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.
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2025 guidance - Schengen pre-progressive
