COMMISSION STAFF WORKING DOCUMENT SUBSIDIARITY GRID 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) 670 final  COMMISSION STAFF WORKING DOCUMENT SUBSIDIARITY GRID 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) 671 final} - {SWD(2024) 672 final}  
 
 
Subsidiarity Grid 

1.  Can the Union act? What is the legal basis and competence of the Unions’ intended action? 

1.1 Which article(s) of the Treaty are used to support the legislative proposal or policy initiative? 

The  legal  basis  for  the  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 credentials1 is Article 77(2), points (b) and (d) of the Treaty on the Functioning of the European 
Union  (TFEU).  It  provides  that  the  European  Parliament  and  the  Council,  for  the  purposes  of 
paragraph  1  of  Article  77  TFEU,  shall  adopt  measures  concerning  the  checks  to  which  persons 
crossing  external  borders  are  subject  (point  (b))  and  concerning  any  measure  necessary  for  the 
gradual establishment of an integrated management system for external borders (point (d)). 

The legal basis for the proposal for a Council Regulation on the issuance of and technical standards 
for  digital  travel  credentials  based  on  identity  cards2  is  Article  77(3)  TFEU.  It  confers  on  the  EU  a 
competence to adopt provisions on, among other things, identity cards that are intended to facilitate 
the exercise of the right to free movement. 

1.2 Is the Union competence represented by this Treaty article exclusive, shared or supporting in 
nature? 

In accordance with Article 4 TFEU, the competence represented by these Articles is shared. 

Subsidiarity does not apply for policy areas where the Union has exclusive competence as defined in 
Article 3 TFEU3. It is the specific legal basis which determines whether the proposal falls under the 
subsidiarity control mechanism. Article 4 TFEU4 sets out the areas where competence is shared 
between the Union and the Member States. Article 6 TFEU5 sets out the areas for which the Unions 
has competence only to support the actions of the Member States. 

2.  Subsidiarity Principle: Why should the EU act? 

2.1 Does the proposal fulfil the procedural requirements of Protocol No. 26: 

-  Has there been a wide consultation before proposing the act? 
- 

Is there a detailed statement with qualitative and, where possible, quantitative indicators 
allowing an appraisal of whether the action can best be achieved at Union level? 

The  following  consultation  strategy  has  been  undertaken  to  support  the  preparation  of  the 
proposals:  
- 

consultations with Member States’ relevant authorities (border authorities, travel document 
issuing  authorities,  policy  makers),  several  European  Commission  services  and  EU  agencies 

1  COM(2024) 670 final. 
2  COM (2024) 671 final.  
3 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E003&from=EN  
4 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12008E004&from=EN  
5 https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E006:EN:HTML  
6 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E/PRO/02&from=EN  

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(such  as  the  European  Border  and  Coast  Guard  Agency  (Frontex),  the  EU  Agency  for  the 
Operational  Management  of  Large-Scale  IT  systems  in  the  Area  of  Freedom,  Security  and 
Justice (eu-LISA), and the EU  Agency for Fundamental Rights  (FRA))  as well as industry and 
international  organisations  and  associations  (International  Civil  Aviation  Organization, 
International  Air  Transport  Association  and  World  Travel  and  Tourism  Council)  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. 

The explanatory memoranda of the proposals and the accompanying impact assessment7 contain a 
section on the principle of subsidiarity.   

2.2 Does the explanatory memorandum (and any impact assessment) accompanying the 

Commission’s proposal contain an adequate justification regarding the conformity with the 
principle of subsidiarity? 

The explanatory memorandum of the 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 states:   

“The current EU legal framework does not allow for the use of digital solutions for remotely verifying 
the authenticity and integrity of travel documents in border checks. Due to the nature of the problem, 
Member States themselves cannot effectively introduce a uniform format for digital travel credentials 
based on travel documents regulated at EU level and so facilitate cross-border mobility. 

EU  action  would  add  considerable  value  in  addressing  the  challenges  related  to  security  and  travel 
facilitation. The current situation affects security at the EU’s borders as well as the proper functioning 
of the external borders and overall Schengen area. While the external borders and the EU as a whole 
are placed under considerable strain, joint EU action would allow us to put in place uniform measures 
to improve integrated border management and reach a minimum level of digital maturity among all 
EU Member States. 

The necessary amendments of the relevant parts of the Schengen acquis (most notably the Schengen 
Borders Code and the EU Passport Regulation) are only possible at Union level. Moreover, for reasons 
of scale, effects and expected impacts, the objectives can only be achieved efficiently and effectively 
at EU level.” 

The  explanatory  memorandum  of  the  proposal  for  a  Council  Regulation  on  the  issuance  of  and 
technical standards for digital travel credentials based on identity cards states: 

“The current Union legal framework does not allow for the use of digital solutions in the context of 
the exercise of the right to free movement. Due to the nature of the problem and the need to ensure 
interoperability, Member States themselves cannot effectively introduce a Union-wide uniform format 
for DTCs based on identity cards, and therefore cannot facilitate the exercise of free movement on the 

7 SWD(2024) 671 final  

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basis of such DTCs. Any national solutions would bear the risk of not being accepted in other Member 
States,  and  would  raise  questions  regarding  their  compliance  with  Union  law  when  used  in  the 
context of free movement. 

This proposal aims to facilitate the exercise of the right to free movement by giving Union citizens the 
option  to  obtain  and  use  DTCs  based  on  their  national  identity  cards.  For  reasons  of  scale  and 
expected impacts, the objectives can only be achieved efficiently and effectively at Union level.” 

2.3 Based on the answers to the questions below, can the objectives of the proposed action be 

achieved sufficiently by the Member States acting alone (necessity for EU action)? 

The EU is committed to facilitating the free movement of persons within an area of freedom, security 
and justice. The shortcomings identified in the impact assessment are inextricably related to existing 
legislation,  notably  the  Schengen  acquis  concerning  passports  and  border  checks,  as  well  as  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  EU  approach  to 
digitalising travel credentials 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). Because of their intrinsic cross-border nature, addressing systemic problems 
clearly requires action with an EU-wide dimension.  

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 the context of cross-border travel. 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.  

(a)  Are there significant/appreciable transnational/cross-border aspects to the problems being 

tackled? Have these been quantified? 

Yes, EU action regarding cross-border mobility has by definition a cross-border dimension.  

(b)  Would national action or the absence of the EU level action conflict with core objectives of 

the Treaty8 or significantly damage the interests of other Member States? 

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  European  digital  identity 
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.  

A digital solution implemented 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 

8 https://europa.eu/european-union/about-eu/eu-in-brief_en  

3 

 
 
 
 
 
 
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. 

(c)  To what extent do Member States have the ability or possibility to enact appropriate 

measures? 

The  proposals  envisage  the  introduction  of  digital  travel  credentials  that  travellers  may  use  in  the 
context of cross-border travel. Member States would be obliged to allow persons to use digital travel 
credentials  for  those  purposes,  after  a  transition  period  and,  as  far  as  the  crossing  of  borders  is 
concerned,  once  the  common  technical  EU  solution  is  ready  to  be  deployed.  Before  such  a  date, 
Member States could opt-in and develop national solutions for the use of digital travel credentials at 
their external borders. 

Therefore,  the  proposals  help  Member  States  address  the  problems  associated  with  increasing 
traveller  volumes,  while  ensuring  high(er)  levels  of  security  with  added  convenience  for  individual 
travellers.  While  the  initiative  requires  regulatory  and  technical  intervention,  it  is  suitable  for  the 
attainment of the objectives and does not go beyond that which is necessary. 

(d)  How does the problem and its causes (e.g. negative externalities, spill-over effects) vary 

across the national, regional and local levels of the EU? 

The identified problems are cross-border in nature and do not vary across national, regional and local 
levels across the EU.  

(e)  Is the problem widespread across the EU or limited to a few Member States? 

The problems the proposals aim to address are widespread across the EU.  

(f)  Are Member States overstretched in achieving the objectives of the planned measure? 

The need for a uniform EU approach was confirmed by the targeted consultation of Member States’ 
representatives. All respondents said it was essential to ensure adherence to international standards 
on  digital  travel  credentials  (DTC). Most  of  the  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. 

The  proposals  have  a  limited  burden  on  Member  States,  which  is  offset  by  the  expected  positive 
impact of the measures that consist in making border checks more effective and efficient, allowing 
also  for  a  better  use  of  resources  at  local  level.  The proposals  mostly  consist  in  improving  existing 
provisions rather than creating new obligations and in making changes in national setups, taking into 
account differences in technological maturity and capacities. 

(g)  How do the views/preferred courses of action of national, regional and local authorities 

differ across the EU? 

Regarding 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. 

2.4 Based on the answer to the questions below, can the objectives of the proposed action be 

better achieved at Union level by reason of scale or effects of that action (EU added value)? 

4 

 
 
 
 
Yes, the objectives can only be achieved by legislative acts at EU level establishing the common EU 
technical  solution  and  amend  or  complement  existing  provisions  on  border  checks  and  travel 
documents (passports and identity cards).  

The  adoption  and  uniform  application  of  these  rules  throughout  the  EU  cannot  be  achieved  by 
Member  States  acting  individually  but  can  rather  only  be  achieved  by  EU  legislation.  The  mere 
application of soft measures does not go far enough to tackle the problems identified and thus does 
not meet the objectives fully.   

For reasons of scope and effects, the objectives of the proposals would thus be best achieved at EU 
level in accordance with the principle of subsidiarity. 

(a)  Are there clear benefits from EU level action?  

Yes. The adoption of rules on the digitalisation of travel documents and facilitation of travel can be 
best  achieved  by  EU  legislation.  As  the  legal  framework  concerning  travel  documents  and  border 
checks at external borders are established by EU law, EU level (regulatory) action is needed to enable 
the use of digital travel credentials for the benefit of both travellers and border authorities.  

(b)  Are there economies of scale? Can the objectives be met more efficiently at EU level (larger 

benefits per unit cost)? Will the functioning of the internal market be improved? 

EU  action  would  add  considerable  value  in  addressing  the  challenges  related to  security  and  travel 
facilitation. The current situation affects the security at the EU’s borders and the opportunity for EU 
citizens to better enjoy their right to free movement as well as the proper functioning of the overall 
Schengen  area.  While  the  external  borders  and  the  EU  as  a  whole  are  placed  under  considerable 
strain  by increasing traveller  flows and security threats, joint  EU action would allow to put  in place 
harmonised measures to enhance integrated border management and to reach a minimum level of 
digital maturity among all Member States. Moreover, by setting up one common technical solution at 
EU  level  (‘EU  Digital  Travel  application’)  for  the  purposes  of  using  digital  travel  credentials,  as 
opposed to each Member State developing their own, the EU and its Member States can reap cost 
benefits (economies of scale) in addition to facilitating the use of digital travel credentials. 

The proposals aim to facilitate the crossing of borders and the exercise of free movement as well as 
to increase security by introducing the possibility for travellers to use digital travel credentials s. 

(c)  What are the benefits in replacing different national policies and rules with a more 

homogenous policy approach? 

In the absence of a common reference architecture, there is a risk that each Member State will rely 
on different private contractors for the design, development and implementation of various tools. As 
a result, Member States’ solutions would become incompatible with each other, digital fragmentation 
would increase and border control management across the EU would risk being negatively impacted. 
Moreover, depending on which Member States 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 would increase the burden on him 
or her and 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. 

5 

 
 
 
 
 
 
A possible 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  negatively  impact  the  travellers’  experience  when  travelling  from  one  country  to 
another. 

(d)  Do the benefits of EU-level action outweigh the loss of competence of the Member States 
and the local and regional authorities (beyond the costs and benefits of acting at national, 
regional and local levels)? 

Even  if,  under  the  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, Member States are obliged to allow persons to use digital travel credentials for the 
purpose  of  undergoing  border  checks,  the  proposal  helps  Member  States  address  the  problems 
associated  with  increasing  traveller  volumes,  while  ensuring  high(er)  levels  of  security  with  added 
convenience  for  individual  travellers.  While  the  initiative  requires  regulatory  and  technical 
intervention, it is suitable for the attainment of the objectives and does not go beyond that which is 
necessary. The benefits of the proposed EU-level action outweigh any potential loss of competence 
for Member States and their competent authorities. 

As far as the proposal for a Council Regulation on the issuance of and technical standards for digital 
travel credentials based on identity cards is concerned, the loss of competence is very limited given 
that the digital travel document will be issued on the basis of identity cards already regulated at EU 
level. 

(e)  Will there be improved legal clarity for those having to implement the legislation? 

The  proposals  aim  to ensure  legal  certainty  for  travellers  as well  as for  Member  States’  competent 
authorities by establishing a clear legal framework harmonising the content (technical specifications) 
and  issuance  of  digital  travel  credentials  in  the  EU  and  on  their  use  at  external  borders  and  for 
exercising the right to freedom of movement.  

3.  Proportionality: How the EU should act 

3.1  Does the explanatory memorandum (and any impact assessment) accompanying the 

Commission’s proposal contain an adequate justification regarding the proportionality of the 
proposal and a statement allowing appraisal of the compliance of the proposal with the 
principle of proportionality? 

The explanatory memorandum of the 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 contains the following text on the proportionality of the legislative proposal: 

“According to the principle of proportionality laid down in Article 5(4) TEU, there is a need to match 
the nature and intensity of a given measure to the identified problem. The problems addressed in this 
initiative call for EU level legislative action to enable Member States to adequately tackle them. 

6 

 
 
 
 
 
 
This  proposal  envisages  the  introduction  of  digital  travel  credentials  that  travellers  may  use  for  the 
purpose of undergoing border checks. Member States would be obliged to allow persons to use digital 
travel credential for this purpose, after a transition period and once the common technical EU solution 
is  ready  to  be  deployed.  Before  such  a  date,  Member  States  could  opt-in  and  develop  national 
solutions for the use of digital travel credentials at their external borders. 

Therefore,  the  proposal  helps  Member  States  address  the  problems  associated  with  increasing 
traveller  volumes,  while  ensuring  high(er)  levels  of  security  with  added  convenience  for  individual 
travellers.  While  the  initiative  requires  regulatory  and  technical  intervention,  it  is  suitable  for  the 
attainment of the objectives and does not go beyond that which is necessary.” 

The  explanatory  memorandum  of  the  proposal  for  a  Council  Regulation  on  the  issuance  of  and 
technical standards for digital travel credentials based on identity cards  contains the following text 
on the proportionality of the legislative proposal: 

“The proposal does not go beyond what is necessary to achieve its objective, as it does not 
fundamentally alter the rules and provisions of Directive 2004/38/EC or those laid down in the 
Commission’s proposal for a Council regulation 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. It simply adds a DTC based on physical identity cards. In 
particular, this proposal does not amend the substantive conditions for the exercise of the right of 
free movement and residence, but seeks instead to facilitate the exercise of that right. 

In addition, the decision as to whether or not to obtain a DTC would be left to individual Union 
citizens. Those who decide not to do so would still be able to exercise their right to free movement 
using their physical passport or identity card only. However, they might not benefit from some of the 
facilitations available to Union citizens who also hold a DTC.” 

Additional explanations as to the proportionality of the different policy options – including the policy 
options not retained – can be found in the impact assessment accompanying the proposals. 

3.2 Based on the answers to the questions below and information available from any impact 
assessment, the explanatory memorandum or other sources, is the proposed action an 
appropriate way to achieve the intended objectives? 

The legislative proposals address the identified issues in the most appropriate and proportionate way 
to achieve the intended objectives.   

(a)  Is the initiative limited to those aspects that Member States cannot achieve satisfactorily on 

their own, and where the Union can do better? 

Yes.  The  proposals  only  contain  common  rules  to  the  extent  necessary  to  achieve  the  policy 
objectives and is limited to those aspects that Member States cannot achieve satisfactorily on their 
own. 

The  current  EU  legal  framework  does  not  allow  for  the  use  of  digital  solutions  for  verifying  the 
authenticity  and  integrity  of  travel  documents  in  the  context  of  cross-border  travel.  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. 

(b)  Is the form of Union action (choice of instrument) justified, as simple as possible, and 

7 

 
 
 
 
 
 
 
 
coherent with the satisfactory achievement of, and ensuring compliance with the objectives 
pursued (e.g. choice between regulation, (framework) directive, recommendation, or 
alternative regulatory methods such as co-legislation, etc.)? 

The objectives of the initiative can only be achieved by legislative acts establishing the common EU 
technical solution and amend existing provisions on border checks and travel documents (passports 
and identity cards). 

(c)  Does the Union action leave as much scope for national decision as possible while achieving 
satisfactorily the objectives set? (e.g. is it possible to limit the European action to minimum 
standards or use a less stringent policy instrument or approach?) 

The proposals strike a balance between the regulatory autonomy of Member States and the need to 
tackle the problems identified. As it seeks to amend existing rules contained in EU law, limiting the 
proposal to a less stringent policy instrument is not possible. 

(d)  Does the initiative create financial or administrative cost for the Union, national 

governments, regional or local authorities, economic operators or citizens? Are these costs 
commensurate with the objective to be achieved? 

It  is  assessed  that  the  proposals  will  result  in  financial,  administrative  and  operational  benefits  to 
stakeholders compared to the status quo: 

- 

- 
- 

- 
- 

increased effectiveness and efficiency of border checks, likely to lead to savings in resources 
needed to especially cover peak times of travel; 
travel facilitation through shorter waiting times at border-crossing points; 
the facilitation of the exercise of the right to free movement through the access to a digital 
travel document; 
integration of digital travel credentials into other border systems and immigration processes; 
carriers’ liability and carrier applications. 

The  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 
would have an impact on the budget and staff needs of eu-LISA (for preparatory activities, software 
and  hardware  acquisition, analysis  and  design,  development  and  testing,  data centre  preparations, 
licence  costs,  operations  and  maintenance)  and  mainly  one-time  costs  for  border  authorities  of 
Member States (to increase server and storage capacity to temporarily store digital travel credentials 
submitted by travellers, develop the secure connection to the Traveller Router allowing integration 
into existing national border management systems, upgrades or procurement of hardware to process 
digital travel credentials and to support facial recognition as well as training of personnel). 

The  costs  of  the  initiative  would  be  commensurate  with  the  objectives  to  be  achieved.  A  detailed 
estimation of the costs can be found in the impact assessment and LFS accompanying the proposals. 

(e)  While respecting the Union law, have special circumstances applying in individual Member 

States been taken into account? 

No  special  national  circumstances  requiring  a  specific  treatment  of  individual  Member  States  have 
been  identified  during  the  preparation  of  the  proposals  or  during  the  consultations  undertaken  to 
prepare the accompanying impact assessment. 

8