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Entry/Exit System (EES): full operational status as of 10 April 2026 – operational and compliance implications

The Entry/Exit System (EES), fully operational as of 10 April 2026, introduces a more stringent and fully automated control of the entry and exit of third-country nationals within the Schengen Area. Early operational issues highlight the need for companies and mobility stakeholders to ensure a structured and carefully managed approach to international mobility in order to mitigate compliance risks and operational disruptions.
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Following the progressive implementation phase launched on 12 October 2025, the European Entry/Exit System (EES)  became fully operational on 10 April 2026.

The introduction of the system entails a strengthening of controls at the external borders of the Schengen Area, with significant implications for the management of international mobility of third-country nationals.

The EES system is governed by Regulation (EU) 2017/2226, which provides for the electronic registration of entry, exit and refusal-of-entry data of third-country nationals travelling maybshort stays within the Schengen Area.

The EES applies, in particular, to individuals who:

  • hold a short-stay visa; or
  • are exempt from visa requirements for stays of up to 90 days within a 180-day period.

Certain categories are excluded as provided by the applicable legislation (including, by way of example, holders of residence permits, family members of EU citizens, and specific categories benefiting from protected mobility regimes).

Functioning of the system

The system replaces manual passport stamping with an automated registration of movements at the border.

In particular, the EES allows for:

  • full traceability of entry and exit dates;
  • real-time monitoring of the duration of stay;
  • automated verification of compliance with the limits set by Schengen legislation.

Initial operational evidence

The first days of full operation have already highlighted certain practical challenges, particularly at major airports.

For instance, disruptions were reported at Milan Linate Airport, where delays in border checks, also attributable to the introduction of the EES, resulted in missed departures for a number of passengers.

These occurrences underline the need for careful planning of international mobility flows.

Calculation of the permitted stay and compliance risks

The system enforces a maximum stay of 90 days within a rolling 180-day period, calculated cumulatively across all Schengen States.

The “rolling” calculation takes into account multiple entries and exits, as well as stays across different Member States.

Any overstay, even if unintentional, may lead to refusal of entry, registration in the EES, administrative sanctions and, in certain jurisdictions (including Italy), potential criminal consequences, as well as negative impacts on future entries into the Schengen Area.

For further details, please refer to the dedicated article available on our website.

Implications for companies

Companies managing internationally mobile personnel are required to adapt their internal processes in order to:

  • accurately monitor periods of stay within the Schengen Area;
  • prevent instances of overstay;
  • ensure continuity of cross-border operations.

Atlasposting

In support of the above activities, A&P Firm provides Atlasposting, a proprietary software solution for the management of international assignments.

The software enables:

  • automated calculation of the permitted stay (90/180 days);
  • monitoring of movements within the Schengen Area;
  • prevention of non-compliance scenarios;
  • operational support to HR and Global Mobility functions.

Conclusions

The full implementation of the EES marks a transition towards a more stringent and automated border control system.

In this context, a structured and informed approach to international mobility becomes essential in order to mitigate operational risks and ensure regulatory compliance.

Regulatory Framework

Authority Source Number Article Type Date Link
EU Regulation (EU) 2017/2226  2017/2226 / Law 30/11/2017 Read more
A&P related service:

Atlasposting – Schengen Compliance for travel in EU 

Atlasposting tracks every day spent in the Schengen area, alerts before limits are reached, and ensures full compliance with EU regulations. Designed for companies managing international assignments for EU and non-EU employees, this feature helps both HR and employees stay on top of their travel days in Europe. 

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