Asbjørn Vollmer Jeppesen
Head of Legal
The EU’s new Entry/Exit System (EES): what project leaders and executives must know before sending staff across Schengen
From October 2025 the EU started rolling out a digital Entry/Exit System (EES) that will replace passport stamping — with full operation across external Schengen borders by 10 April 2026. For companies deploying engineers, supervisors, traveling technicians and project teams across Europe, EES removes the “grey area” around short stays and makes overstay detection automatic.
What EES does, the short version:
- EES digitally records non-EU/third-country nationals’ travel-document data, travel dates and biometric identifiers (photo + fingerprints on first enrolment). Subsequent border checks may use facial verification.
- The rollout is phased (progressive introduction from October 2025) and fully replaces passport stamping by 10 April 2026.
- Data retention: travel records are kept for 3 years (and in certain overstay cases up to 5 years). That travel history will be available to border and visa authorities.
Why this matters for employers sending personnel abroad:
- Automatic overstay detection. The system calculates and exposes the rolling 90-days in any 180-day limit centrally, meaning an overstay is likely to be detected instantly and recorded. Overstays can trigger fines, entry bans and visa refusals in later applications.
- Longer visibility of travel history. Even short / incidental overstays are stored and can affect future deployment ability for that individual (and thus project staffing).
- Operational friction and reputational risk. An employee flagged for overstay may be refused entry on future projects, causing schedule disruption, replacement costs and reputational headaches with clients and partners.
Practical checklist for companies (what to do now)
- Track cumulative Schengen days for each employee. Use a rolling 90/180-day tracker (spreadsheet/HR system) and add automatic alerts at 75–80 days.
- Build buffer time into deployment plans. Avoid back-to-back short stays that cumulatively exceed the 90-day allowance.
- Plan for contingencies: local legal counsel, budget for fines/returns, and a rapid replacement plan for critical roles.
Want help mapping deployment calendars to the 90/180 rule or building a compliance workflow for your project teams?
