The Coordinated Supervision Committee (CSC) of Europe’s data-protection authorities confirmed on 22 October that the new biometric Entry/Exit System (EES) is now formally under its oversight, following the system’s operational start on 12 October. Although Ireland and Cyprus remain outside Schengen, the decision matters to the Irish market because Dublin Airport handled 5.2 million outbound trips to Schengen countries in 2024 and because Irish passport-holders will have their fingerprints and facial images recorded every time they cross an external Schengen border.
Under the progressive roll-out agreed by the EU Council and Parliament, member states must capture at least 10 % of crossings in the new database by 11 November, rising to 35 % with biometrics after three months and 100 % by April 2026. During the transition, passport stamps continue, but travellers could face dual-processing queues. Airlines are warning group-travel organisers to build a minimum 45-minute buffer into connections at continental hubs, and ground-handling agents at Paris-CDG and Frankfurt have created dedicated “IE/UK nationals” lanes to explain the new procedure.
For corporate mobility teams, the biggest impact will be on short-term assignees shuttling between Irish headquarters and EU sites. Over-staying the 90/180-day allowance will now trigger automated alerts and could complicate A1 social-security certificate applications. Employers should audit Schengen-day counts for frequent travellers and update travel-management-company profiles with passport and fingerprint-enrolment status.
Data-privacy officers must also note that traveller records will be retained for three years and can be accessed by member-state law-enforcement agencies. The Data Protection Commission in Dublin has issued guidance reminding organisations that storing EES data locally is unnecessary and may breach the GDPR’s data-minimisation principle.
Under the progressive roll-out agreed by the EU Council and Parliament, member states must capture at least 10 % of crossings in the new database by 11 November, rising to 35 % with biometrics after three months and 100 % by April 2026. During the transition, passport stamps continue, but travellers could face dual-processing queues. Airlines are warning group-travel organisers to build a minimum 45-minute buffer into connections at continental hubs, and ground-handling agents at Paris-CDG and Frankfurt have created dedicated “IE/UK nationals” lanes to explain the new procedure.
For corporate mobility teams, the biggest impact will be on short-term assignees shuttling between Irish headquarters and EU sites. Over-staying the 90/180-day allowance will now trigger automated alerts and could complicate A1 social-security certificate applications. Employers should audit Schengen-day counts for frequent travellers and update travel-management-company profiles with passport and fingerprint-enrolment status.
Data-privacy officers must also note that traveller records will be retained for three years and can be accessed by member-state law-enforcement agencies. The Data Protection Commission in Dublin has issued guidance reminding organisations that storing EES data locally is unnecessary and may breach the GDPR’s data-minimisation principle.
