Eurosmart Position Paper on the EU Digital Travel Application: Feedback on proposed amendments by LIBE Committee Shadow Rapporteurs and MEPs
The position paper published on the 16th of June 2025, presents Eurosmart’s detailed feedback on the proposed amendments to the European Commission’s draft regulation on the EU Digital Travel Application, as submitted by Members of the European Parliament’s Committee on Civil Liberties, Justice and Home Affairs (LIBE). Eurosmart, representing the voice of the digital security industry in Europe, welcomes the LIBE Committee’s engagement but seeks to ensure that the final legislative text remains aligned with the goals of secure, user-friendly, and interoperable digital travel credentials, while fulfilling its potential as a secure, effective, inclusive, and trusted system that can benefit both travelers and authorities in the border-crossing process. In this context, Eurosmart offers constructive recommendations to enhance the proposed amendments focusing on maximizing the impact and usability of digital travel credentials, ensuring robust security and data protection, clarifying data governance responsibilities, supporting global interoperability, aligning with the eIDAS and EUDI Wallet framework, preserving the role of physical travel documents, and enabling practical and secure use at European and international borders.
Executive summary
Eurosmart welcomes the amendments proposed by the European Parliament’s LIBE Committee and offers targeted recommendations to ensure that the EU Digital Travel Application delivers high security, data protection, and user-friendly innovation at European and international borders.
- Maximizing Impact: Eurosmart calls for digital travel credentials to be available to most citizens as quick as possible, and in particular urges reconsideration of the age restriction limiting digital travel credentials to individuals above 18, as this risks undermining uptake and overall efficiency. Eurosmart supports ensuring most citizens can obtain digital credentials free of charge.
- Enhancing Security: Eurosmart calls for stronger integrity and authenticity checks on travel document chips, the addition of validity verification, and cybersecurity measures including annual testing and mandatory high-level certification.
- Safeguarding Data Protection: Anonymization is unfeasible for uniquely identifying data; strong encryption is preferred. Eurosmart supports strict limitations on data transfers to third countries and clear encryption standards.
- Clarifying Data Governance: Amendments should clearly specify who has the data controller and processor roles, particularly regarding the EU Digital Travel Application and the Traveller Router.
- Supporting Global Interoperability: Digital travel credentials must align with ICAO standards to ensure global acceptance and functionality.
- Aligning with eIDAS and the EUDI Wallet: Eurosmart supports storing digital credentials in the EUDI Wallet and recommends treating them as electronic attestations of attributes issued by public authorities, while clarifying responsible entities.
- Preserving Physical Documents: Physical travel documents should remain the trust anchor and always be available as a fallback for identity verification.
- Enabling Practical Use: Eurosmart emphasizes that digital travel credentials must support facial recognition and allow optional use beyond border control, such as in financial services, while ensuring legal safeguards and traveler consent.
These recommendations aim to ensure that the EU Digital Travel Application delivers a secure, privacy-preserving, and interoperable solution that improves border crossing efficiency and trust for EU citizens and third-country nationals alike.
For the comprehensive version of Eurosmart's key comments and recommendations on the proposed amendments, please consider the document below: |
