EU-LISA: The BizAv Guide

The EU has officially started switching on its new border-control system, and the rollout is already affecting how flights are handled across Europe. Here’s the quick version as of Jan 2026:

EES is live (sort of). Launched in Oct 2025, with a staggered rollout across Europe – some airports are already using it, while others are still coming online.
Full switch by April 2026. During the six-month transition, passports will still be stamped alongside digital checks, but once the rollout is complete across all 29 EES countries, manual stamping will end entirely.
All travellers included! Everyone crossing an external Schengen border (no matter if they arrive by airline, private jet, yacht, car, or donkey) must comply with EES and ETIAS – but who is responsible for the checks depends on the type of operation. Commercial operators must register with EU-LISA and verify pax electronically before boarding, while border guards handle checks for private arrivals.
Private operators opting in. Even though owner-operated private flights are exempt from EES and ETIAS requirements, many are registering with the system anyway so they can confirm pax docs and authorisations in advance – helping avoid surprises for their pax on arrival.

So here’s a more detailed look at what’s changing, when, and what actually matters for BizAv operators.

EES (live from Oct 2025)

Think of EES as the EU’s new digital passport stamp. Operators flying to one of the 29 EES countries need to use the EU-LISA carrier interface to electronically verify whether passengers holding short-stay visas (single or double entry) have already used the number of entries authorised by that visa.

The 29 European countries doing EES:

This check must be done no earlier than 48 hours before the scheduled time of departure.

Remember, this only applies to passengers with short-stay visas for one or two entries. For everyone else (including visa-exempt passengers) border authorities will handle checks during the six-month transition period while EES is phased in across Europe (through 10 April 2026).

So for visa-exempt travellers (like US passengers), operators don’t need to do anything yet under EES – your obligations for them begin later, once ETIAS is live.

Any commercial operators (Part 135 / charter / commercial bizjet operators) must be registered with EU-LISA to access the carrier interface. Operators were expected to complete registration and testing before the Oct 2025 go-live. Latecomers can still apply, but should expect delays before being fully approved to use the system.

If you’re flying an owner-operated private non-commercial flight, you’re off the hook – you’re not considered a “carrier” and don’t need to register or query anyone (but read more on this below!)

ETIAS (coming in late 2026)

If EES is about recording entries and exits, ETIAS is about screening pax before they arrive. It’s the EU’s version of the US ESTA – a quick online authorisation for visa-exempt travellers.

Operators flying to one of the 30 ETIAS countries (the 29 EES states plus Cyprus) will need to verify before boarding that all visa-exempt pax hold a valid ETIAS travel authorisation.

As with EES, the verification query can be made anytime from 48 hours before departure (that “no earlier than 48 hours” rule).

When ETIAS launches (expected in the last quarter of 2026), there’ll be a six-month transition followed by a six-month grace period, so enforcement will ramp up gradually rather than overnight.

The ETIAS fee is €20 (up from €7) and is waived for travellers under 18 or over 70.

ETIAS obligations mostly apply to travellers, but operators must verify that passengers who need an ETIAS actually hold one before boarding.

Again, this rule only applies to commercial operators.

For more info on all the basic stuff of EES and ETIAS, check out the homepage here.

Are private flights definitely exempt?

Since 2024 we have asked EU-LISA this question many times, in different ways. Their position had always been the same. They told us that EES and ETIAS apply to commercial flights, not private flights.

They confirmed that:

Private flights with non fee paying passengers are out of scope for EES and ETIAS.
This remains the case even if the pilots are paid to operate the aircraft.
Operators using privately owned aircraft for private purposes are not considered “carriers” and do not need to connect to the carrier interface.
Company owned and operated aircraft flying to the EU for private purposes also fall under the private flight definition.

Based on this, the industry understanding was simple: private flights did not need to do EES or ETIAS.

However!!!

In Jan 2026, EU-LISA has now refined this position, with a new and much narrower distinction. They have told us the following:

Privately operated flights that are not open for public use, with a crew hired directly by the aircraft owner, do not need to comply with EES and ETIAS obligations, therefore, no need to register with eu-LISA and query the travellers in scope of EES and ETIAS.

Flights of private aircrafts managed by a professional operator (crew, maintenance, handling, etc.), or managed by a commercial charter operator, even if the flights are not open for public use, need to comply with EES and ETIAS obligations, therefore, the operator needs to register with eu-LISA and query the carrier interface.

Therefore, if you transport solely the owners of the plane and their guests, you will not need to register with eu-LISA.

In other words:

Owner-operated private flights with owner-hired crew = no EES / ETIAS.
Professionally managed or charter-operated private flights = EES / ETIAS required.

This explains why two aircraft that both look like “single owner private flights” can now fall on opposite sides of the rule, depending on how the aircraft and crew are managed.

Why some private flights are registering anyway

Several OPSGROUP members who do purely owner-oprated private flights have told us that they have registered for the system anyway. The benefit of doing this is that you will be able to confirm prior to the flight that your pax have all the proper documentation they need – potentially avoiding any nasty surprises on arrival.

With the EES system, passports will no longer be stamped, so in the case of a limited visa that only allows a certain number of visits, operators will have no way of confirming that all the allowed visits have not been exhausted unless they check the system.

Also, similar story when ETIAS starts. Though there will be a website to confirm a passenger has an approved ETIAS, EU-LISA says there are a lot of reasons for an ETIAS to be revoked, so checking the system prior to the flight will help make sure the ETIAS is still valid.

More info for operators

For more info, you can check the EU-LISA homepage for operators here.

For answers to pretty much all the questions we can think of, including how to actually use the system as an operator, check this FAQ document provided by EU-LISA.

2 Comments

Chris Yoder says:

15 June, 2022 at 5:19 pm

Can anyone comment on “not managed by an external company”? Our corporate structure is organized in a way that the owner has a dry-lease in place for personal travel. The pilots and maintenance work for a third-party whose only job is to provide pilot and maintenance services to the registered owner and dry lessee.

Similarly, what if you own an aircraft and use full-time contractors to crew or maintain your aircraft?

Enrique Hernandez says:

8 June, 2022 at 11:32 am

Well my department falls into the not need to comply with this new mandate and we already registered and paid the fees.

Now What?

EU-LISA: The BizAv Guide