EU Entry/Exit System (EES): Implications for Non-EU Travellers

At a Glance

• From 12 October 2025, the European Union will begin the phased rollout of the Entry/Exit System (EES), a digital border management tool replacing passport stamping for non-EU nationals entering the Schengen Area.
• UK and U.S. travellers, along with other non-EU nationals, will be required to register their entry into and exit out of the Schengen Area by providing biometric data. They will also need to comply strictly with the 90-day short-day limit in any 180-day rolling period.
• While ESS is intended to improve efficiency and security, businesses and travellers should expect operational delays and potential compliance risks during implementation.

Background

The Entry/Exit System (EES) is part of the EU’s “Smart Borders” initiative to digitise and modernise external border checks. It will create a central record of non-EU nationals’ movement in and out of the Schengen Area, replacing the current practice of manual passport stamping.

Key Features of the System

Implementation Timeline

EES rollout will begin on 12 October 2025, with full functionality expected by 10 April 2026. During this transition, some passports may still be stamped in parallel with digital registration.

Scope and Coverage

The system will apply in 29 countries, including all states in the Schengen Area, which comprises 25 EU countries (except Ireland and Cyprus) and four non-EU countries (Norway, Switzerland, Iceland and Liechtenstein).

Traveller Obligations

UK, U.S. and other non-EU nationals on short stays will be required to provide a facial image and/or fingerprints on their first entry. This data will be retained for up to three years.

Operational Challenges and Risks

Although EES is designed to improve border efficiency, its rollout is expected to be uneven. Infrastructure such as kiosks and self-service gates is still being deployed, raising the prospect of delays at busy entry points. This is of particular concern for the Port of Dover in the UK, Eurostar terminals in the UK and France, and major EU airports, which are used heavily by EU and UK travellers in particular.

The automated system will also reduce flexibility. Whereas manual stamps allowed for occasional ambiguity, ESS will record and enforce the 90/180-day rule precisely, making inadvertent overstays more likely to be flagged and sanctioned.

Implications for Non-EU Travellers

• Visa-free access continues, but the 90/180-day limit will now be applied automatically.
• First-time registration may extend processing times, particularly in the early months of rollout.
• Frequent business travellers are likely to experience more disruption than leisure, given the need for regular crossings and compliance with stricter record-keeping.

Practical Considerations for Employers and Institutions

Employers and institutions with frequent travellers to Europe should:

• Update mobility policies to reflect the reduced scope for flexibility.
• Track days of stay internally, rather than relying on passport stamps.
• Allow additional time in travel schedules for border checks during the transition.
• Communicate proactively with staff, ensuring non-EU nationals are aware of new obligations at EU entry points.

Conclusion

The EES represents a significant shift in how the EU manages its borders. For UK and U.S. nationals — the largest group of non-EU visitors — the system will bring greater security and efficiency but also a period of disruption as it is phased in. Employers should act now to prepare mobility policies and ensure travellers are informed of their new obligations.