We have increasing questions from the Business Aviation community concerning eu-LISA, EES or ETIAS :
- What is eu-LISA, EES, ETIAS?
- Why are carriers impacted by EES, ETIAS ?
- How should Business jets implement EES /ETIAS?
- What are the steps to be ready for EES?
- What processes do airlines and others carriers need to apply for EES launch in September 2022?
- Why carriers have to register to eu-LISA ?
This article aims to provide clear answers to these questions.
eu-LISA, EES, ETIAS : what is it ?
The legal basis of EES – ETIAS
Between 2017 and 2018, the European Parliament voted two pieces of legislation which aim to give the EU more control over its borders and better management of irregular entries into the EU’s borderless Schengen zone:
- the EU Regulation 2017/2226 related to EES completed by its Implementing Regulation 2021/1224
- the EU Regulation 2018/1240 related to ETIAS completed by its Implementing Regulation 2021/1217
Why are international carriers impacted by EES, ETIAS ?
Air, sea or coach carriers must ensure that their passengers have the required travel documents for entry into the destination country or while in transit.
It is not always well-known but ensuring that passengers have the required travel documents is a legal obligation for all international carriers. Don’t think, it is only under customs responsibility. In fact, carriers should comply with this obligation since 1985 in Europe by the article 26 of the convention implementing the Schengen Agreement. Carriers are impacted by the EES ETIAS implementation by extension of this obligation and the application of the recent implementation regulations 2021/1217 and 2021/1224 (already quoted above). As EES and ETIAS impose the usage of a central tool to check the travel documents, the carriers have been mandated to connect to those systems.
What new obligations is imposed to Carriers to comply with EES and ETIAS?
With EES and then ETIAS, carriers will have to query the euLISA central system to obtain the authorization status of all Third Country Nationals entering into the Schengen states before boarding … so airlines will have to integrate this query into their current check-in process and implement new processes to collect the responses and manage them, especially in case of “Not OK” answers (traveler unauthorized).
To allow a progressive roll-out for all impacted persons, EES and ETIAS will not enter into force at the same time.
All international carriers transporting non-EU/Schengen citizen into the Schengen zone are concerned
- Airlines, scheduled and non scheduled ones,
- Ferry, cruise operators
- International coaches operators
What are the steps to be ready for EES?
A positive point is that querying EES or ETIAS will be done through the same interface, the Carrier Interface as called by eu-LISA. So once the connection to the Carrier Interface is set-up for EES, it will be valid for ETIAS.
This interface has been designed for syst2syst connection (web interface and mobile app should also be available). The carriers have the choice to connect through 2 different modes… it shouldn’t be the hardest piece.
To set up this mandatory access, besides connectivity, carriers have to follow an uneasy process to get the eu-LISA certification, starting with an administrative registration, followed by the preparation of the specific message format for the query to finally perform dozens of tests on the different environments, to cover and validate the different use cases. As presented in the plan below, all these steps are bound to a tight calendar imposed by the eu-LISA implementation team. It is a real IT project that requests time and effort.
Implementation milestones for EES (led by eu-LISA)
You can outsource this project and appoint a service provider to be your representative and connect on your behalf.
Streamlane already represents several carriers and can be your representative.
What processes do carriers need to follow for the EES launch in September 2022?
At the launch of EES, only single and double entry visas will be stored. This means that the travelers with others type of visa (multiple entry, short-stay, long-stay or airport transit visa) or authorizations (residence permit /card, diplomatic passport, laissez-passer, visa-exempt) will have to be checked manually.
Why carriers HAVE TO register to eu-LISA ?
Carriers should NOT wait to be notified and asked by the EU authorities to comply. EES and ETIAS are regulations that carriers must be aware of and comply with as soon as they come into force.
As the legal responsible, the carrier is the only one authorized to register itself and to eventually appoint its future service provider. This step can’t be outsourced.
The registration allows the carriers :
- to receive all information necessary to prepare the integration of EES-ETIAS into their daily processes,
- to participate in the Working Group for Carriers led by eu-LISA staff
- to set-up the connection and perform the compliance testing.
- to get its eu-LISA carrier id and authorization for query
If you wish to register go to Carrier registration on eu-LISA website.
Appointing a service provider
You can delegate your participation to a service provider. Once appointed, your service provider can be your representative in the carrier for working group and get all the details in order to implement the project smoothly for its client.
Streamlane is currently the representative of several carriers and would be happy to represent other carriers.
Enter into the new Schengen regulations without any turbulences, we are here to help you
We know all these new regulations are a new burden for carriers. Implementation is complex, not core business. You may lack the resources to manage the project and perform all the required tasks to connect to this new system. You can contact Streamlane if you wish to outsource this connection or if you just need free and clear information. We provide the EES ETIAS service as a stand-alone service or as a completary service to our GOVlink service
Contact us, we will be happy to inform you.
We will guide you upon your needs. Streamlane is already registered as an official EES-ETIAS service provider at eu-LISA.