BRITISH IN EUROPE UPDATE ON THE EU'S NEW ENTRY/EXIT SYSTEM

 

What you need to know about the EU's new Entry/Exit System

The European Union's new Entry/Exit system (EES) is scheduled to be introduced in Autumn 2025. What does this mean for UK nationals and their dependents living in the EU, and what problems might it cause?

Note: this blog focuses on the introduction of EES, and does not cover the new European Travel Information and Authorization System (ETIAS) due to be introduced in 2026.

The EU announced plans back in 2017 to introduce a fully electronic border entry and exit system, with the aim to completely automate the system and bypass the need for passport stamping when entering or leaving the Schengen area.

What is the current status of EES?

The introduction of EES has been beset by delays but the system will be phased in as of October 2025. On 18 July, the Council of the EU gave the green light to a progressive start of EES. The official start date has now been announced as 12th October 2025, with rolling start dates country by country ending on 9th April 2026. We don’t yet have starting dates for most of the Member States but they have until 24 September 2025 to inform the Commission of the roll-out start date in their country.

Within EU law, citizens of any EU member state can travel in and out of the Schengen area by producing an EU passport. As it stands, legal residents of Schengen Member States (all EU states except Cyprus and Ireland, plus Norway, Iceland, Lichtenstein and Switzerland) are also exempt from EES registration, regardless of their nationality. This means that British nationals who are legally resident in one of these countries should be exempt from registration under the new electronic system. This applies to those with both temporary and permanent residence status.

However, the distinction lies in the documents they will need to produce on entry and exit. Not only do those resident in an EU country but without an EU citizenship need to produce their passport, but they will also need to show proof of residence, in line with Annex 22 of the Schengen handbook. In practice, this means showing a valid biometric residence card.

Where does the problem lie?

The main issue this creates is for those who have not obtained the biometric residence card. From within the subset of Withdrawal Agreement (WA) beneficiaries in member states that adopted a declaratory system (where British citizens resident prior to the end of the transition period did not have to make an application by a deadline to acquire WA residence status), there will be some British citizens in countries like Spain who have retained their original EU certificate of residence, or ‘green certificate’, having not exchanged it for a biometric card.

There will also be others such as those living in Germany who never had a residence card as an EU citizen because it was not required, and who have also not applied for a biometric residence card to evidence their WA status because, in declaratory countries, this was optional.

Why should I upgrade to the biometric card?

In countries such as Spain, original assurances from authorities suggested that the old green certificates would remain valid in perpetuity, but more recent legal interpretations by both the European Commission and the UK government suggest this only applies for domestic purposes in the issuing country.

This means that, for those WA beneficiaries who have retained their original residence documents, it is imperative to obtain the biometric residence card in order to travel without problems within the Schengen area and when entering and exiting once the EES system is introduced.

British in Europe also believes that there will be decreasing recognition of the green residence certificates by local authorities in Spain and elsewhere, meaning it will be advantageous even at a domestic level to hold the biometric card. We therefore strongly suggest that you exchange your green certificate for a biometric residence card to ensure your residence status is recognised both in your country of residence, and when travelling in and out of the Schengen area.

In other declaratory countries like Germany, WA beneficiaries who have not applied for a biometric card to show their status will now need to do so if they travel outside Germany within the Schengen area in order to be able to show exemption from EES registration. It will also be useful in any case to have a residence card to prove your status as a WA beneficiary in your country of residence.

For those having trouble getting appointments to exchange their residence documents for the biometric card, BiE will continue to raise this issue with individual governments and in the joint UK/EU WA Specialised Committee on citizens’ rights. Email us at info@britishineurope.org if you are experiencing problems obtaining a WA card.

Current questions

At this point in time, it is unclear how WA beneficiaries travelling on their UK passport will prove their exemption from EES registration, besides carrying their residence cards when travelling. We can foresee this causing issues, particularly as electronic gates are unable to read both passports and residence cards.

We have also asked for clarity from the European Commission on whether it will be necessary to produce both passport and proof of residence on exit and entry, or only on exit, as both options could create issues, particularly for those whose passports expire in the interim. We have discussed these and other issues around EES with the European Commission, and have been told that a targeted information campaign in each member state will be undertaken nearer to the date of introduction and that there will be specific information for WA beneficiaries.

On 4 August the Commission published three (attached) guidance notes on EES for Withdrawal Agreement beneficiaries covering the period July to 11 October 2025, 12 October2025 to 9 April 2026 and 10 April 2026 onwards. Other announcements about EES are here, and about ETIAS here. There is also a very useful FAQ page up on the website.

BIE also remains in contact with DG HOME (the European Commission’s department in charge of migration and home affairs) for updates on the information campaign, and we will share any news here as and when we know more. Please check our website and social media pages in September for further information.

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Since 2017 EuroCitizens has been an active member group of the citizens' rights coalition, British in Europe, which continues to do fantastic work for Britons living and working in Britain. 

More information:  https://www.britishineurope.org/page/1016442-home

 

How can you support our work?

BIE receives some funding from the EU, but most of our work is carried out by dedicated volunteers, which means we rely on your donations to keep doing valuable work. If you have found this, or any of our other recent articles on absences and upgrading from ordinary to permanent residence helpful, please think about donating to support our work.

Documents

2025 guidance - Schengen pre-progressive

UPDATE ON TRAVEL BETWEEN BRITAIN AND SPAIN: THE NEW EU AND UK VISA WAIVER SCHEMES

A message from our chair, Nigel Aston, with guidance on the new travel requirements to be imposed by both the EU and the UK.

1. EU (Schengen) Exit and Entry System (EES)

Whilst this was supposed to have been introduced in November 2024, various issues, principally of infrastructure, have delayed implementation.  Although the European Commission are attempting to introduce a phased introduction (that we see as fraught with issues), their proposal seems bogged down in the EU legislative procedure. There are now rumours that introduction is delayed again until the autumn of this year.  There is no imminent guidance other than the general principles published on the following:

 
https://travel-europe.europa.eu/ees_en

It remains unclear exactly what British citizens protected by the Withdrawal Agreement will need to do initially in practical terms, but there is no deviation from previous advice that protectees will be treated as EU citizens.  However, we stress the importance of exchanging the old green residence certificate for the TIE card in order to avoid any misunderstanding at frontiers.  Please bear in mind that EES applies only to the external Schengen frontier.  However, it is essential to carry passports and TIEs when travelling inside the EU in case of spot checks.

2. ETA (Electronic Travel Authorisation)

The UK visa waiver programme becomes operative for EU citizens from the beginning of April 2025! British (and Irish) passport holders using their UK/IRE passports to enter the UK are exempt. 

Holders of dual British and Spanish nationality may wish to bear in mind that Spain does not recognise the dual nationality in their case. Whilst the UK government strongly advises that UK citizens use their UK passports to enter the UK, we understand that this is not a legal obligation. It should, therefore, be possible to travel to the UK on a Spanish passport having made an ETA application.  The choice is that of the individual and EuroCitizens makes no recommendation on the course taken by individuals. Applications for authorisation can be made by EU/EEA nationals from 5 March.

https://www.gov.uk/guidance/apply-for-an-electronic-travel-authorisation-eta

THE GOODBYE EMAIL OF HUGH ELLIOT, HM AMBASSADOR SPAIN, TO EUROCITIZENS

Photo: The Diplomat

Since the autumn of 2016, EuroCitizens has worked closely with the British Embassy in Spain as part of our campaign to defend the rights of UK residents in Spain after Brexit. Hugh Elliot arrived in Madrid five years ago, at a particularly difficult juncture for the Brexit negotiations and for British nationals living here. On his impending departure, we wrote to Hugh to thank him for his work on citizens' rights (see below). He has kindly replied to us (see below), describing our approach to the UK Embassy as a 'mix of frank challenge and constructive engagement'. 

We very much look forward to having such a positive relationship with the incoming HM Ambassador Spain, Sir Alex Ellis. Despite all the progress that has been made, there are still issues that need attention, such as the phasing out of the old green resident cards and the need for all UK residents in Spain to apply for a TIE or foreigners' ID card (more information) .

Reply of HM Ambassador Spain:

«Thank you very much for your kind email.  The Brexit years have been so turbulent and worrying for so many people, it has been a privilege if we have been able to be of some help.  If even those like myself very closely involved with the many twists and turns struggled at times to understand absolutely everything that was going on, I can only imagine how difficult it was for those at more of a distance, concerned about the very real impact on their lives.  

I have been full of admiration for what Eurocitizens has done during this period, and am particularly glad that we have now moved beyond most of the issues. The new government’s clear priority is on resetting its relationship with Europe.

I agree about the productive relationship: I’ve admired the mix of frank challenge and constructive engagement you have always brought.  I’m sure the strong relationship will continue under my successor, Sir Alex Ellis.»

 

Email of EuroCitizens Chair, Nigel Aston:

 

«I am writing on behalf of EuroCitizens to thank you for your efforts on our behalf during the past five years and to wish you all the very best going forward. Your initial year, of course, was complicated by the pandemic, coinciding as it did with the transition period.  

I think it is true to say that many of the worst fears of our members did not come to fruition.  The approach taken by the Spanish authorities to introduce TIEs was sensible and, generally, proportionate and we thank you for the influence that the Embassy had on this.  We all accept that there have been on-going annoyances but, thankfully, satisfactory outcomes were reached on the few serious cases with which we have been confronted.

 

We feel that we have a productive relationship with the Embassy and trust that this will continue with your successor. Of course, there have been difficult times behind the scenes on political issues, including those manufactured in the UK. Your support for our interests was not distracted by these and we are grateful for all your help in assuaging members' concerns as Brexit became a reality. And your personal kindness towards individual members was much appreciated.»

AN IMPORTANT LETTER FOR UK PENSIONERS OVER 80 FROM HM AMBASSADOR IN SPAIN, HUGH ELLLIOT

Dear EuroCitizen Member,

See below a link to a letter sent by the British Ambassador with respect to the ongoing receipt of UK state pensions.

It is particularly critical for those recipients over 80.  If the requested action is not taken then pension entitlement will be lost, if only until corrective action is taken (which will be highly bureaucratic).

Could you please make this known to anyone in your circler who receives such a pension and, particularly the over 80s.  We cannot ignore that this represents a particularly vulnerable segment of pensioners.

A quick word on the 4 July general election. First, we will be analysing the efficacy (or not) of the postal voting arrangements in due course.  Given the likely size of a Labour majority, there is no immediate rush to do so and time to lobby for some serious improvements. Second, we will do some analysis of what a change in government will have on British citizens in the EU.  Again this may take a few weeks as new Ministers are appointed and the new government beds down, with a Parliamentary recess at the end of this month in any case - albeit likely to be shorter than usual.

With many thanks

Nigel Aston

President, EuroCitizens, Vice Chair British in Europe

 

Link to full letter: 

https://mcusercontent.com/e2c828a6e395b7f8f24ed6348/files/78b6ca08-6ea6-e753-62b2-bc2a90cd1d4f/20240621_OU001_Letter_to_Charities_and_CR_Groups_regarding_DWP_039_s_Request_for_Life_Certificates.pdf

 

Main content of the letter:

 

THE AMBASSADOR STRONGLY ADVISES ALL UK RESIDENTS IN SPAIN TO GET THE BIOMETRIC RESIDENCE CARD (TIE) AS SOON AS POSSIBLE

 

A very important message from UK ambassador, Hugh Elliot, about the new EU border control scheme:

 

• In October 2024 (TBC), the European Union (EU) is expected introduce a new scheme that will affect non-EU citizens, including British nationals, entering an EU country for a short stay.    
• The scheme, called EU Entry/Exit System (EES), will register travellers via an automated system in the port or airport when they arrive in Spain. It will replace the current manual stamping of passports at the border.  
• British tourists will be required to provide their name, passport details, biometric data (fingerprints and captured facial images) as well as the date and place of entry and exit upon entering Spain.  
• These details will be held on file for three years, meaning Britons making repeat visits to Spain within a three-year period will not have to go through the same registration process each time. 
• To be exempt from EES registration, British residents in Spain will need to show a valid uniform-format biometric card, which in Spain is the TIE. The British Embassy and the Spanish Government therefore strongly recommend that all British residents in Spain get the TIE before the EES comes into force to avoid disruption at the border.
  

 

Full message:

 

 As you may already be aware, the European Union (EU) is expected to introduce a new border control scheme that will affect all non-EU citizens, including British nationals, who enter an EU country for a short stay. It’s known as the Entry/Exit Scheme (EES) and is due to launch in October - although this date is subject to change and we will inform you when we have more details around the exact timings and processes for its introduction.  The EES will require all British passport holders to register via an automated system before they cross an EU border, replacing the manual stamping of passports. Biometric data will be taken (fingerprints and facial images) and travellers will also need to provide their name, passport details and place of entry and exit in the EU. It is very similar to the ESTA system currently in place in the US.  

  

Impact on Residents 

British residents in Spain will be exempt from registering with EES provided they can produce a valid uniform-format biometric card, which in Spain is the TIE.  

 

Fortunately, most British people living in Spain already have a TIE, having abandoned the formerly issued Green Certificate in recent years. However, as you know, we believe that many people are still using their Green Certificate. This non-biometric document, though a valid residency document in Spain, was issued prior to EU Exit and therefore, does not feature in the Withdrawal Agreement or in Annex 22 of the Schengen Border Guard Handbook document. As a result, we expect that Green Certificate holders may face delays and difficulties at the border once EES comes into force.  

We are therefore asking all British people living in Spain to urgently get the TIE, if they haven’t already done so, and would like your help spreading this message please. 

 

At the same time, we are speaking with the Spanish Government to highlight the urgent need for TIE appointments in the areas of Spain where most British people reside. If you become aware of any issues with appointments or other barriers affecting your members/contacts, please let us know. 

 

Impact on Tourists 

 

MESSAGE FROM EUROCITIZEN CHAIR, NIGEL ASTON, ABOUT EXERCISING OUR VOTING RIGHTS IN THIS YEAR'S UK ELECTIONS

As we have advised before, if you are a UK citizen who has lived for even a short time in the UK you can now vote in Parliamentary elections and national referendums irrespective of the time you have lived outside the UK.

Speculation is rife about the timing of the next general election.  My hunch is that the Prime Minister will take the opportunity of the Conservative Party conference in the Autumn to call the election and kick start a campaign, with an election date of late October/early November!

There is still time to register to meet this deadline. If you have not already done so please follow this link to British in Europe's web site giving updated FAQs
 https://www.britishineurope.org/articles/145184-voting-faqs-updated

and also see the original content for guidance on registering.

This will also be helpful if you have registered but want advice on the options for voting - essentially postal vote, proxy or in person.  

Given the potential for delays in the post, I have appointed a proxy! Bear in mind that a proxy can have a postal vote on your behalf so they do not need to vote in person but can use the Royal Mail.  This is particularly worth bearing in mind if you don't know anybody in your most recent place of UK residency.

Please share with your contacts outside the UK!

Many thanks 

Yours

Nigel Aston
President, EuroCitizens, Vice Chair British in Europe

THE AMBASSADOR'S NEW YEAR'S MESSAGE: GREEN CARDS, PENSIONS, AND OUR VOTING RIGHTS

 

 

As an organisation, EuroCitizens received a New Year's message from the British Ambassador, Hugh Elliott.  The substantive points highlighted by the Ambassador are:

 1. An ‘exchange’ closely monitored in 2023 was that of the Green Certificate. This document remains a valid way to prove Withdrawal Agreement beneficiary status and therefore, the right to work and reside in Spain. For the most part, it is recognised as such, but in response to some reports of non-recognition, we have created this letter on the Living In Guide to explain its validity, pointing to relevant Spanish Government guidance, which we hope will help. That said, the best and most reliable way to prove your rights under the Withdrawal Agreement is with the TIE. That’s why the Embassy strongly advise all British citizens in Spain to get one as, put simply, it will just make life easier. We are pleased that over 200,000 British people (a growing number) do now have a TIE, but we still have a way to go in encouraging take up. 

 

2. The Embassy also hope to make progress on pensions and healthcare matters in 2024. On the former, we believe that many British people living here may be entitled to a Spanish state pension without knowing it. Even those who may have only worked for one year in Spain could be eligible and, if they have worked in other EU countries as well, could potentially combine Spanish social security contributions with those from other countries. As for healthcare, many British citizens in Spain have not yet registered with the Spanish public health system and therefore, are missing out on their entitlement to receive basic state services for free. This means that they could be charged privately for their healthcare, potentially resulting in unnecessary and expensive bills. It is also important that British residents in Spain receiving UK-funded healthcare keep the NHS Business Services Authority updated on their circumstances and contact information. The NHSBSA will be engaging more proactively with British citizens in Spain and are contactable through OHS.S1emailupdate@nhsbsa.nhs.uk.

 

3. The Ambassador is  pleased to say that new legislation has come into force to enable British citizens living abroad to vote in UK general elections, regardless of how long they’ve been living outside the UK. This law removes the previous 15-year time limit and I know will be very welcome news for many British people in Spain. The Embassy has updated our Living in Guide accordingly and are calling on partner to help us spread the word, so British people can get registered and be ready to cast a ballot when the time comes.

Happy New Year!