Digital Travel Credentials Adoption Within the EU: The Technology May Be Ready, But the Jury Is Still Out

The European Digital Rights (EDRi) network has responded to the European Commission’s (EC) public consultation request regarding the proposal for the digitalization of travel documents: a regulatory initiative at the core of the Commission’s Digital Europe Strategy and constituting a major step toward the adoption of Digital Travel Credentials (DTCs) within Europe. In a written submission to the EC on December 23, EDRi illustrates the procedural, proportionality, and rights-based issues raised by the EC’s DTC proposal. With the submission window to the public consultation closing on January 8, the EC will move to reviewing and potentially amending their proposal, either taking heed of EDRi and other bodies’ feedback or adopting the proposal in its present condition—a move that is unlikely to bode well for maximizing public and governmental support for DTCs.

In October, the EC put forward two proposals pertaining to the digitalization of travel credentials: the first on the establishment of an “EU Digital Travel Application” to accommodate the electronic submission of travel documentation, and the second seeks to enable DTC issuance based on EU identity cards, aligned with the International Civil Aviation Organization’s (ICAO) passport specifications. If successfully adopted, the EC’s proposals are expected to function as key cogs in the prospective Digital Travel machine, joining the growing regulatory arsenal pertaining to digital identity, including the European Digital Identity Regulation (eIDAS 2), which entered into force in May 2024. As the latest installment in the trend toward digitalization, DTCs are expected to act as a globally interoperable digital counterpart or substitute for passengers’ e-passports, composed of a virtual copy of the passport, transmitted to airport or border authorities before travel, and a physical copy retained by the user, either in the form of an e-passport (Type 1 DTCs) or in any form factor (smart device, smart card, etc.) that complies with the prospective ICAO technical specifications (Type 2, Type 3 DTCs). As the technology to create and support DTCs is an extension of existing digital identification systems, it is largely ready for deployment once sufficient testing and standardization (of DTC Types 2 and 3) is complete.

Given its progress in the digital wallet space and the eIDAS wallet’s capability for holding DTCs, Europe has a competitive edge in both the digital wallet and DTC sub-markets. Although alone unlikely to derail the global movement toward the digitalization of travel, EDRi’s concerns over the EC’s proposal’s disproportionate impact on privacy, freedom of movement, and non-discrimination have the potential to reverberate across the European community, inhibiting state and public acceptance of DTCs. In its submission to the EC, EDRi points to the pre-submission of passengers’ identity data as a means to create a potentially discriminatory infrastructure for mass surveillance, complaining that the proposal unjustifiably prioritizes unsubstantiated “efficiency” justifications at the expense of passengers’ right to privacy and freedom of movement, while simultaneously lacking sufficient detail as to the security measures taken to protect passengers’ biometric information collected via their DTCs. EDRi’s submissions are indicative of the wider security, privacy, and societal issues that the EC and other regulatory bodies must be willing to engage with if DTC adoption is to be successful.

To garner public trust and ensure meaningful dialogue that helps to boost acceptance and thus drive DTC uptake, vendors should:

• Prioritize the Usability of Prospective DTC Systems: Finding participants for DTC pilots within the EU has already proven to be burdensome and arduous onboarding processes likely to compound this difficulty. Accessibility for all prospective passengers regardless of deviations in digital literacy is crucial. Conformity with established usability standards such as the Web Content Accessibility Guidelines (WCAG 2.2) will be advantageous here.
• Keep DTC Use Optional, Rather Than Mandatory: DTC use should be meaningfully optional; ensuring that users who opt out of DTCs are not subject to disproportionate delays that render non-DTC travel practically unworkable. Vendors should pay heed to passenger complaints surrounding the Indian DigiYatra system where power imbalances between airport authorities and passengers have effectively usurped passengers’ ability to choose whether to use the DTC system.
• Clearly Detail the Security Measures Taken to Protect DTCs: Transparency as to how DTCs will be securely created, transmitted, and stored will help promote trust in vendors’ DTC solutions, boosting uptake and adoption.
• Substantiate Any Efficiency Justifications with Evidence: Given the national security implications of new technologies, the travel sector is naturally conservative with updating or modernizing its systems, thus requiring evidence from vendors as to the tangible benefits of their system. Vendors should focus on quantitative illustrations as to how DTCs will speed up border processing, balancing any efficiency gains with security and privacy considerations. Further, for passenger uptake, demonstrating how increased time spent at the preparatory phase, before travel, will be compensated by enhanced efficiency of travel at the border will be key to driving acceptance and, eventually, uptake of DTCs for travel.