Starting 12 October 2025, the European Union will begin rolling out a new digital border control system known as the Entry/Exit System (EES). This initiative marks a significant shift in how the EU manages its external borders, particularly for non-EU nationals traveling for short stays. The system will be introduced gradually over a six-month period, with full implementation expected by April 2026.
What is the EES and why is it being introduced?
The EES is a centralized IT system designed to replace the traditional passport stamping process. It will automatically record the entry, exit, and refusal of entry of third-country nationals who do not hold EU citizenship or long-term residence permits. The system will collect biometric data (fingerprints and facial images), travel document details, and timestamps of border crossings.
The primary goals of the EES are:
- To enhance border security and detect overstayers—individuals who remain in the Schengen Area beyond the permitted 90 days within any 180-day period
- To streamline border checks through automation
- To reduce identity fraud and improve the accuracy of migration statistics
Who will be affected?
The EES applies to non-EU nationals entering the Schengen Area for short stays, whether they are visa-exempt (e.g. Brazil, Israel, Japan, Mexico, United States) or traveling with a Schengen visa (e.g. Armenia, China, Egypt, India, Saudi Arabia). This includes tourists, business travelers, and other visitors who do not hold a residence permit or long-stay visa.
Excluded categories include:
- EU citizens and their family members with residence rights
- Holders of long-stay national visas or residence permits
- Certain diplomatic and official travelers
Importantly, individuals with Italian investor visas or other long-term residence permits will not have their data stored in the EES, although they may still be subject to border checks.
How will the rollout work?
The rollout of the EES will follow a phased approach, allowing Member States to introduce the system progressively at selected border crossing points. During the transition period:
- Passport stamping will continue as a backup
- In case of discrepancies between stamps and EES data, authorities will assess which record prevails
- Member States must submit national rollout plans and report monthly on progress
Data protection and privacy concerns
The EES will store sensitive personal data, raising concerns about privacy and fundamental rights. Regulation (EU) 2017/2226 includes safeguards to ensure that data access is limited to authorized border, immigration, and law enforcement authorities. These entities are subject to oversight by national and EU data protection bodies.
However, critics have pointed out potential risks:
- Automated decision-making could lead to profiling or discrimination
- Errors in data (e.g. missing exit records) could result in travelers being wrongly flagged as overstayers
- Remedies for correcting data may vary depending on national laws, potentially limiting access to justice for affected individuals
ETIAS: the next step
Following the EES, the EU will launch the European Travel Information and Authorisation System (ETIAS) in late 2026. ETIAS will require visa-exempt travellers to obtain prior authorization before entering the Schengen Area. The application will be submitted online and will cost €7. Once approved, the authorization will be valid for three years, or until the travel document expires.
ETIAS is modelled after systems like the U.S. ESTA and aims to assess potential security, migration, or health risks before travelers arrive. Importantly, ETIAS approval does not guarantee entry, border checks will still apply.
Special considerations for Mexican HNWI and families traveling to Europe
Mexican nationals are among the many third-country citizens who benefit from visa-free access to the Schengen Area for short stays. Under current rules, they may enter for up to 90 days within any 180-day period without a visa. However, with the introduction of the EES and later ETIAS, the travel experience will change in several key ways:
- Digital tracking of stay duration: with the implementation of the EES, Mexican nationals will be digitally logged at entry and exit points. Travelers should be mindful of their time spent in the Schengen Area and consider using the upcoming EU portal to monitor their status.
- ETIAS authorization requirement: once ETIAS is launched, Mexican nationals will need to apply for travel authorization online before entering the Schengen Area. This process will involve submitting personal and travel information, answering security-related questions, and paying a small fee. While most applications are expected to be approved quickly, travelers should apply well in advance of their trip.
- HNWI, business travelers and frequent visitors: Mexican HNWI, entrepreneurs, investors, and frequent travelers who often approach the 90-day limit may wish to explore long-term visa options. The Italian investor visa, for example, allows for extended stays and may exempt holders from EES data storage. However, border checks will still apply, and travelers should carry documentation proving their visa or residence status.
- Entry refusals and data accuracy: travelers should ensure that their travel documents are valid and that they comply with entry requirements. Refusal of entry may occur if biometric data is not provided or if the system flags a previous overstay. It is advisable to retain records of travel dates and consult legal counsel if any discrepancies arise.
This insight piece features input from Alejandro Ramirez.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
