LawFlash

EU Update: EES and ETIAS Implementation Timelines - Phased Rollout Confirmed

2025年07月31日

The European Union has provided updated guidance on the phased implementation of its long-anticipated Entry/Exit System (EES) and the European Travel Information and Authorisation System (ETIAS), both of which form part of a broader effort to modernise border management across the Schengen Area.

EES: PHASED INTRODUCTION FROM OCTOBER 2025

The EES will begin gradual implementation in October 2025, with full operational deployment expected by 10 April 2026.

The phased rollout will span a 180-day period during which EES capabilities will be progressively introduced at external border checkpoints across participating European countries. Initially, only a limited number of border crossings will operate under the new system, with gradual expansion planned through to full coverage by April 2026.

During the transition phase, not all travellers will have their biometric data collected, nor will their personal information necessarily be registered in the system. Passport stamping will continue in this interim phase. Travellers are advised to consult national border authorities for country-specific procedures during this time.

ETIAS: LAUNCH EXPECTED IN LATE 2026

The launch of the ETIAS is now anticipated for the last quarter of 2026. This marks a further delay from earlier projections targeting a 2025 rollout. The revised timeline is pending review and approval by the European Parliament.

ETIAS is designed to pre-screen visa-exempt travellers before entry into the Schengen Area, similar to systems used by the United Kingdom, United States, and Canada. EU authorities have confirmed that ETIAS will begin only after the EES is fully implemented—meaning any delays to the EES timeline will directly impact the ETIAS launch.

The ETIAS will include a six-month transitional period, during which travellers may still enter without an ETIAS authorization, provided they meet all other entry conditions. This will be followed by a six-month grace period, during which only first-time arrivals since the end of the transitional phase may still be permitted entry without ETIAS approval. All other travellers will be required to hold a valid ETIAS authorization.

WHAT EMPLOYERS SHOULD BE DOING NOW

Considering these upcoming changes, employers—particularly those with internationally mobile workforces—should begin preparing now. Employers should consider the following:

  • Reviewing existing travel policies
  • Identifying employees who travel regularly to Europe and may be affected by the new systems
  • Informing employees about the upcoming changes to ensure proper review of travel documents, to address any concerns they may have about the changes and to make employees aware that they may experience travel delays as the programs are rolled out

Contacts

If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following:

Authors
Shannon A. Donnelly (Washington, DC)
Yvette Allen (London)
Carina Bryk (London)