hashes in the SOD and check the CSCA root, therefore need 
to have access to PKI) as well as active or chip authentication, depending on the 
travel  document  (AA/CA:  challenge  sent  to  physical  chip  and  response 
received). To note, however, that some travel documents do not support AA/CA 
and  it  will  be  a  later  policy  choice,  which  travel  documents  could  be  accepted 
despite this lack of support.  

If the validation fails, the process will stop, prompting an error message that the 
travel document is not eligible.  

Biometric matching: DG2 of the travel document chip contains the facial image 
portrait of the travel document holder. The Travel EU app should be able to carry 
out a one-to-one verification of identity of the live user against that image. The 
system  should  have  capabilities  to  detect  morphing  and  presentation  attacks  as 
well  as  carry  out  liveness  checks.  If  the  biometric  matching  fails  or  if  the  app 
detects an attack, the process will stop, prompting an error message.  

Consultation  of  ICAO  DTC  virtual  component  in  the  EUDIW:  The 
legislative initiative will allow national authorities to create a DTC on behalf of 
EU citizens, e.g. when they issue a new physical passport. The authorities would 
send the DTC to the EU citizen’s digital wallet based on EU requirements. The 
Travel  EU  app  should  be  able  to  retrieve  and  use  that  DTC  (as  opposed  to 
creating  a  new  one)  for  EU  citizens.  In  this  flow,  there  is  no  need  to  carry  out 
additional document verification or biometric matching. 

Requirement 5  Entry  of  travel  related  data:  The  Travel  EU  app  should  present  a  series  of 
questions, depending on the profile of the traveller (based on nationality as stated 

70 

 
 
Requirement 

Further Description  

in  the  travel  document),  that  are  necessary  for  determining  the  travel 
route/competent  Member  State  (for  EU  and  TCNs)  and  for  assessing  the  entry 
conditions (for TCNs). 

EU  citizens:  Intended  travel  date,  window  of  time  for  crossing  the  border  (e.g. 
1400h-1800h), Member State, border-crossing point. 

TCNs: Intended travel date, window of time for crossing the border (e.g. 1400h-
1800h),  Member  State,  border-crossing  point  +  visa/residence  permit/ETIAS 
number, possible additional questions of entry conditions. 

Users  should  be  able  to  re-submit  the  DTC  (+  travel  related  data)  in  case  they 
made a mistake or there is a change in travel plans.  

Requirement 6 

Storage of personal data: No personal data will be stored in a database at EU 
level as all data is directly sent by traveller via the EU Digital Travel application 
to  the  relevant  Member  State.  The  DTC  will  be  stored  locally  on  the  user’s 
device  and  protected  against  unlawful  use  (PIN/biometrics).  The  app  should 
present data processing rules to users and ask consent. 

Requirement 7 

Security  measures: 
the  app  should  prevent  cyberattacks  and  software 
applications that run automated tasks (bots). Abuse such as multiple submissions 
(DoS/DDoS) in a short period of time should also be prevented. 

Submission of data and acknowledgement of receipt: Once the data has been 
entered,  user  chooses  to  send  the  data  to  the  competent  Member  State. 
Submission could take place e.g. between 48 and 4 hours prior to arrival (TBC). 
The data is transmitted using a secure communication channel in which the data 
is encrypted. If the transmission fails, user can try again.  

Requirement 8 

The  user  should  receive  an  acknowledgment  of  receipt  from  eu-LISA  that  the 
data was successfully transmitted (no additional data, only that the data has been 
sent to MS X). At a later stage, additional info would follow (see req. 9). 

The  MS  in  question  determines  how  that  data  is  further  used  and  transmitted 
onwards  to  the  relevant  BCP  and  inspection  devices.  The  transmission  solution 
should  be  connected  to  each  Member  State  and  capable  of  transmitting  the 
different  types  of  data  (DTC  +  facial  image  taken  for  the  matching  in  req.  3, 
where  applicable, other travel  data) to  the relevant  MS based on the travel  info 
submitted by the user. 

Requirement 9 

Messaging/instructions:  Users  shall  receive  notifications/messages  in  the  EU 
Digital Travel application, submitted by the competent Member State (including 
possibly  a  digitally  signed  2d  barcode  to  be  encoded  by  competent  Member 
State)  to  eu-LISA.  The  message  should  include  instructions  on  which  booth/e-
gate to proceed to at the BCP etc (as stated by competent MS). 

Requirement 
10 

Statistics  and  logging:  The  Travel  EU  app  is  able  to  collect  basic  statistics  on 
user  volume,  number  of  submitted  entries,  nationalities,  modes  of  transport, 
number  of  failed  transmissions,  number  of  failed  biometric  matches  (+ 

71 

 
Requirement 

Further Description  

nationalities and reasons) and failed document authentications (+ country of issue 
and reasons). 

Logging capabilities are supported by the Travel EU app as required by law (data 
protection and should be hack-proof).  

User  interface  and  help:  The  Travel  EU  app  should  be  available  for  iOS  and 
Android mobile devices. Upon installation, access control should be set up (e.g. 
PIN/biometric verification) to access the application in the future. 

Requirement 
11 

Users  should  be  assisted  with  a  FAQ,  clear  instructions.  The  app  should  be 
available in the 24 official languages as well as some common foreign languages 
(e.g. Arabic, Chinese, Japanese, Korean, Russian, Serbian, Turkish). 

User  volume:  different  scenarios  of  uptake  of  the  app,  e.g.  1  million  users, 
10 million users, 100 million users. 

EXCLUDED (Out-of-Scope) 

1.  Automatic checks  with  interoperability components: The Travel  EU app 
will  not  be  connected  to  or  consult  the  interoperability  components  or 
other databases. Any checks using those components  and other database 
queries will be carried out by the competent Member State after receiving 
the data. 

2.  Any  inspection/verification  of  the  data  submitted  (apart  from  the 
document  verification  and  biometric  matching  services)  by  EU  agencies 
is excluded.  

3.  Once the data are transmitted, the national authorities are responsible for 

the checks to be carried out and further contacts with the traveller. 

In  addition  to  the  high-level  requirements,  several  assumptions  were  made  to  facilitate  the  cost 
estimate: 

▪  No more than 200 000 users per day with peaks of 10 per second; 
▪  Travel EU app will be based on the API Router components re-use for transmission; 
▪  The user will not be able to update the request, but can re-send a submission; 
▪  The validation of the DTC is based on ICAO standards; 
▪  The content of the FAQ will not be managed by eu-LISA; 
▪  The legislative act will be adopted in 2025 so that preparation can begin in 2026. 

eu-LISA based its estimations on prior experience with the EES/ETIAS Web Services project, on 
which the API Router will be based. The Travel  EU app will also rely on the API Router for the 
transmission part. As estimated by eu-LISA, the total cost for the Agency to develop the EU Digital 
Travel application is estimated at EUR 49.5 million, with additional staff needs of 2 FTE for 2027, 
17.5 FTE for 2028, 19 FTE for 2029 and 20 FTE for 2030 and 2031. It is envisaged that the profiles 
will be recruited in phases according to the business needs: 

72 

 
 
 
 
For  the  first  year  after  adoption,  limited  support  may  be  provided  to  the  Commission  in  the 
development of implementing acts for the technical specifications. 

For  the  technical  design,  build  &  development  phase,  key  resources  will  be  needed  combining 
expertise in IT architecture, business analysis, testing, security, project & programme management, 
the  elaboration  of 
infrastructure/network/application  management).  They  will  work  on 
specifications  /  requirements  solicitation  as  well  as  on  all  analysis  and  design  tasks  in  close 
cooperation  with  the  contractors.  They  will  perform  the  necessary  assessments,  will  kick  off  all 
projects (work packages) and ultimately conclude this part of implementation with the production 
of the detailed design of the solution. 

A  combination  of  transversal  resources  (procurement,  finance,  HR,  business  relationship  and 
stakeholders’  management,  communication,  security,  corporate  IT)  is  also  included.  In  order  to 
deliver a “fit for purpose “and tailored solution, significant pressure will be put on this phase and 
knowledge  of  experts  in  the  domain  is  highly  recommended.  Particular  security  requirements  to 
build the EU Digital Travel application with hosting services in the cloud, reusing also API router 
components  for  the  transmission,  can  be  only  met  by  skilled  security  officers  and  experienced 
architects and test engineers. 

Specifically,  for  the  business  relations  management  profiles,  it  has  to  be  taken  into  consideration 
that they will provide continuous support during the ‘analysis and design’ phase, as well as during 
the  testing,  deployment  and  throughout  the  whole  governance  with  all  involved  stakeholders’ 
phases  until  the  entry  into  operations  (EiO).  More  specifically,  they  are  required  for  business 
analysis,  requirements  and  demand  management,  consultancy  and  coordination  with  all  involved 
internal and external stakeholders. The profiles will in particular be responsible for analysis of the 
business  and  its  interdependencies  across  all  involved  domains,  elicitation  and  analysis  of  the 
business  /  stakeholders  requirements,  coordination  with  internal  /  external  stakeholders  and  the 
governance, follow-up and validation of deliverables / artefacts and continuous internal / external 
guidance. They need to master the topic, have concrete knowledge, years of experience in business 
analysis,  certifications,  experience  in  the  involved  business  and  capable  at  analysing  numerous 
interdepended legal documentations, especially in the JHA domain. They must have the ability to 
explain  in  detail  and  thus  provide  the  expected  high  quality  structured  advice  to  all  involved 
stakeholders  and  governance,  as  well  as  work  closely  with  the  internal  teams  to  determine 
acceptable technological solutions which will comply with high quality standards. 

For  the  Operations  phase,  on  top  of  the  expertise  and  combination  of  skills  in  the  areas  of 
infrastructure,  network,  security  and  testing,  eu-LISA  will  require  resources,  adding  expertise  on 
service  management  and  first  and  second  level  support,  complementing  the  resources  already 
acquired  in  the  previous  phase,  in  development,  test  and  deployment  of  the  final  solution.  These 
resources will properly monitor, operate and debug the system, in order to meet the agreed level of 
the required SLAs and respond to intense monitoring and security requirements. The requested mix 
of profiles will ensure that best practices from project management as well as ITIL frameworks will 
be properly applied. 

Especially  for  the  test  management  profiles,  the  proposed  level  of  seniority  is  needed  as  there  is 
increased  complexity  on  maintaining  several  mobile  app  products,  that  requires  senior  level  of 
experience to conduct efficiently the tasks. Moreover, very specific Public Key Infrastructure (PKI) 

73 

 
and  biometric  expertise  is  necessary  to  test  the  functionalities  of  the  product,  when  reading  chip 
data and performing biometric matching / detecting morphing probability. 

Regarding  product  management  profiles,  it  has  to  be  emphasised  that  the  EU  Digital  Travel 
application  should  not  be  seen  as  an  extension  of  already  developed  systems.  There  are  new 
parameters  introduced  in  the  equation  making  this  implementation  stand  as  a  separate  product, 
within the domain of the systems developed by eu-LISA. 

Regarding security profiles, in order to ensure the provision of proper security services for the EU 
Digital Travel application and support the transversal delivery model setup, an assessment against 
current allocated resources for the EES/ETIAS WS development (Carrier Interface) as well as the 
API Router was performed. 

In  more  detail,  the  same  resources  will  be  needed  for  both  phases  i.e.,  development  & 
operation/maintenance. For example, the profile for security testing will be performing tasks during 
development  and  continue  to  test  under  operations  and  maintenance  on  a  recurrent  basis.  In 
practice, the same profile will serve both phases chronologically. Moreover, business continuity as 
well  as  protective  security  profiles  are  also  needed,  in  order  to  properly  support  the  increased 
physical and personnel security needs. 

Regarding infrastructure management profiles, the rationale is to have in 2027 the profiles to work 
on  the  design  phase  of  the  platforms,  then  in  2028  they  will  be  working  on  the  design  and 
documentary  reviews  as  well  as  on  build  &  deployments.  From  2029  and  onwards  the  indicated 
resources will be needed to properly operate and maintain the system. 

Concerning  the  network  management  profiles,  the  resources  are  considered  necessary  for  both 
phases,  as  the  services  to  be  provided  (hosting  lines  installation  and  operational  management, 
DDOS installation and operational management, network infrastructure installation and monitoring, 
etc.)  require  the  associated  expertise  and  knowledge  for  the  relevant  installation  as  well  as 
operational  tasks.  Concerning  functions  in  support  to  operations  (1st  and  2nd  level  support),  it  is 
necessary  to  plan  resources  that  allow  24/7  operation.  While  the  tasks  related  to  the  operational 
support may constitute a fraction of 1 FTE and be added as an additional task to the current staff, 
ensuring a full shift-work cycle is necessary. 

Table 2 – eu-LISA’s estimated staff needs 

Posts 

2027 

2028 

2029 

2030 

2031 

2.0  

9.0  

9.0  

9.0  

9.0  

-    

-    

-    

-    

-    

Temporary 
agents (AD) 

Temporary 
agents 
(AST) 

Contract 
agents 

74 

 
 
                 
                 
                 
                 
                 
 
                   
                   
                   
                   
                   
 
                   
                 
                
                
                
 
(FGIV) 

-    

8.5  

10.0  

11.0  

11.0  

Contract 
agents 
(FGIII) 

TOTAL 

Calculation 
of 
salary 
costs (EUR) 

Temporary 
agents (AD) 

Temporary 
agents 
(AST) 

Contract 
agents 
(FGIV) 

Contract 
agents 
(FGIII) 

TOTAL 

-    

-    

-    

-    

-    

2.0  

17.5  

2027 

2028 

19.0  

2029 

20.0  

2030 

20.0  

2031 

Total 
2027-2031 

178,000  

979,000  

1,602,000  

1,602,000  

1,602,000  

5,963,000  

-    

-    

-    

-    

-    

-    

-    

403,750  

878,750  

997,500  

1,045,000  

3,325,000  

-    

-    

-    

-    

-    

-    

178,000  

1,382,750  

2,480,750  

2,599,500  

2,647,000  

9,288,000  

75 

 
                   
                   
                   
                   
                   
 
                 
                
                
                
                
 
          
          
       
       
       
       
                   
                   
                   
                   
                   
                   
                   
          
          
          
       
       
                   
                   
                   
                   
                   
                   
          
       
       
       
       
       
 
ANNEX 5: COMPETITIVENESS CHECK  

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS  

The preferred option has no or at best negligible impacts on the different dimensions of 
competitiveness. Therefore, the competitiveness check is not relevant for this initiative.  

Dimensions 
Competitiveness 

Impact of the initiative 

of 

(++ / + / 0 / - / -- / n.a.) 

References  to  sub-sections  of  the 
main report or annexes 

Cost and price competitiveness  n.a 

International competitiveness  

n.a 

Capacity to innovate 

SME competitiveness 

n.a 

n.a 

2.  SYNTHETIC ASSESSMENT  

N/A 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX  5:  SUMMARY  OF  THE  PILOT  PROJECT  IN  FINLAND  AND 
CROATIA 

1. 

INTRODUCTION 

In order to support the Commission’s legislative initiative on the digitalisation of travel 
documents and facilitation of travel, EU-funded pilot projects were launched to trial the 
use of digital travel credentials in a border-crossing environment. This annex reports on 
the interim results from the project undertaken jointly by Finland and Croatia, which was 
awarded EU funding under the Border Management and Visa  Instrument  (BMVI). The 
pilot  project  tests  the  development  and  use  of  a  Digital  Travel  Credential  (DTC)  for 
border checks at air borders and tests the creation and verification of a digital residence 
permit. Following a description of the general objectives of the project, the outcomes are 
presented according to the project work package, some legal and practical considerations 
are raised, and interim conclusions are put forward. 

2.  PROJECT OBJECTIVES 

The  primary  goal  of  this  project  is  to  design,  develop  and  field-test  an  IT  solution  that 
implements  the  DTC  (type  1)  standard  published  by  the  International  Civil  Aviation 
Organization  (ICAO),  the  global  body  responsible  for  ensuring  the  interoperability  of 
travel documents. Data collected during the project can also be used as an evidence base 
for  assessing  further  stages  of  digitalisation.  A  secondary  goal,  for  the  participants  in 
Finland,  is  to  explore  the  potential  of  a  digital  residence  permit  as  an  alternative  or  a 
complement to the physical residence permit in credit-card format (TD1 format). 

Regarding  the  DTC,  the  project  trials  the  feasibility  of  using  a  DTC  –  created  using 
biographical  and  biometric  data  derived  from  a  passport  with  a  chip  –  to  allow  a 
passenger  to  submit  travel  details  to  border  authorities  in  advance  of  travel,  and  to 
process  a  passenger  through  border  control  using  biometric  data  (the  facial  image) 
contained in the DTC. The project seeks to collect data on waiting and processing times 
per  traveller  at  the  physical  border-crossing  point,  to  determine  if  clearance  is  faster 
when  border  authorities  have  more  time  to  process  individual  travellers  who  submit  a 
DTC in advance. 

Finland  is  testing  and  analysing  chip-reading  software  that  identifies  flaws  in  genuine 
documents  and  corrects  them  before  the  verification  process  is  carried  out,  so  that  no 
'unnecessary' warnings have to be shown to the inspector. 

Regarding the digital residence permit, the project (in Finland only) seeks to examine the 
possibility to  embed biometric data (the  facial  image) of  sufficient  output quality  to  be 
integrated into a 2D-barcode. The aim of the study is to harmonise the findings with the 
ICAO  data-structure for barcodes standard to enable global interoperability.  

3.  PROJECT IMPLEMENTATION AND OUTCOMES 

The project is structured into eight work packages, consisting of one project governance 
package and seven substantive packages incorporating system development, roll-out and 
field testing. 

77 

 
 
3.1 Governance work package 

A  project  steering  committee  was  set  up  in  January  2023  to  define  the  scope  of  the 
project, specify the solution requirements, and establish a project schedule. The steering 
committee also coordinates the work among all project participants, including reporting 
to the Commission and financial monitoring. 

3.2 System development work package 

3.2.1 System development (Croatia) 

The aim of this work is to test the use of the existing digital identity wallet, developed by 
Certilia for users of Croatian digital identity services, at Croatian border control, once the 
app is upgraded to include additional functionality to handle a DTC.  

The Croatian participants developed a digital identity wallet solution for mobile Android 
and iOS devices with a functionality to import and submit a DTC to border officials for 
advance  processing.  In  parallel,  they  developed  a  system  in  a  secure  environment  that 
creates  and  stores  a  DTC  derived  from  the  data  in  the  chip  of  a  passport.  Users  who 
register  to  participate  in  the  pilot  project  can  request  the  creation  of  a  DTC  to  be 
imported into their digital wallet on a mobile device. The system was available to receive 
requests  for  a  DTC  as  from  September  2023  for  Android  users  and  as  from  December 
2023 for iOS users. 

The  IT  equipment  required  to  process  a  passenger  holding  a  DTC  was  installed  and 
tested  in  September  2023  at  the  border-control  point  in  Zagreb  Airport.  The  system 
includes  document  inspection  system  software  to  read  the  DTC  and  perform  a  facial 
biometric match comparing a live photo with the photo contained in the DTC submitted 
in advance. 

3.2.2  System development (Finland) 

This work aimed to deliver a solution which includes: 

•  a digital identity wallet with the ability to import a DTC and submit it 

prior to travel; 

•  a kiosk for registering participants with pseudonymised personal data 

(for GDPR-compliance); 

•  a portal to receive the DTC submitted by users in advance, 

•  a  DTC  inspection  system  at  the  airport  border-crossing  point, 
supporting  facial  biometric  matching,  as  well  as  clone  detection 
performed on the passport chip. 

The initial version of the digital wallet app (Android and iOS) was released in July 2023. 
The digital wallet has advanced security features, including mobile device authentication, 
encrypted data storage, and mandatory participant registration at the kiosk to enable the 
wallet to receive the encrypted DTC. 

78 

 
 
In July 2023 a registration kiosk was set up at Helsinki Airport, where participants in the 
trial present their passport to a border control officer. Using the kiosk, the officer scans 
the  passport,  enabling  the  kiosk  to  perform  security  checks  on  the  passport  chip  and 
verify the data used to create the DTC, which the kiosk then sends to the digital identity 
wallet in encrypted form.  

A submission portal was deployed in July 2023. The portal functions as the system’s data 
processing hub, as it receives the DTC submitted by a passenger for advance processing 
and  communicates  with  a  border  control  officer  who  screens  the  participant  using  the 
existing  systems  and  workflow.  The  officer  either  clears  or  rejects  the  passenger,  and 
enters the result of this pre-screening, recording a reason in the case of a rejection. 

A  DTC  document  inspection  system  was  installed  in  July  2023  at  an  existing  manual 
passport control booth. The inspection system periodically connects with the submission 
portal  to  download  the  approved  DTCs  submitted  by  passengers  crossing  the  border  in 
the next 24 hours, stores them locally, and extracts the facial biometric from the DTC for 
matching. When a passenger approaches the booth, the inspection system camera takes a 
live  photo  and  matches  it  to  a  photo  stored  locally,  thereby  retrieving  the  passenger’s 
DTC. The inspection system then verifies the DTC, and the e-passport chip, allowing the 
officer  to  clear  the  passenger  and  open  the  border  gate.  Should  the  process  fail  at  any 
point,  the  officer  processes  the  passenger  using  the  existing  systems  and  in  the  normal 
workflow. 

3.3  System integration work package 

3.3.1  System integration (Croatia) 

Integration  between  the  submission  portal  and  the  inspection  systems  at  the  border-
crossing  point  was  fully  achieved.  Passengers  are  able  to  submit  a  DTC  directly  from 
their digital wallet app to the submission portal for advance border screening.  

The  objective  of  integrating  the  system  with  external  systems  was  only  partially 
achieved.  Integration between the submission  portal for  creating and storing DTCs and 
the Ministry of Interior system for retrieving available travel locations was implemented 
in  September  2023.  However,  integration  with  Finland,  or  any  other  country,  for 
submission  and  receipt  of  each  other’s  DTCs  was  not  achieved.  This  non-integration 
prevents  any  full  end-to-end  testing  of  the  DTC  systems  during  a  single  trip  between 
Helsinki  and  Zagreb  (as  opposed  to  testing  only  locally  in  Helsinki  and  locally  in 
Zagreb). 

3.3.2  System integration (Finland) 

This  work  aimed  at  integrating  various  components  of  the  DTC  system  so  they  could 
communicate with each other (for instance, registration kiosk with back-office approval 
system,  submission  portal  with  inspection  system).  The  possibility  of  also  integrating 
with selected external systems used during the passenger travel continuum was explored. 

The only integrations successfully executed were between the registration system (kiosk) 
and  the  submission  portal  (advance  border  approval),  on  the  one  hand,  and  the 

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submission  portal  and  the  inspection  system,  on  the  other.  Full  integration  of  these 
subsystems  was  completed  in  August  2023.  Integration  with  external  systems  such  as 
airline  check-in  or  communication  with  Croatian  systems  for  mutual  submission  and 
receipt  of  DTCs  were  not  carried  out.  Similarly,  integration  between  the  submission 
portal  and  the  existing  Finnish  Border  Guard  secure  network  running  border  control 
applications was not possible due to data security regulations and the available time.  

3.4  Field test work package 

3.4.1  Pilot field test (Croatia) 

The aims of the field test included recruiting and informing participants, training border 
control  staff,  deploying  the  systems  and  infrastructure  at  Zagreb  Airport,  executing  the 
live trial and collecting data about the results. 

Potential  participants  were  invited  to  take  part  in  the  pilot  during  several  large-scale 
events  and  conferences  in  Zagreb,  as  well  as  via  media  interviews  with  project  team 
members. The required infrastructure and systems were in place at Zagreb Airport from 
early  October  2023,  while  border  control  officers  received  training  on  the  new  DTC 
border application by end-September 2023. 

The field test is currently running since October 2023, with statistics (number of DTCs 
created,  number  of  travel  submissions  to  border  control,  number  of  border  crossings 
using the DTC) collected in real time, with participation by users of the Android mobile 
app since the start, and iOS users from end-December 2023. 

By December 2023,  around 6200  DTCs  were  created  and stored in  digital  wallets,  223 
travel announcements were submitted to border control, while 58 border crossings using 
a DTC were recorded. 

3.4.2  Pilot field test (Finland) 

The aim of this work was to prepare the ground for a live trial run – through participant 
registration, training of border staff, and installation of a dedicated DTC passenger lane – 
and then proceed to live testing of DTC processing at Helsinki airport.  

Preparatory tasks involved training airport staff (registration kiosks) and border officers 
(advance  screening  and  onsite  DTC  inspection),  drafting  reference  manuals  for  the 
various functions, and communications outreach via online media and press. 

The live trial  started on 28 August 2023 when registrations opened, with the first  DTC 
being  used  for  a  flight  to  London  on  1  September  2023.  Initially,  the  trial  tested  DTC 
border crossings for Finnair outbound flights to London, Manchester and Edinburgh. Due 
to  the  Russian  hybrid  influence  during  autumn  2023,  the  pilot  had  to  be  temporarily 
suspended at Helsinki Airport. A substantial part of the DTC-trained control staff had to 
be deployed to support the eastern border-crossing points. Customers were informed of 
the suspension.  

The  DTC  piloting  resumed  on  19  December  2023  by  training  the  entire  border  control 
staff in the use of the DTC system. In this context, the inspection lines were moved to a 

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new location where both EU citizens and DTC passengers are checked at the same point 
with  DTC  passengers  having  priority.  The  temporary  suspension  of  the  pilot  had  some 
impact  on  the  number  of  DTC  checks.  According  to  estimates,  during  the  suspension, 
approximately 150 DTC checks were missed. 

In  December,  DTC  use  was  enabled  for  all  Finnair  outbound  flights  from  Helsinki 
Airport involving a border check (extra-Schengen). 

The  trial  results  as  of  30  November  include:  292  registered  DTC  users,  203  border 
checks,  with  the  average  border-crossing  time  under  eight  seconds  (compared  with  e-
gates, at 20 to 25 seconds). 

Case study: effectiveness of advance checks 

The  DTC  pilot  project  in  Finland  involved  a  person  who  booked  an  appointment  at  a 
police registration point. At the time of registration, the person's background check did 
not return any hits in the relevant databases and a DTC record was created for the person. 
At a later stage, a warrant concerning the person was issued in the databases. When the 
person  sent  the  DTC  data  for  a  pre-verification  check,  the  advance  check  rejected  the 
person  due  to  the  new  hit,  making  the  DTC  data  unavailable  at  the  DTC  checkpoint. 
Once the person attempted to travel and use the DTC at the border (exit check Helsinki-
London Heathrow), the border guard noticed that the DTC data could not be found. The 
officer  requested  the  passenger's  passport  and  ran  a  background  check  on  the  national 
border management system and found that the person had a valid warrant. The customer 
was directed to the second line check, where his case was processed to completion. 

3.5  Digital residence permit work package 

The  objective  of  this  work  is  to  specify  some  requirements  for  a  fully  digital 
(dematerialised)  residence  permit,  including  minimum  data  requirements  for  a  facial 
biometric which is  usable for identification but  also  encodable in  a digitally signed 2D 
barcode small enough to fit feasibly on a mobile device.  

Analysis  showed  that  facial  images  held  in  the  Finnish  Immigration  database  were 
captured in a wide variety of file formats and data quality, some uncompressed (lossless) 
and others compressed (lossy). The study established the minimum requirements for an 
input facial image in order to achieve an output compressed image of sufficient quality to 
be used for automated biometric facial comparison.    

The  minimum  requirements  for  an  input  image  of  a  digital  residence  permit  were 
established  to  have  to  be  lossless  and  of  high  resolution.  Otherwise,  the  output  image 
would  not  meet  the  requirements  for  manual  visual  comparison  or  automated  facial 
comparison. Technical specifications determining the criterions and processing of facial 
images is in preparation. The specifications will include a model of a mobile application 
enabling reading the residence permit 2D-barcode. 

The  analysis  also  determined  that  compression  yielded  the  best  results  when  the  input 
image is lossless and captured at high resolution. 

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These results point to the need for a high-resolution capture and storage in RAW format 
of images to be used in travel documents. A technical specification is in preparation for 
input  images  that  are  well  suited  for  automated  facial  recognition,  as  well  as  for 
compression to encode in a 2D barcode. 

4.  NOTEWORTHY OBSERVATIONS AND QUESTIONS RAISED 

Several questions and observations were raised during the planning and execution of the 
pilots, some of which require policy choices at Union level: 

4.1 Digital wallet ownership and liability — who bears liability in the event of 

damages due to non-performance of the mobile digital wallet app? 

4.2 DTC encryption — DTC data is currently stored encrypted in the digital 
wallet,  due to  concerns raised by data protection authorities. As a result, 
the  DTC  is  not  interoperable,  since  the  key  to  decrypt  the  DTC  data  is 
held by the submission portal, meaning the user cannot decrypt their data 
for submission to a foreign border authority. 

4.3 Airline  passenger  data  —  the  DTC  system  is  not  integrated  with  airline 
check-in  systems.  Consequently,  the  passenger  is  required  to  do  two 
things  rather  than  one  –  flight  check-in,  then  DTC  submission  – 
introducing  a risk of error, and the obvious reduced facilitation. Airlines 
show reluctance to integrate their systems due to uncertainty about GDPR 
compliance, and how far their responsibility for passenger data extends. 

4.4 Secure  messaging  —  the  pilot  demonstrated  a  need  for  a  standardised 
to  be 

secure  message 
the  DTC 
interoperable and hence submittable to a foreign border authority. 

transmission  protocol, 

to  allow 

4.5 Various IT and process issues arose during the live trials that needed to be 
resolved. For example, the image quality of a passenger photo captured at 
registration  was  initially  poor,  due  to  lighting  causing  shadows  on  the 
face.  A  low-quality  image  impacts  the  facial  recognition  phase  of  the 
procedure. Similarly, light reflecting off the screen of the kiosk computer 
caused problems reading the QR codes.  

4.6 The mobile app experienced compatibility issues with different brands and 
models of mobile phones. For example, the app would not work properly 
if the phone’s access control (via PIN, biometric or on-screen pattern) was 
disabled. Following a version update, the app worked on all phones used 
in  the  pilot,  but  in  a  wider  scale  global  roll-out,  full  functionality  of  the 
app  on  all  phones  might  not  be  guaranteed.  Likewise,  the  mobile  app 
functionality  includes  a  messaging  service,  which  was  used  to  send 
surveys  to  customers,  but  the  app  does  not  have  language  support  for 
Finnish or Swedish. 

4.7 The pre-screening of a DTC passenger is done on the submission portal, 
but  legally  required  background  checks  (record  checks)  had  to  be 

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performed  manually  for  each  DTC  passenger.  This  was  because  the 
system  as  built  for  the  pilot  project  is  not  integrated  with  the  existing 
border control application, due to security regulations and available time. 
Had  the  system  been  integrated  with  the  existing  border-control 
application, background checks could have been automated. 

4.8 A survey of the  Finnish  user experience of the pilot  project  showed that 
use  of  the  DTC  is  widely  perceived  as  positive  and  efficient.  65%  of 
respondents “fully agree” that the DTC border check was smooth and fast. 

4.9 A significant time saving was observed when using a DTC during border 
checks,  compared  to  the  usual  manual  document  inspection  —  and  also 
with  automatic  e-gates.  Trial  results  show  the  average  border-crossing 
time is under eight seconds using a DTC. In a sample of 100 passengers of 
all  types  (solo  travellers,  group  travellers,  flight  crew,  etc.)  the  average 
time  for  manual  border  checks  was  30  seconds  per  person,  while  the 
average e-gate check for an EU citizen was 20 to 25 seconds. 

4.10 

Some users reported that they were unable to use their DTC at the 
border  control  checkpoint  in  Zagreb  Airport  where  usage  of  DTC  was 
enabled.  For  some  of  these  cases,  the  reason  was  an  inability  to  use  the 
QR code generated in the mobile wallet  at the border check, while other 
cases  related  to  the  DTC  inspection  system  application  at  the  border  not 
being operational. 

4.11 

When  asked  whether  users  would  continue  to  use  the  DTC  to 
travel, during the collection of feedback in the Finnish project, 82% fully 
agreed.  

5.  CONCLUSIONS 

The  key  finding  of  this  summary  based  on  an  interim  project  report  by  Finland  and 
Croatia  is  that  the  DTC  is  in  a  league  of  its  own  as  regards  the  speed  of  border  check 
procedures,  whether  compared  to  a  normal  border  check  at  a  booth  or  at  an  e-gate.  It 
saves time for the traveller and frees up staff to focus on other border-control tasks. 

An additional benefit of using the DTC is that any necessary identity and travel eligibility 
checks can be performed remotely and securely in advance, before the traveller arrives at 
the airport. 

Some issues that still need to  be addressed include: how to  securely  transfer DTC data 
from  country  of  origin  to  country  of  destination,  and  how  to  transfer  any  travel 
restrictions recorded in a physical passport to the DTC. 

This  pilot  project  trialled  the  use  of  a  “type-1”  DTC,  as  established  by  the  ICAO 
standard. It should be underlined that implementation of a type-2 or type-3 DTC can be 
expected to result in even more benefits to travellers. 

The  DTC  could  maximise  its  potential  if  used  throughout  the  travel  continuum,  by 
carriers,  airport  operators  and  border  authorities.  Travel  facilitation  is  clearly  enhanced 

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by  streamlining  border-control  procedures,  but  other  touchpoints  in  the  journey  could 
also  benefit  from  the  use  of  DTC,  for  example:  baggage  drop-off,  security  screening, 
boarding at the gate. 

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