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Which EU member states collect fingerprints and facial images for EES and do any temporarily opt out?
Executive Summary
The Entry/Exit System (EES) will collect fingerprints and facial images from non‑EU nationals in the majority of Schengen and EU countries when it starts operations on 12 October 2025, with progressive roll‑out completing by April 2026. Most reporting lists the same set of implementers — a cohort of 25–26 EU member states plus four Schengen non‑EU countries — while Cyprus and Ireland are explicitly exempt, and regulatory texts note special derogations or opt‑out arrangements that create nuance for states such as Denmark [1] [2] [3] [4] [5] [6].
1. Who the reporting names as collectors — a near‑comprehensive roll call that largely agrees
Multiple contemporaneous reports list a largely consistent roster of countries that will collect fingerprints and facial images for the EES: Austria, Belgium, Bulgaria, Croatia, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden — with Iceland, Liechtenstein, Norway and Switzerland added as Schengen non‑EU implementers in many lists [1] [3]. These sources present the EES as operating in 25–26 EU member states plus the four Schengen partners, and they emphasise that the system targets non‑EU nationals crossing external borders. The reporting frames the scope as broad and near‑universal across the Schengen area, highlighting the biometric capture (fingerprints and a facial image) as the core operational change [4] [2].
2. Where sources diverge — counts, timing and the status of Denmark and Ireland
Published accounts differ slightly on numbers and timing: some items state the EES will cover 25 EU countries with Cyprus and Ireland exempt, while others describe 26 EU member states among 29 total countries implementing EES [2] [4]. Timing is presented consistently as a phased roll‑out beginning 12 October 2025 with full implementation expected within about six months — cited end dates range around 9–10 April 2026 [2] [4] [6]. The most significant legal nuance arises around Denmark and Ireland: several news lists include Denmark among implementers, but the formal regulation text highlights that Denmark and Ireland have special opt‑out arrangements from certain EU justice and home‑affairs measures, which introduces legal complexity even if practical implementation proceeds [5]. This explains the superficial discrepancy between reporting and regulatory nuance.
3. Legal background — what the regulation actually says about derogations and progressive starts
Regulation (EU) 2025/1534 establishes rules for the progressive start of EES operations and explicitly contemplates temporary derogations and special arrangements for Member States with pre‑existing opt‑outs or internal procedures. The regulation requires member states to implement biometric collection but provides mechanisms for phased entry into operations and tailored timelines where national legal or administrative constraints apply [5]. That means while many media lists treat the rollout as a single event across named countries, the legal instrument allows exceptions, transitional measures or administrative delays for states with particular treaty positions or domestic constraints, which is why some reporting flags Denmark’s and Ireland’s special status even when other sources list Denmark among implementers [5] [2].
4. How the reporting frames exemptions — Cyprus, Ireland and practical realities
Multiple reports explicitly identify Cyprus and Ireland as exempt from EES biometric collection; this is a consistent point across several summaries and the operational descriptions [1] [2]. The exemption stems from the particular treaty arrangements and Schengen participation status of those states. The practical import is that travellers to Cyprus and Ireland will not be subject to automated fingerprint and facial-image capture under EES in the same way as across the EES network. Media coverage that omits the regulatory caveats may still correctly list countries that will physically collect biometrics, but regulatory text clarifies why certain states are treated differently and why phased roll‑outs or temporary derogations exist [1] [5].
5. What to watch — implementation timelines, operational roll‑out and potential agenda signals
Observers should watch the phased implementation dates and national communications for airports, seaports and rail hubs as the EES goes live; reports note staged starts at major entry points with full functionality expected by April 2026 [2] [4] [6]. Media pieces tend to simplify the legal subtleties, presenting a single list of implementers, while the regulation documents the legal mechanisms that allow exceptions or temporary derogations. This difference in emphasis reflects two agendas: operational reporting focuses on who will collect biometrics in practice, whereas legal texts emphasise treaty opt‑outs and transitional derogations that can delay or alter how a member state implements the system [3] [5].
6. Bottom line — an operational list plus legal caveats
In operational terms, most reliable summaries indicate that all named EU and Schengen countries except Cyprus and Ireland will be collecting fingerprints and facial images under EES, with Iceland, Liechtenstein, Norway and Switzerland included among non‑EU implementers; phased national starts began 12 October 2025 and continue toward full deployment in April 2026 [1] [4] [6]. In legal terms, Regulation 2025/1534 preserves derogation mechanisms and acknowledges opt‑outs, so country‑level implementation can vary in timing and scope; this is why some sources treat Denmark’s position differently even when others list it among implementers [5] [2].