Migration and Fundamental Rights Bulletin - 2/2026

The EES started progressively on 12 October 2025, according to Regulation (EU) 2025/1534. While a few Member States, such as Sweden, Latvia and Malta operated the EES on all border crossing points (BCPs) from the beginning, others, such as Austria, Belgium, Bulgaria, Denmark, France, Germany, the Netherlands, Poland and Slovakia, initially deployed the system only at selected BCPs for the first 60 days while passport stamping continued at other BCPs.

Prior to the progressive start, in March 2025, the European Data Protection Supervisor (EDPS) raised data-protection concerns because data recorded during the progressive start could be incomplete, and that such incomplete data may cause negative consequences for third-country nationals. Regulation (EU) 2025/1534 established safeguards for this transitional period. For example, according to Article 5 (3) authorities should not take adverse decisions on the basis of there being no registration of the alleged entry or exit in the EES. Nevertheless, border guards in the survey and in the Franet consultation reported divergent national practices to deal with low quality and incomplete data in the EES as well as concerning the acceptable quality threshold for fingerprints and facial images. This shows that, despite the existence of legal safeguards, their effective application in practice remains crucial. The handling of vast volumes of data under time pressure increases the risk of errors and potentially flawed conclusions.

Before the EES was fully rolled out on 10 April 2026, the Airport Council International (ACI) reported about up to two hours of waiting times at peak periods at BCPs, referring to staff shortages, and technical problems with self-service terminals at border crossing points and the central system. Also, the International Air Transport Association (IATA) warned that the EES roll-out was causing major delays. On the first day of full operation, disruptions and missed flights were reported. Border guards told FRA of malfunctioning or unused kiosks, rejected fingerprints, unreliable facial images, and little staff guidance.

To assess perceptions of the impact of the EES on waiting times at BCPs, FRA’s survey asked respondents at the beginning of June 2026 of their experience with increased waiting times. Out of 121 respondents, 50 were employed at land BCPs, 49 at air BCPs, two at sea BCPs and 11 at the central/ministerial level. Nine respondents did not provide information on their workplace. The results presented below are based exclusively on respondents who reported working at a land, air or sea BCPs; respondents with missing workplace information were excluded from the analysis of this question.

The perceived increase in waiting times was similar between land and air BCPs according to the survey. Overall, more than a third of respondents (45 out of 121) reported a large or very large increase in waiting times, indicating that the EES had increased waiting times by more than 50 % on average at their BCP. About one-fifth (25 out of 121) reported a moderate increase in waiting times of between 30 % and 50 %, while around one-sixth reported a small (between 10 % and 30 %) or negligible increase in waiting times. These findings suggest that a substantial proportion of respondents perceived the implementation of the EES as having led to a significant increase in average waiting times at their BCP.

Figure 1 summarises the respondents’ views on waiting time increase at land and air BCPs.

Figure 1 – Waiting time increase at land and air BCPs

Alternative text: The chart shows different reported levels of increase in waiting times at land and air BCPs. Most respondents indicated a large increase (28) or a moderate increase (25), followed by a very large increase (17). Fewer respondents reported a small increase (14), while the smallest number reported no change or a negligible increase (8).

Source: FRA, 2026.

Note: n = 121. Question: ‘ ‘Thinking of the past four weeks, how would you estimate the EES has increased the waiting time on average at your BCP? ‘ Response options were: (a) very large increase (>70 %); (b) large increase (>50 %–70 %); (c) moderate increase (>30 %–50 %); (d) small increase (>10 %–30 %); and (e) no change or negligible increase (≤10 %).’ Responses ‘I do not know’ or ‘Not applicable’ are not included in the figure.

These findings were confirmed by media reports. Queues at airports in France, Greece, Italy, the Netherlands, Portugal and Spain were typically averaging two to three hours during peak periods, according to media reports. A Belgian media source reported on four-hour long queues at the Brussels airport. In Italy, for example, a flight from Milan Linate to Manchester departed with only 34 of 156 passengers on board, leaving 122 passengers stranded in border control queues caused by EES processing, as media reported in April. In France, at the end of May, the Port of Dover confirmed that border authorities stopped gathering the additional biometric data after people had waited for up to six hours in hot weather, the media reported. By mid-April, according to media reports, Greece had stopped collecting biometric data for British nationals. At the end of May, this practice was reversed again, as the British government announced.

Respondents to FRA’s survey were asked which factors contributed to the delays. The most commonly cited factors were biometric data collection, system delays or reduced processing capacity and high volumes of travellers.

A few countries, such as Austria or Bulgaria, did not see a significant increase in waiting times at airports following the EES start. According to an interview with the Bulgarian Border Police, recruiting 240 additional border guards before the EES launch helped increase border-check capacity. In Austria, as reported to FRA by the Federal Ministry of the Interior, on-site staff and dedicated services support travellers at the border, including assistance for persons with reduced mobility and active queue management to prevent delays or family separation.

Long waiting times disproportionately affect vulnerable groups, including children, elderly people, pregnant women, and persons with disabilities. Inadequate infrastructure and staffing forced some passengers, sometimes with infants or reduced mobility, to wait for hours in overcrowded, poorly ventilated spaces with limited access to toilets, drinking water and places to sit.

Respondents to FRA’s survey working at land and air BCPs indicate that basic passenger facilities in areas where EES data collection takes place are often limited. The survey asked respondents whether seating, drinking water, and accessing toilets were available for passengers waiting to complete EES data collection at their BCPs. For each facility, respondents could indicate whether it was available and easily accessible, available but difficult to access or not available. Out of 50 respondents working in land BCPs, more than half (28) reported that seating was not sufficiently available. Similarly, among the 49 respondents working in air BCPs, 21 reported that seating was unavailable. Accessing toilets in land BCPs was reported as ‘not available’ or ‘available but difficult to access’ by 21 out of 50 respondents working in land BCPs. Access to free drinking water was reported as not available by 32 out of 50 respondents working in land BCPs.

Figure 2 summarises reported access to basic facilities across land and air BCPs, including free drinking water, seating, and toilets.

Figure 2 – Available facilities at land and air BCPs

Alternative text: The chart shows different levels of availability of facilities, that is: free drinking water, seating and toilets, at land and air Border Crossing Points (BCP). For each response, bars on the chart are colour-coded, showing the different responses given by border guards working at land BCPs and air BCPs. Most respondents from land and air BCPs indicated that free drinking water (43) and seating (49) are not available. As for toilets, most respondents in land and air BCPs said that they are available and easily accessible (52).

Source: FRA, 2026.

Note: n = 121. Question: ‘For passengers waiting to complete EES data collection at your BCP, how available are the following facilities within the immediate queueing area or within a short walking distance (≤2 minutes)? Please select one option for each item: Toilets; Seating (e.g. benches, chairs); free drinking water; land/sea borders only: Sheltered areas providing protection from sun, rain, or other adverse weather conditions.’ Responses from sea BCPs are excluded from the analysis owing to the low number of respondents. Responses ‘I do not know’ or ‘Not applicable’ are also not included in the figure.

FRA’s Entry/Exit System: Fundamental rights guidance for border guards stresses that border authorities should actively identify and support travellers with specific needs—including children, families, older persons and people with disabilities—through tailored assistance, accessible procedures and priority handling where necessary.

The EES processes sensitive personal data. Next to travellers’ names, travel-document data, the date and place of entry and exit – the system also records fingerprints and facial images. While children under the age of 12 are exempt from the requirement to give fingerprints, there is no age limit for facial images (Article 17 of the EES Regulation 2017/2226). Member States may access the data for border management, immigration and law-enforcement purposes. Europol may also access the data for law-enforcement purposes and under strict conditions the data may be transferred to another Member State, a third country or an international organisation for return or law-enforcement purposes.

FRA’s Entry/Exit System: Fundamental rights guidance for border guards emphasizes that data in the EES must be processed lawfully, securely and transparently, with clear information provided to travellers, strict limits on what is collected as well as safeguards to ensure accuracy and protection of sensitive biometric data. Authorities must also enable individuals to access and correct their data, prevent discrimination and ensure strong oversight and accountability.