As global migration patterns increase in complexity, the European Union has taken decisive steps to reshape its approach to managing migration with the New Pact on Migration and Asylum. The EURODAC reform is the first building block of this transformation. What are the key elements of the reform, and how are EU Member States expected to implement it?
The European asylum dactyloscopy database (EURODAC) was established in 2000 as a fingerprint database to assist Member States with processing asylum applications. It has since become a crucial tool in the EU’s migration management arsenal. However, increasing complex global migration patterns require a more sophisticated system. The EURODAC reform is more than a technical upgrade: it is a strategic enhancement of its scope and capabilities to achieve a more secure Schengen Area.
The revised EURODAC regulation: key changes
The EURODAC reform focuses on three primary objectives, each targeting a critical area to enhance its effectiveness, security and efficiency.
Closing the gap on illegal immigration
One of the central goals of the EURODAC reform is to strengthen the EU’s ability to track and manage migrants across the Schengen Area, addressing gaps in the existing system by:
- Extending its scope: The legislation expands the categories of individuals who must be registered in the database. This ensures Member States have a complete view of all migrants, including those involved in resettlement, relocation and search and rescue (SAR) operations.
- Lowering the age threshold for biometrics: By reducing the age for biometric data collection from 14 to 6 years, the system now captures data for younger minors, which is crucial for protecting vulnerable children from trafficking and aiding in family reunification efforts.
Enhancing security
Enhancing the security of the EU's external borders and internal security is a key priority, and the EURODAC reform introduces several measures to support this goal:
- Advanced biometrics integration: the legislation acknowledges the need for expanded data collection, including facial imaging biometrics and alphanumeric data. This mandatory shift towards multi-modal biometrics represents a substantial technological advancement, enabling more accurate identification and reducing the risk of identity fraud.
- Expanded law enforcement access: the system now grants broader access to law enforcement authorities, ensuring they can leverage EURODAC’s data for crucial security operations. With alphanumeric data searches, EURODAC also enables more sophisticated queries, enabling law enforcement agencies to efficiently track individuals involved in terrorism and serious criminal activities.
- Interoperability with EU systems: EURODAC will be fully interoperable with other major EU information systems such as the Schengen information system (SIS), the entry exit system (EES), the visa information system (VIS), and the European travel information and authorisation system (ETIAS). This interoperability ensures seamless data exchanges, enhancing the EU’s overall security framework.
Reinforcing efficiency in migration management
The EURODAC reform also aims to make migration management more efficient, supporting Member States in handling asylum applications and other migration-related processes:
- Shifting responsibilities: the legislation allows for greater flexibility in shifting responsibilities between Member States to optimise the management of asylum seekers and reduce administrative burdens.
- Expanded data storage: the system now includes additional categories of identity and business data, providing a richer dataset for decision-making and operational planning
- Information sharing with third countries: to facilitate the return of individuals to their countries of origin, the EURODAC reform enhances data-sharing mechanisms with relevant non-EU countries, helping streamline the return process and improving overall migration management.
Five strategic actions for timely implementation with concrete immediate steps
The timeline for implementing the EURODAC reform is tight, with Member States having until mid-2026 for a full roll-out. To stay on track, national migration authorities must act swiftly and efficiently to prepare for the upcoming changes.
Below are five strategic actions that Member States should take, alongside immediate steps to ensure they meet the mid-2026 deadlines.
1. Awareness and capacity building:
Raising awareness among national stakeholders is critical for the smooth implementation of the EURODAC reform. Stakeholder alignment across national IT, law enforcement, immigration authorities and other relevant bodies is essential. Member States should recognise that EURODAC is not a standalone system but a vital part of the broader European migration and security framework, which requires synchronised efforts.
Immediate actions:
- Establish a national EURODAC task force: set up a cross-functional task force consisting of representatives from all relevant authorities – immigration, IT, law enforcement and legal teams. The goal is to ensure that all stakeholders are aligned from the outset and that efforts are coordinated across departments and jurisdictions.
- Initiate stakeholder training programmes: organise immediate training workshops to educate national stakeholders on how EURODAC integrates with other EU systems and the specific challenges of biometric and alphanumeric data collection.
2. Business impact assessment:
Analysing all pieces of legislative documentation to assess not only the mere functional evolution of the system but also the opportunities for optimisation in the various business processes and within the national organisation.
Immediate actions:
- Conduct a business process audit: launch an immediate audit to assess how new requirements, such as expanded biometrics and new data categories, will impact existing workflows. Involve stakeholders from different departments to ensure that all potential operational changes are identified and addressed early.
- Leverage past lessons in business process optimisation: review how past IT system upgrades (e.g. SIS or VIS) impacted business processes, and use those lessons to pre-emptively optimise EURODAC-related workflows. This can help reduce administrative burdens as well as save time and resources during implementation.
3. IT infrastructure gap analysis:
The EURODAC reform introduces advanced biometric and data-sharing requirements that require significant IT infrastructure upgrades. Member States should focus on ensuring that their systems can handle increased demand while also ensuring interoperability with EU-wide systems.
Immediate actions:
- Conduct a comprehensive IT audit: immediately assess national IT infrastructure to ensure that it can accommodate the increased volume of biometrics (fingerprints, facial recognition) and alphanumeric data. Include relevant stakeholders (IT, legal and operational) in the audit to ensure alignment on capacity and security needs.
- Leverage technical expertise from past large-scale IT projects: draw on expertise from professionals who worked on other large-scale EU projects (such as SIS, EES and ETIAS) to avoid common pitfalls like data integration failures or system overloads. This ensures that IT infrastructure upgrades are smooth and interoperable with other EU systems.
4. Building collaborative interoperability:
Given the need for collaboration between authorities introduced by the interoperability requirements between EURODAC and other EU systems, it's crucial to establish collaborative frameworks that clearly define the responsible sharing and usage of data. This is essential to maintain data integrity and security and ensure true transversality of business processes. The success of the EURODAC reform hinges on the readiness and coordination of these systems, making collaborative efforts among all stakeholders essential.
Immediate actions:
- Establish an identity management collaboration framework: protocols should be established to handle data sharing, comparison and conflict resolution as EURODAC enters full interoperability with other EU systems.
- Create (or join) a national interoperability coordination body: this action highlights the importance of a coordination body in establishing clear communication channels, incident response procedures and regular readiness tests to handle challenges arising from increased system interconnectivity.
5. Data protection compliance:
Compliance with GDPR and new data protection regulations introduced in the EURODAC reform is non-negotiable. Member States need to ensure that data protection is built into their systems from the outset, with robust measures to safeguard personal and biometric data.
Immediate actions:
- Audit current data protection practices: conduct an immediate audit of current national data protection policies to ensure they align with GDPR and EURODAC-specific requirements. Identify areas of weakness and implement stronger safeguards, particularly for sensitive biometric data.
- Leverage past data protection protocols: use the data protection frameworks established during the implementation of other large-scale systems (like SIS and VIS) to guide the management of EURODAC data. This helps ensure that privacy and security protocols are effective from the start.
Looking ahead: navigating the challenges of EURODAC reform
As European migration continues to evolve, the EURODAC reform represents a significant leap forward in creating a more secure and efficient asylum and migration management system. However, the complexities surrounding its implementation – from advanced IT infrastructure needs to alignment across multiple stakeholders – are notable challenges for Member States. The tight timeline for compliance adds further pressure, making it essential to act quickly and strategically.
Successful implementation will require not only a clear understanding of the new legislative framework but also the technical and operational capacity to integrate EURODAC with other critical EU systems. This is no small task, but with the right expertise and collaborative approach, Member States can turn these challenges into opportunities for more efficient migration management.
If you've made it this far, you're likely already preparing for the EURODAC reform. With so many moving parts, it’s natural to have questions or seek advice on the best approach. If you're looking to explore the most effective way forward, feel free to reach out—we’d be happy to continue the conversation. With over 20 years of experience supporting large-scale IT systems within the EU (EURODAC, SIS, VIS, EES, IO and sBMS), we can offer valuable insights into the impacts of EU legislation and help you prepare for the necessary system adaptations.
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