Dokumendiregister | Siseministeerium |
Viit | 5-4/45-2 |
Registreeritud | 25.08.2025 |
Sünkroonitud | 26.08.2025 |
Liik | Sissetulev kiri |
Funktsioon | 5 EL otsustusprotsess ja rahvusvaheline koostöö |
Sari | 5-4 Rahvusvaheliste suhete ja välislepingute alane kirjavahetus (AV) |
Toimik | 5-4/2025 |
Juurdepääsupiirang | Avalik |
Juurdepääsupiirang | |
Adressaat | Nordic and Baltic at International Air Transport Association (IATA) |
Saabumis/saatmisviis | Nordic and Baltic at International Air Transport Association (IATA) |
Vastutaja | Janek Mägi (kantsleri juhtimisala, sisejulgeoleku asekantsleri valdkond, piirivalve- ja rändeosakond) |
Originaal | Ava uues aknas |
Unrestricted
Dear Sirs,
I hope my email finds you well.
Please find attached FYI the joint industry paper that has been submitted to the EC and MSs.
Should you have any questions or comments, please let me know.
Kind regards,
Ksenia Zissow Manager Industry Relationships DDG-EUR-Field Offices |
Mob: +46 708 8181 44 |
Page 1 of 3
Industry Recommendations
On residual challenges ahead of the EES start of operations
August 2025
This paper presents the air carriers' proposals to the European Commission and Member States (MSs) to
address the following remaining challenges ahead of the progressive start of operations of the Entry/Exit
System (EES), namely:
1. Issues faced by crew members that do not hold a Crew Member Certificate (CMC) and would therefore
be subject to EES border procedures, and
2. The need for transparent and effective communication from national authorities to air carriers as
concerns the EES rollout at their border crossing points.
1. Crew not holding a Crew Member Certificates
Persistent challenges
1.1 EU MSs adopted different border procedures for crew members not holding a CMC. Typically, these
crew members are exempt from visa requirements based on their passport, crew ID card, or a general
declaration. This is in line with international practices and has been effective for carriers and border
authorities, expediting and facilitating crew experience at such border.
1.2 Since the establishment of the CMC in the first edition of ICAO Annex 9 in 1949, there has been a low
adoption rate globally, with only 16 States issuing CMCs, according to industry evidence. This indicates
that the CMC identity function has not been prioritized and is often considered less secure than
passports.
1.3 With the implementation of the EES, on-duty crew members not holding a CMC will be subject to EES
border procedures, including enrolment. This will increase operational, administrative, and financial
burdens on all carriers, including inefficient crew rotations, operational disruptions, and additional costs.
Most crew members are unable to obtain a CMC as their national authorities simply do not issue them as
a matter of policy. Even when national authorities would do so, the administrative cost of providing each
crew member with the certificate will amount to more than 4 million EUR annually per carrier.
We recommend and call for:
1.4 A legislative solution: amending EU legislation to acknowledge current and future border practices, with
a flexible and harmonized approach across Schengen by:
• expanding the range of crew documents granting visa/EES/ETIAS exemptions and their formats,
with a view to more digitalisation, and
• establishing an EU-wide flexible and harmonized approach to accepted documentation
1.5 Operational measures on crew treatment at border crossing points: the industry proposes that MSs
deploy the necessary measures ensuring that border crossing and processing of crew members
remains unhindered, efficient and smooth, from the start of EES operations and until Schengen
legislation is amended.
Crew members generally pose low aviation security and immigration risks. They are subject to recurrent
background checks, systematic security screening, and are admitted temporarily for clearly defined
duty-related purposes.
Page 2 of 3
The way forward
1.6 In legislation: we will welcome swift and steady progress on the discussions to amend the Schengen
Borders Code and remain committed to contributing to this work.
1.7 Operationally, we encourage MSs and the European Commission to:
• adopt specific measures to expedite crew treatment at the border, for instance through dedicated
queues, and
• provide industry with timely, complete and centralized information on national derogations from visa
and/or ETIAS requirements for crews across the EU, ideally via a dedicated online resource or any
other easily accessible interface
2. Transparent and effective communication from Member States to air carriers
Background and challenges
2.1 Recital (18) of Regulation 2025/1534 recognizes the distinct application of the EES at Border Crossing
Points (BCPs) and emphasizes the importance of effective communication and transparency from MSs
to carriers regarding the deployment of the EES at BCPs.
2.2 It is therefore essential that MSs provide carriers with timely and comprehensive information on their
planned EES deployment at the border. A lack of communication and information flow from authorities
well in advance of the EES rollout would directly hinder our members’ ability to adequately prepare and
inform travellers in a timely manner.
2.3 Expecting air carriers to individually contact each border control authority, each BCP or every airport
management company to obtain details on EES rollout plans, including each phased approach, is most
impractical and inefficient for all actors involved.
2.4 Today, only a small number of MSs are proactively and consistently informing carriers and other affected
stakeholders about the status and implementation plans of EES within their territory.
Our recommendations and way forward:
2.5 We urge each national authority establish regular and centralized communication channels, in order to
provide air carriers with timely and detailed information on national EES rollout plans, including any
update on their approach to the progressive start of operations.
2.6 We call on the European Commission to national authorities on this matter, providing for full
transparency and information flow between all concerned stakeholders across the Union, safeguarding
the Internal Market and the commitments made so far.
Our industry remains committed to collaborate with institutions and authorities and identify effective solutions
and anticipate frictions before the full rollout of the EES.
At the same time, ahead of the start of the European Travel Information and Authorisation System (ETIAS)
operations in 2026, the air transport is also concerned about the negative effects of the disproportionate
proposed increase of the ETIAS registration fee from €7 to €20. We emphasize our call for a thorough impact
assessment justifying the new proposed fee. We call on all MSs to scrutinize thoroughly the Commission’s
decision, evaluating the socio-economic consequence of such a drastic increase.
Page 3 of 3
About us
About A4A (Airlines for America)
Airlines for America (A4A) advocates on behalf of its members to shape crucial policies and measures that promote safety,
security and a healthy U.S. airline industry.
About A4E (Airlines for Europe)
Founded in 2016, A4E represents the united voice of Europe’s leading airlines in Brussels. Its 17 airline group members
represent over 80% of European air traffic and carried over 771 million passengers in 2024. Leading global aircraft
manufacturers are also members of A4E. Airlines with cargo and mail activities transport more than 4 million tons of goods
annually.
About Association of Asia Pacific Airlines (AAPA)
The AAPA is the trade association for scheduled international airlines based in the Asia-Pacific region. The AAPA permanent
secretariat is headquartered in Kuala Lumpur, Malaysia with international representation in Brussels and Washington, D.C.
Collectively, the region’s airlines represent over one-third of global passenger and air cargo traffic, and thus play a leading
role in the ongoing development of global aviation.
Airlines International Representation in Europe (AIRE)
An Airline Association formed principally of European Airlines, based in Brussels Belgium, whose scope is dealing with
advocacy on EU Regulations in Aviation with a number of EU Institutions, ECAC and EASA.
About the Latin American and Caribbean Air Transport Association (ALTA)
ALTA is a non-profit organization that fosters a safer, more sustainable, efficient, and competitive aviation environment for
airlines in Latin America and the Caribbean. We achieve this through advocacy, and collaboration with governments and
industry stakeholders to strengthen connectivity, drive economic development, and support social progress across the
region. Our member airlines carry over 80% of the region’s passengers, underscoring aviation’s essential role in regional
development.
About European Regions Airline Association(ERA)
Founded in 1980, European Regions Airline Association (ERA) is a non-profit trade association representing more than 50
airlines and over 150 associate members involved in European air transport, and is the only association that bring together
the entire spectrum of companies involved in European aviation. The association supports and defends the airline industry in
providing safe, efficient and sustainable air connectivity to all regions of Europe. By lobbying European regulatory bodies on
policy matters, ERA promotes and protects social responsibility, environmental sustainability and the development of
regional economies and local communities.
About IATA (International Air Transport Association)
The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 350
airlines or 80% of total air traffic. We support many areas of aviation activity and help formulate industry policy on critical
aviation issues.
About the National Airlines Council of Canada (NACC)
The National Airlines Council of Canada represents Canada’s largest national and international passenger air carriers: Air
Canada, Air Transat, Jazz Aviation LP and WestJet. It promotes safe, sustainable, accessible and competitive air travel by
advocating for the development of policies, regulations and legislation to foster a world-class transportation system. Pre-
pandemic our members collectively carried over 80 million passengers annually, directly employed over 60,000 people and
served as a critical component of Canada’s overall air transport and tourism sector, which supported more than 630,000 jobs.
Nimi | K.p. | Δ | Viit | Tüüp | Org | Osapooled |
---|---|---|---|---|---|---|
Message from the global air transport industry - challenges ahead of the EES start of operations | 19.08.2025 | 1 | 5-4/45-1 | Sissetulev kiri | sisemin | AIRLINES FOR EUROPE |
Aviation industry's recommendations for a phased roll-out of the Entry/Exit System | 28.11.2024 | 1 | 5-4/51-4 | Sissetulev kiri | sisemin | AIRLINES FOR EUROPE |
Urgent recommendations for the successful implementation of the EES | 25.09.2024 | 1 | 5-4/51-3 | Sissetulev kiri | sisemin | AIRLINES FOR EUROPE |
Declaration of Readiness for the entry into operation of the EES | 26.07.2024 | 3 | 5-4/64-1 🔒 | Sissetulev kiri | sisemin | Eesti alaline esindus Euroopa Liidu juures |
Preparations for the launch of the Entry/Exit System - Transport Industry Statement: Urgent Action Needed ahead of the EES Implementation | 02.07.2024 | 1 | 5-4/51-2 | Sissetulev kiri | sisemin | AIRLINES FOR EUROPE |
Growing Concerns Regarding Entry/Exit System (EES) Implementation | 17.05.2024 | 3 | 5-4/51-1 🔒 | Sissetulev kiri | sisemin | Airports Council International/ACI EUROPE |
Ühispöördumine: Entry/Exit System (EES) | 22.01.2024 | 119 | 5-4/6-1 🔒 | Sissetulev kiri | sisemin | International Air Transport Association (IATA) |
Letter regarding the implementation of regulation EU 2226/2017 | 10.02.2023 | 465 | 5-4/15-1 🔒 | Sissetulev kiri | sisemin | International Air Transport Association (IATA) |
Estonian situation with SIS Recast implementation | 22.12.2022 | 515 | 5-4/66-2 | Sissetulev kiri | sisemin | EL Komisjon |
Entry/Exit System (EES) | 09.12.2022 | 528 | 5-4/27-4 🔒 | Sissetulev kiri | sisemin | ACI EUROPE |
Estonian situation with SIS Recast implementation | 10.11.2022 | 557 | 5-4/66-1 | Väljaminev kiri | sisemin | EL Komisjon |
Effective start of operations of the Entry/Exit System - aviation associations letter | 12.07.2022 | 678 | 5-4/27-3 🔒 | Sissetulev kiri | sisemin | ERA (European Regions Airline Association) |
Start of operations of the Entry/Exit System | 18.05.2022 | 733 | 5-4/27-2 🔒 | Sissetulev kiri | sisemin | ACI EUROPE (Airports Council International) |
Effective start of operations of the Entry/Exit System - aviation associations letter | 10.05.2022 | 741 | 5-4/27-1 🔒 | Sissetulev kiri | sisemin | AIRLINES FOR EUROPE |