EU: Interoperability: Letter confirms delays in implementation of “complex and challenging” plan


It is unsurprising that the creation of the EU’s ‘Big Brother’ system is facing obstacles and delays – the same happened with the Schengen Information System a decade ago. What is striking is that the all these new legal instruments will be implemented and interconnected simultaneously without leaving room to test their reliability and performance.

In December the Justice and Home Affairs Council agreed to revise the timeline for the implementation of the EU’s interoperable policing and migration databases. The decision was based on information provided by eu-Lisa, the EU agency responsible for the operational management of large-scale IT systems, and now being published here (pdf).

In a letter dated 8 December 2021, eu-Lisa informed the Slovenian Presidency of the Council of a revised timeline for the implementation of interoperability, “the most complex and challenging transformation program that has launched in the last decades globally.” Through the interoperability initiative, personal data on hundreds of millions of foreign nationals that is currently held in separate systems will be merged in a giant new database, the Common Identity Repository, and new systems (for example, an automated Multiple Identity Detector) will be introduced.

The December letter followed a previous eu-Lisa report about the implementation of the forthcoming Entry/Exit System (EES), which is faced with “substantial delays”. An alternative timeline for implementation of the EES, the European Travel Information and Authorisation System (ETIAS) and interoperability was drawn up by eu-Lisa and member states with the aim of not affecting the “ultimate objective of having the new interoperability architecture implemented by the end of 2023.”

The new timeline was endorsed by eu-LISA’s Management Board on 16 November 2021, as the “only one feasible” taking into account the delays in the implementation of the revised Schengen Information System Regulations, scheduled for end of June 2022. Under this timeline, EES will start its operations at the end of September 2021 and ETIAS mid-May 2023.

The letter contains an Annex with milestones for the implementation of each information system and their interoperability at central and national level.

  • For EES: compliance test with member states will commence beginning of March 2022 and the preparation for entry into operation will start beginning of August 2022.
  • For ETIAS, integration tests will begin in June 2022, compliance tests with member states in November 2022 and preparation for entry into operation in March 2023.
  • For ECRIS-TCN (the European Criminal Records Information System for Third-Country Nationals), integration tests will begin in July 2022, compliance tests with member states in November 2022 and preparation for entry into operation in March 2023.
  • Interoperability: integration tests will begin in January 2023, compliance tests with member states in June 2023 and preparation for entry into operation mid-October 2023.

The annex also reports that the revised VIS will be implemented after the end of 2023. Finally, the letter states that in relation to the Multiple Identity Detector, one of interoperability components, which was supposed to become operational after a transitional period, will need a revised and shortened transitional period.

The letter concludes with key success factors for the implementation of the alternative timeline, including: the adoption of outstanding legal instruments, such as the Eurodac proposal and ETIAS implementing and delegated acts; the coordination of all actors at national and EU level; “engagement with all national stakeholders”; and “continuous political oversight and support at central and national level.”


Further reading

Image: Jasper Nance, CC BY-NC-ND 2.0


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