What medical or functional criteria qualify persons with disabilities for an EES biometrics exemption?

Checked on November 29, 2025
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Executive summary

The EU Entry-Exit System (EES) requires most non‑EU short‑stay travellers to provide facial images and fingerprints on first entry; exemptions listed in reporting focus on age groups, family members of EU citizens and residents, and legal residents — but explicit medical or functional disability exemptions are not detailed in the available reporting [1] [2] [3]. Available sources do not mention a published, specific medical or functional criteria set that qualifies people with disabilities for an EES biometrics exemption (not found in current reporting).

1. What EES collects and who it targets — the baseline

The EES records name, travel‑document data, a facial image and fingerprints for non‑EU nationals on short stays and logs entry and exit dates and places; it is being rolled out from 12 October 2025 across 29 countries and will be progressively implemented over six months [1] [2]. Journalistic accounts and travel guides consistently describe fingerprint and face capture at first crossing, with biometric data retained and used to verify subsequent entries [4] [5] [6].

2. Publicly identified exemptions — what reporters list

News outlets and syntheses identify several exemptions and special categories: children (variously under 12 for fingerprint exemptions in reporting), travellers under 18 or over 70 for certain administrative exemptions (payment or processing in some summaries), EU/EEA residents and family members of EU citizens, and some Schengen‑excluded states or specific border practices [6] [2] [3] [1]. Industry pieces and airline guidance reiterate that legal residents are already biometrically registered via residency processes and so are outside the short‑stay capture requirement [3] [7].

3. What the sources say — and do not say — about disability or medical exemptions

None of the provided sources sets out a specific medical or functional criteria list (for example, diagnoses, mobility limitations, prosthesis use, or cognitive impairments) that would automatically exempt a person with disabilities from EES biometric capture. Reports note age‑based fingerprint exemptions for young children and signal that certain categories (residents, EU family members) are exempt, but explicit disability or health‑based rules are absent from the reporting sampled here [6] [3] [1]. Therefore: available sources do not mention detailed medical/functional exemption criteria for people with disabilities (not found in current reporting).

4. Practical accommodations flagged by reporting — what travellers and advocates can expect

Coverage describes procedural realities that imply practical accommodations may be possible even if formal exemptions are not publicised: border staff may conduct secondary checks or manual processing in complex cases, and some sources advise travellers to expect human intervention where automated capture fails (e.g., poor fingerprint read, physical inability to comply) [8] [5]. Travel guidance recommends advance planning — extra time, documentation and, where relevant, proof of residency or EU family status that already excludes one from EES capture [5] [9].

5. Two competing perspectives in the sources

Security and migration authorities, as represented in EU pages and policy reporting, frame EES as a necessary tool to prevent irregular migration and identity fraud while asserting respect for rights and data protection [1]. Travel industry voices and advocacy‑minded reporting highlight operational burdens and call for exceptions or practical solutions for groups like professional drivers or people with special needs — but these calls have not translated into a published disability‑specific exemption regime in the sources reviewed [2] [10].

6. What to do now if you or someone you assist has a disability

Because no medical/functional criteria are published in these sources, travellers with disabilities should carry relevant documentation (medical letters, proof of EU residency or family status when applicable) and seek guidance in advance from the embassy/consulate of the Schengen country of first entry and their carrier. Sources indicate border officers can apply manual checks or secondary screening when automated kiosks fail or circumstances are atypical — prepare for extra processing time [8] [5].

7. Limits of available reporting and next steps for verification

This analysis is limited to the provided reporting; official EES Regulation text, operational guidance from eu‑LISA or national border authorities might contain specific accommodation procedures or medical exemption criteria not covered here. For definitive, legally binding criteria consult the EU Commission/EU‑LISA operational guidance or national border force instructions — those documents are not included in the current sources (available sources do not mention those specific operational rules) [1].

Want to dive deeper?
What is an EES biometrics exemption and who administers it?
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What documentation is required to support an EES biometrics exemption request?
How do immigration officers evaluate functional limitations for EES biometric exceptions?
Can caregivers or legal representatives submit biometric exemption requests and what is the process?