EU initiative

Digitalising travel documents

The EU Commission wants to store ID data on smartphones in the future and introduce contactless border controls with biometrics. This could affect all travelers in the future. We intervene.

Passport and ID card - soon only as smartphone app? At least that's how the EU Commission seems to envision it. In a public consultation, it is still asking for opinions on the digitization of travel documents. We have made a submission there, because we see dangers in the EU Commission's plans. Travelers could be affected by "Digitalzwang" if travel documents are only accepted digitally in the future. Digitalzwang means that there is no non-digital option to participate in matters of everyday life. In this case Digitalzwang would mean that travelers cannot use physical travel documents anymore or are disadvantaged for doing so.
If physical and digital documents are used in parallel, users who travel in the traditional way with a passport or ID card could be disadvantaged. In addition, there is a risk that the control infrastructure to be set up for the digitalised travel documents will also affect people with physical travel documents from biometric mass surveillance.

We believe that the introduction of digitalised travel documents can only be considered if three conditions are met:

  1. Travelers must not be forced to use digital travel credentials. The possibility of using physical travel documents must be guaranteed permanently and not just for the “near future”, as the European Commission is proposing.
  2. Travelers who don’t use digital travel credentials must not be discriminated against. This condition includes that border controls for travelers with physical documents must be equally accessible and sufficiently staffed to enable travel checks in a reasonable amount of time.
  3. Travelers who don’t use digital travel credentials must not, under any circumstances, be affected by the border control technologies required for checking digital travel credentials. Policy options “where all travelers are monitored and their biometric data are processed”, as the European Commission is considering, must be ruled out.

Biometric surveillance

The European Commission's Migration and Home Affairs Department (DG HOME) has launched an initiative to digitalise travel documents. Following the public consultation, this could result in a proposal for an EU regulation in the third quarter of 2023. In its initiative, the EU Commission outlines possible options for what the digitization of travel documents could look like. For example, in a document accompanying the EU consultation, one possible option mentioned (the Commission promotes this option as "A digital passport/digital identity card allowing a full seamless experience") is for all member states to be required by regulation to implement digital travel credentials:

"These measures would exploit one-to-many biometric matching on the move, where all travelers are monitored and their biometric data are processed. These measures would rely on large-scale biometric matching and would enable travelers to pass borders without stopping for being controlled at a border check."

This would subject every traveling person and those who visit or work at travel hotspots to biometric mass surveillance. We oppose this.

Abolition of physical travel documents?

We are concerned about a point that the EU Commission is quickly addressing in passing. It assures us that "in the near future, physical travel documents will continue to exist alongside digital documents". This is already a disturbing anticipation of the future abolition of physical documents. Only the digitalized travel documents would then remain. However, we vehemently reject the idea of forcing passports and ID cards to be digital. In particular, the planned storage of these documents on smartphones poses major security problems. Currently, we are suing against the obligation to store fingerprints in the ID card. If this and other sensitive data were to be mandatorily stored in an app in the future and sent and matched for travel, it exposes all travelers to increased risk. The more frequently biometric data is collected or processed, the higher the likelihood of accidental or malicious data leaks. It is important to remember that biometric characteristics have a special dimension because they enable lifelong control: People can, if need be, change passwords, names, and places of residence to protect themselves from persecution or threats, for example. Biometric data, however, can never be changed.

Questionable understanding of democracy

The European Commission also reveals a problematic understanding of the relationship between the state and its citizens:

"Incorporating biometrics solutions can give screening authorities greater confidence in the traveller’s identity, eventually reducing risk associated with each traveller …"

To consider citizens primarily as a security risk that must be kept in check by the state does not correspond to the fundamental values of democratic societies. This twisted logic of insecurity politics leads to a wrong policy focus. With this proposal, the EU Commission is trying to solve the problem of time-consuming border controls through supposedly more efficient procedures. However, the EU Commission does not ask why border controls are time-consuming in the first place. The right to free movement in the EU is already restricted by the extensive "Security Theater" in the form of invasive border controls. Rather than compromising the security of travelers and their (biometric) data through digitalised travel documents, this problem should be addressed by reducing unnecessary and disproportionate restrictions on free movement in current border control systems. A possible reduction in waiting times at airports resulting from previous interference with the right to free movement is not a valid reason for further interference with the rights of citizens.


We call on the EU Commission to ensure that digital travel credentials and all related procedures may only be introduced as a voluntary option for citizens and travelers in the European Union. The option to use physical travel documents must be permanently guaranteed. Travelers with physical travel documents must not be discriminated against or subjected to biometric monitoring or other border control technologies required for digital travel documents. To facilitate the exercise of the right to free movement within the EU, the European Commission should instead work on proposals to reduce unnecessary and disproportionate violations of the right to free movement and other rights in current border control systems.

Find our full submission to the consultation by the EU commission.

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