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EU – RUSSIA: Full Suspension of EU and Danish Visa Facilitation Agreements
September 13, 2022
Short stay visa applications more challenging for Russians
During an informal meeting by Foreign Affairs Ministers on August 31st, 2022 a political agreement was reached on a common and coordinated way forward when it comes to visa issuance for Russian citizens. This agreement has now been formalized when, on September 9th, 2022 the EU Council adopted Council Decision (EU) 2022/1500 to suspend the EU’s Visa Facilitation Agreement with Russia in whole, giving Member States wide discretion and greater scrutiny in processing short-stay visa applications from Russian citizens.
While Russian nationals are still able to apply for Schengen and EU national short stay visas, as of September 12th, 2022 the visa fee will increase from €35 to €80, and such applications will be processed with increased scrutiny. The European Commission has issued guidelines for the member states on how to process visa applications while the Facilitation Agreement is suspended. Among other things, these guidelines contain the following recommendations:
- Visa applications for non-essential reasons should be de-prioritised when allocating visa appointments.
- Processing times can go up from the 10 days under the Facilitation Agreement to up to 45 days, to ensure that sufficient scrutiny can be applied to the applications. Member states can e.g. decide to take such longer time for non-essential applications, which may allow for faster processing of applications for essential travel and for emergencies.
- Issuing visas with shorter validity and/or single-entry visas instead of multiple-entry visas should be considered, since the economic instability, the restrictive measures and political developments in Russia may increase the likelihood that applicants will no longer fulfil entry conditions over time.
- Travel insurance issued in Russia may be rejected, since claims against the insurance company might not be recoverable in a Member State due to the sanctions which are currently in place.
- Additional documents outside of the normal can be requested, where this is needed to ensure a high level of scrutiny, in particular in cases of possible threats to public policy, public order and international relations.
- Already issued visas for Russian nationals may be revoked if it becomes evident that the conditions for issuing a visa are no longer met.
It should be noted that long term permits and visas are not affected by this Decision, and Ireland is not bound by it.
Denmark has its own Visa Facilitation Agreement with Russia. In response to the EU suspension, it has decided to suspend this agreement as well and has issued a new Visa Executive Order on September 10th, 2022, which moves Russia from group 3 to group 5 of countries with a visa requirement, with immediate effect. This means that Russians can only apply for visas for private reasons in extenuating circumstances, such as a terminal illness or death in the family. Business visas can still be issued, but only in specific justified cases.
The Schengen-associated countries (Norway, Iceland, Switzerland and Liechtenstein) have their own bilateral visa facilitation agreements in force with Russia which replicate the Visa Facilitation Agreement. They are not bound by the Decision, but are expected to suspend their bilateral agreements as well, following their national procedures.
Newland Chase Insights
Companies who rely on Russian nationals to travel to the EU and Schengen for business or short term work up to 90 days are likely adversely affected by this Decision of the EU Council. Employers should expect to be required to provide more information about why the travel is essential, as well as to provide assurances of return of their employees to Russia after their activities are concluded. Frequent travel to EU/Schengen may be impaired due to the possible need of subsequent single entry visas, where previously multi-entry visas potentially could have been obtained, as well as due to the likely longer processing times. Companies may want to consider transferring their frequently travelling Russian nationals to one of their entities in the EU/Schengen.
Please reach out to Newland Chase for your specific questions about how these suspensions of agreements impact your company or if you want to discuss the options for your specific situation.
