REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the state of play of preparations for the full implementation of the VIS Regulation in accordance with Article 11(3) of Regulation (EU) 2021/1134
Date: 2025-07-01
Institutions: Directorate-General for Migration and Home Affairs, European Commission
Subjects: EU migration policy, EU visa policy, Schengen Agreement, data protection, exchange of information, external border of the EU, foreign national, information system, personal data, residence permit

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.7.2025  COM(2025) 346 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the state of play of preparations for the full implementation of the VIS Regulation in accordance with Article 11(3) of Regulation (EU) 2021/1134   
 
 
Executive summary 

Article  11(3)  of  Regulation  (EU)  2021/11341  amending  inter  alia  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)2 requires the Commission to submit an annual report to the European 
Parliament  and  to  the  Council  on  the  state  of  play  of  preparations  for  the  Regulation’s  full 
implementation. This is the Commission’s third report. 

Implementing the new IT architecture for migration, borders and security is the cornerstone of 
establishing  one  of  the  most  modern  border  management  systems  in  the  world.  The  Visa 
Information System (VIS) is an integral part of this architecture. To achieve full and timely 
implementation, EU Member States and Schengen associated countries, EU agencies and the 
Commission  should  advance together.  It  is  important  that  each party take responsibility  for 
ensuring that the system can become operational at the same time, thus avoiding further delays 
and increasing costs. 

Overall, the implementation of the revised VIS is on track. Following adoption of the amending 
Regulation (EU) 2021/1134 on 7 July 2021, the Commission immediately started to discuss in 
the relevant committee and expert group the 12 implementing and delegated acts necessary 
to develop the new functionalities of the revised VIS. Work continued in 2024, with the 12 
implementing and delegated acts currently at various stages in the adoption procedure. Seven 
acts have been adopted, while five are being prepared by the Commission. 

1 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,  ELI: http://data.europa.eu/eli/reg/2021/1134/2021-07-13). 
2 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) 
(OJ L 218, 13.8.2008, p. 60, ELI: http://data.europa.eu/eli/reg/2008/767/2023-12-27). 

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1.  Introduction 

The VIS was established by Council Decision 2004/512/EC3 to allow the exchange of visa data 
between Member States. Regulation (EC) No 767/2008 of the European Parliament and of the 
Council (VIS Regulation)4 laid down:  

• 
• 

the purpose and functionalities of the VIS and the associated responsibilities.  
the conditions and procedures for the exchange of short-stay visa data between Member 
States  to  facilitate  the  examination  of  applications  for  short-stay  visas  and  related 
decisions.  

The  VIS  started  operating  on  11 October  2011  and  was  gradually  rolled  out  in  all  Member 
States’ consulates between October 2011 and February 2016. 

The purpose of the VIS is to improve implementation of the common visa policy and consular 
cooperation and consultation between central visa authorities by facilitating the exchange of 
data between Member States on applications and related decisions. The VIS aims inter alia to: 

facilitate the visa application procedure. 

• 
•  prevent ‘visa shopping’. 
• 
•  assist in the identification of any person who does not or no longer fulfils the conditions 

facilitate the fight against identity fraud. 

• 

for entry to, stay or residence in the territory of the Member States. 
facilitate  the  determination  of  the  Member  State  responsible  for  examining  an 
application  for  international  protection  under  Regulation  (EU)  No 604/2013  of  the 
European Parliament and of the Council.5 

On 2 August 2021, Regulation (EU) 2021/1134 (revised VIS Regulation) entered into force 
amending inter alia the VIS Regulation. The revised VIS will provide visa-issuing authorities 
with key information on applicants for short-stay Schengen visas, while enabling border guards 
to detect travellers who may pose security risks. The new rules also expand the scope of the 
VIS – notably by adding applicants and holders of long-stay visas and residence permits – in 
full respect of the data protection requirements. This will ensure that the relevant authorities 
have  the  information  they  need,  when  they  need  it.  The  new  rules  will  enable  thorough 
background checks on applicants for short-stay visas, long-stay visas and residence permits, 
better information exchange between Member States on holders of such documents and full 
interoperability with other EU information systems. 

3  Council  Decision  2004/512/EC  of  8 June  2004  establishing  the  Visa  Information  System  (VIS)  (OJ  L  213, 
15.6.2004, p. 5, ELI: http://data.europa.eu/eli/dec/2004/512/2019-06-11). 
4 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) (OJ L 218, 13.8.2008, p.  60, ELI: http://data.europa.eu/eli/reg/2008/767/2023-12-27)). 
5 Regulation (EU) No 604/2013 of the European Parliament and of the Council of 26 June 2013 establishing the 
criteria and mechanisms for determining the Member State responsible for examining an application for 
international protection lodged in one of the Member States by a third-country national or a stateless person (OJ 
L 180, 29.6.2013, p. 31, ELI: http://data.europa.eu/eli/reg/2013/604/oj). 

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Pursuant to Article 11(1) of Regulation (EU) 2021/1134 the Commission is to adopt a decision 
on setting the date for the start of operations of the revised VIS. That article also sets out the 
conditions that need to have been met for this decision to be adopted. These are:  

• 

• 

the  necessary  implementing  and  delegated  acts  referred  to  in  this  report  have  been 
adopted.  
the  European  Union  Agency  for  the  Operational  Management  of  Large-Scale  IT 
Systems  in  the  Area  of  Freedom,  Security  and  Justice  (eu-LISA)  has  notified  the 
Commission that all testing activities have been successfully completed; and  

•  Member  States  have  notified  the  Commission  that  they  have  made  the  necessary 

technical and legal arrangements. 

The VIS will be part of the common interoperability framework established by Regulations 
(EU)  2019/8176  and  (EU)  2019/8187  of  the  European  Parliament  and  of  the  Council.  The 
interoperability  framework  between  EU  information  systems8  was  set  up  in  order  for  these 
systems and their data to supplement each other, with the overall objective of improving the 
effectiveness  and  efficiency  of  checks  at  the  external  borders.  This  will  contribute  to  the 
prevention  and  combating  of  irregular  immigration,  as  well  as  to  ensuring  a  high  level  of 
security  and  improving  the  implementation  of  the  common  visa  policy.  To  that  end,  the 
technical development of new VIS functionalities and processes should be fully consistent with 
those of the other EU information systems that are part of the framework. 

Article 11(3)  of  Regulation  (EU)  2021/1134  requires  the  Commission  to  submit  an  annual 
report to Parliament and the Council on the state of play of preparations for the Regulation’s 
full implementation. This applies until the Commission adopts the decision setting the date for 
the start of operations of the VIS in accordance with Article 11(1) of that Regulation. The report 
is to include detailed information about the costs incurred and information as to any risks that 
may affect the overall costs. 

The first Commission report on the state of play of preparations for full implementation of the 
VIS  Regulation  was  adopted  on  9 February  20239,  with  the  second  report  following  on 
18 January 202410. Since the second report covers the period up to its preparation in November 
2023, this third report covers the period from December 2023 to its preparation in November 
2024. 

6 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, ELI: http://data.europa.eu/eli/reg/2019/817/2025-01-28). 
7 Regulation (EU) 2019/818 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 police and judicial cooperation, 
asylum and migration and  amending Regulations (EU) 2018/1726, (EU) 2018/1862 and (EU) 2019/816 (OJ L 
135, 22.5.2019, p. 85, ELI: http://data.europa.eu/eli/reg/2019/818/2025-01-28). 
8  The  Entry/Exit  System  (EES),  the  Visa  Information  System  (VIS),  the  European  Travel  Information  and 
Authorisation System (ETIAS), Eurodac, the Schengen Information System (SIS), and the European Criminal 
Records Information System for Third-Country Nationals (ECRIS-TCN). 
9 COM(2023) 66 final. 
10 COM(2024) 13 final. 

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2.  Implementing legislation of the VIS Regulation 

Regulation  (EU)  2021/1134  provides  the  Commission  with  several  empowerments  for  the 
adoption of implementing and delegated acts, some of which are necessary to fully enable eu-
LISA to start designing and developing the new functionalities in the context of the overall IT 
system architecture, especially as this requires the definition of technical specifications. Other 
acts  are  needed  to  lay  down  technical  rules  to  facilitate  the  use  of  the  VIS  by  the  relevant 
Member State authorities and EU agencies. 

Since the adoption of Regulation (EU) 2021/1134 in 2021, the Commission has organised 22 
Committee  meetings  and  12  Expert  Groups  on  the  revised  VIS,  to  discuss  a  series  of  draft 
implementing and delegated acts necessary for its development. 

The 12 implementing and delegated acts are at various stages in the adoption procedure. Six 
implementing  acts  and  one  delegated  act  are  already  formally  adopted,  while  three 
implementing  acts  and  two  delegated  acts  are  being  prepared  for  adoption.  This  is  further 
illustrated in the table below: 

Table 1. Required implementing and delegated acts – state of play as of November 2024 

Regulation 

Type of act 

Adopted 

Under 
formal 
adoption 

In 
committee 
or group 

yet 

Not 
started 

VIS 

Delegated 

1 

Implementing  6 

2 

3 

Table 2. Required implementing and delegated acts, by act – state of play as of November 2024 

Legal basis 
1 
Art. 5a 
2 
Art. 6(5) 
3 
Art. 9  
4 
Art. 9h & 22b 
5 
Art. 9j(2) 
6 
Art. 9j(3) 
7 
Art. 29 & 29a 
8 
Art. 45(1) 
Art. 45(2) 
9 
10  Art. 45(3) 
11  Art. 45c & 45d 
12  Art. 50(4) 

Type of act 
Implementing 
Implementing 
Delegated 
Delegated 
Delegated 
Implementing 
Implementing 
Implementing 
Implementing 
Implementing 
Implementing 
Implementing 

Status 
Adopted 
Adopted 
Adopted 
Work ongoing 
Work ongoing 
Work ongoing 
Adopted 
Work ongoing 
Work ongoing 
Adopted 
Adopted 
Adopted 

3.  Monitoring of Member States’ and EU agencies’ implementation 

The  importance  of  timely  implementation  of  the  revised  VIS  is  well  recognised  at  EU  and 
Member State level. All stakeholders also well understand the interdependencies between the 

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VIS  and  the  development  of  other  EU  information  systems  and  of  the  interoperability 
components. To achieve full and timely implementation,  the Commission is  monitoring  the 
implementation  of  the  revised  VIS  Regulation  through  various  measures,  including 
Committee’s, Expert Group’s and Advisory Group’s meetings, as well as regular meetings with 
EU agencies. 

4.  Costs and risks 

Costs for EU agencies 

According to the information they provided, the relevant EU agencies incurred the following 
costs relating to implementing the revised VIS between November 2023 and November 2024: 

•  eu-LISA had a total implementation cost of EUR 12.7 million. 
•  Europol’s consultancy and software costs amounted to EUR 0.6 million. 
• 
the European Border and Coast Guard Agency did not incur any costs. 

eu-LISA’s additional costs 

During  the  implementation  of  the  revised  VIS,  new  needs  were  identified  as  the  project 
progressed, requiring eu-LISA to request changes from its contractors concerning the revised 
VIS.  This  led  to  unforeseen  costs.  Additionally,  the  Agency’s  current  contractual  set-up 
includes  costs  linked  to  project  governance  and  transversal  activities  proportional  to  the 
contract’s duration. Therefore, extending the timeline for the revised VIS, as referred to in the 
section ‘revised VIS timeline’ of this report, generates additional costs. 

Member States’ costs 

The indicative allocation planned in the Member States’ BMVI programmes for the 2021-2027 
period for the setting up, operation and maintenance of VIS, including its interoperability with 
other large-scale IT systems, is EUR 103.4 million (EU contribution11).  

According to the data on programme implementation sent by the Member States’ authorities, 
the EU contribution to the selected operations (projects, actions or group of projects under the 
programmes  concerned)  is  EUR 58.4  million.12  This  amount  represents  the  contribution  to 
Member  State  authorities’  commitments  for  those  operations.  It  does  not  correspond  to 
expenditure already incurred. 

Revised VIS timeline 

Implementing the revised VIS within the common interoperability framework and adapting it 
to interact with the other IT systems (e.g. the Entry/Exit System (EES)) involves changes to 
the system that result each time in a new version of it. These different versions of VIS must be 
implemented in a sequence. The interdependence of the various EU information systems may 

11 Source: Member States’ programmes, expenditure planned under specific objective 2, Common Visa Policy, 
Intervention code 006. Large-scale IT system, Visa Information System (VIS), November 2024. 
12 Source: Data sent by Member States in accordance with Article 42 of Regulation (EU) 2021/1060, 30 November 
2024. 

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affect  the  duration  of  some  parts  of  the  project  to  implement  the  new  architecture  for  EU 
information systems for borders, migration and security. 

The  renewed  Schengen  Information  System  entered  into  operation  in  March  2023.  On 
19-20 October  2023,  the  Justice  and  Home  Affairs  Council  endorsed  a  timeline  for  the 
remaining systems. According to this roadmap, the EES was scheduled to enter into operation 
in autumn 2024, the European Travel Information and Authorisation System (ETIAS) in spring 
2025 and the revised VIS in autumn 2026, along with the interoperability architecture. 

However, subsequent to the period covered by this report, the roadmap for the roll-out of the 
interoperability architecture was revised due to the postponement of the entry into operations 
of  the  EES,  affecting  the  timeline  for  the  revised  VIS.  In  particular,  the  Justice  and  Home 
Affairs Council approved the revised roadmap on 5 March 2025, according to which, the EES 
is scheduled to start operations in a progressive manner in October 2025, ETIAS in the last 
quarter of 2026 and the revised VIS in 2027. 

5.  Conclusion 

Member States, Schengen associated countries and EU agencies share a general commitment 
to ensuring full implementation of the revised VIS, also as part of the wider interoperability 
framework for EU information systems. 

The  Commission  continues  to  coordinate  and  closely  monitor  the  progress  of  all  parties 
involved to ensure a timely availability of the revised VIS. 

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