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From Facilitation to Surveillance: How Digitalization Will Impact Your European Compliance Program

August 12, 2025

From Facilitation to Surveillance: How Digitalization Will Impact Your European Compliance Program

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  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

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  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

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Jo Antoons

Senior Counsel

Fragomen in Brussels, Belgium, Belgium

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[email protected]

T:+32 (0) 2-250-4900

Sara Fekete

Sara Fekete

Manager

Fragomen in London, United Kingdom

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[email protected]

T:+44 (0) 20 7090 9281

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Andreia Florina Ghimis

Senior Manager

Fragomen in Brussels, Belgium, Belgium

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[email protected]

T:+32 (0) 2 250 4879

Related insights

  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

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By: Jo Antoons, Sara Fekete, Andreia Florina Ghimis

Digital transformation is reshaping Europe—not only at the national level across member states, but also at the EU-wide level. This wave of digitalization brings new compliance processes for employers and travelers, navigating a complex landscape of immigration rules, posted worker regulations and social security coordination.

The ultimate goal of these developments is twofold: simplify compliance for companies and facilitate enforcement for authorities.

Digitalization as the Key to Managing Complex Compliance

Europe’s regulatory framework is unique. Employers must navigate the national rules of 27 EU Member States alongside EU provisions for the free movement of people within a single market. In addition, the Schengen area maintains a common external border with strict entry rules.

Compliance with these regulations, especially for short-term business travelers into and throughout the EU, has traditionally been complex. New digital processes aim to untangle this complexity, but also to detect irregularities.

These systems provide standardized, interoperable tools that make compliance easier for employers and allow authorities to monitor and enforce the rules more efficiently. This means fewer administrative burdens and more transparency for all stakeholders.

How the Entry/Exit System (EES) Will Affect Short Term Mobility

From October 12, 2025, the Entry/Exit System (EES) will progressively go live. For more information on the launch status of EES, see Fragomen’s client alert.

EES strengthens EU’s capacities to combat irregular migration and security threats, while easing entry and intra-EU travel for frequent business travelers. However, this also means stricter enforcement of short-term stay requirements in Europe, in particular monitoring the allowable stay in the Schengen area up to maximum 90 days within a six-month period for frequent travelers.

The EES database is expected to maintain:

      • Biometric data (facial image and fingerprints);
      • Passport details; and
      • Entry/exit dates.

It will also be interoperable with other EU information systems, such as the Schengen and Visa Information Systems and the upcoming ETIAS (European Travel Information and Authorization System).

What Non-Compliance Could Mean for Businesses

Non-compliance detected by the EES may:

      • Lead to refusal of entry to Schengen countries.
      • Trigger alerts in other EU databases.
      • Impact future travel and potentially even long-term visa applications for EU countries.

Therefore, in addition to the serious consequences for individuals, this also creates potential business disruptions due to employee travel delays and risks to cross-border operational continuity within the EU. To learn more about navigating EES and ETIAS, read Fragomen’s previous blog.

Digital Transformation of Posted Worker Notifications

Another significant step is the digitalization of Posted Worker Notifications (PWN). The European Commission, European Parliament and Council are finalizing negotiations for a multilingual, centralized EU digital portal linked to the Internal Market Information System (IMI).

This portal will greatly simplify compliance for employers sending personnel across Europe. Benefits include:

      • A single EU portal for submission of a standardized posted worker declaration form instead of separate national procedures and data requirements.  
      • The ability to reuse data for subsequent notifications.
      • Secure document uploads in the employer’s own language.

While initially voluntary, use of this portal is expected to become mandatory by 2026, with nine member states already expressing interest in replacing their national portals.

Enhanced Cooperation and Data Exchange Between Member States

The portal will also boost cooperation and mutual assistance between home and host countries. It allows direct communication and data sharing to support effective workplace inspections ensuring equal pay and employment law protections for posted workers. Discussions also include potentially integrating the A1 social security certificate application process into this system, given its close link to Posted Worker compliance.

Beyond cross-border interoperability, national authorities—immigration, tax, social security, labor inspection—are increasingly connected through digital platforms to enforce rules efficiently and consistently. Concerted and joint inspections are already taking place under the umbrella of the European Labour Authority (ELA), which aims to step up cross-border cooperation in enforcement, expanding their geographic and sectoral scope and fully exploiting the potential of data analytics.

How to Prepare for Stricter Enforcement Across Europe 

Europe’s short-term travel compliance landscape is evolving rapidly with digitalization. New processes will simplify enforcement but also increase enforcement. Companies need to upgrade their short-term travel programs to take a consistent and integrated approach towards compliance in Europe: considering and tackling immigration, posted worker and social security compliance in a streamlined manner.

Preparing today means avoiding business disruption and financial risks, while taking full advantage of the opportunities offered by the European Single Market.

How Fragomen Can Help

Fragomen offers digital compliance solutions that are the sole and necessary response to the digital transformation at EU level and that navigate the complexities of short-term travel compliance in Europe.

Need To Know More?

To learn more about navigating short-term travel compliance in Europe, please contact Fragomen Consulting Europe at [email protected] or Manager Andreia Ghimis at [email protected].

This blog was published on 12 August 2025, and due to the circumstances, there are frequent changes. To keep up to date with all the latest updates on global immigration, please subscribe to our alerts and follow us on LinkedIn, X, Facebook and Instagram.

Country / Territory

  • European UnionEuropean Union

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Sara Fekete

Sara Fekete

Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9281

Andreia Ghimis - Porthole

Andreia Florina Ghimis

Senior Manager

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2 250 4879

Related insights

  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

Related offices

  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Brussels, Belgium

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Sara Fekete

Sara Fekete

Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9281

Andreia Ghimis - Porthole

Andreia Florina Ghimis

Senior Manager

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2 250 4879

Related insights

  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

Related offices

  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Brussels, Belgium

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Jo-Antoons

Jo Antoons

Senior Counsel

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2-250-4900

Sara Fekete

Sara Fekete

Manager

Fragomen in London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9281

Andreia Ghimis - Porthole

Andreia Florina Ghimis

Senior Manager

Fragomen in Brussels, Belgium, Belgium

Email

[email protected]

T:+32 (0) 2 250 4879

Related insights

  • European Union: European Travel Information and Authorisation System (ETIAS) and Entry/Exit System (EES) Launch Status
  • EES and ETIAS: Automation Meets Immigration Complexity

Related offices

  • Fragomen in Frankfurt, Germany
  • Fragomen in London
  • Fragomen in Brussels, Belgium

Related content

  • Fragomen Consulting Europe

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

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In this blog, Senior Counsel Jo Antoon explores what multinational employers need to know about pay transparency, cross-border workers and mobility-related compensation differences as implementation unfolds across the EU. 

Learn more

Media mentions

The PIE: UK Unis Must Treat Compliance as “Strategic Institutional Risk”

Immigration Supervisor Sanjay Parmar discussed how recent UK Basic Compliance Assessment changes are driving universities toward more data-led, proactive compliance management.

Learn more

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Learn more

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Learn more

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Learn more

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