Schengen: a Europe without borders?
Enlargements
The expanding borders of borderless Europe
The expanding borders of borderless Europe
The Schengen Agreement was originally signed in 1985 by five of the total of ten members of the European Community, France, West Germany, Belgium, Luxembourg and the Netherlands. They were the six founding members of the European Communities minus Italy.
Great Britain, Ireland and Denmark opposed the idea of giving up controls on their borders with Community partners. Being islands, Great Britain and Ireland relied much more than continental countries on border controls; the virtual inexistence of internal identity checks made London and, to a lesser extent, Dublin reluctant to abandon checks on people at borders. Denmark, meanwhile, did not have any intention of jeopardising relations with its partners in the Nordic Passport Union (see the chapter on Origins).
Greece and Italy were deliberately excluded. In 1985, Greece was a recent member of the European Community and still subjected to important limitations: fearing massive influx of Hellenic nationals into the Community, freedom of movement of Greek workers was postponed to 1988. Greece, in addition, did not have terrestrial borders with its Community partners and borders one of the countries with the highest potential migratory influx in the Euro-Mediterranean region: Turkey. At that time, Greece had neither laws nor instruments to effectively control its North-Eastern frontiers. The country itself did not see any urgent need to join the future borderless area.
Italy had wanted to join the Schengen Agreement since its inception, but its ambition was frustrated by the five founding members. France was particularly concerned that the abolition of border controls with Italy might encourage the influx of irregular migrants into the Schengen Area: these were persons who breached conditions of entry or the expiry of the legal basis for entering and residing in the host country. France also feared that the removal of checks at the common borders might favour the importation of terrorism and criminality originating or transiting through the peninsula.
The Convention implementing the Schengen Agreement made provisions for the enlargement of the Schengen Area. The expansion could prove that Schengen was a real European project, thereby overcoming objections in the European Commission and the European Parliament that the system was an alternative to the Community. The expansion could also contribute to legitimise and strengthen the European borderless area and pass a part of the political and financial costs of border management on to the peripheral members of the Community, later the European Union.
Every member of the Community could become a party to the system on the basis of an agreement between the acceding state and the contracting parties. Such an agreement was subject to ratification by the acceding country and each contracting party. Yet the ratification of the adhesion protocol did not coincide with the entry into the Schengen Area.
In order to effectively join the Schengen system, the acceding state should convince the Schengen Executive Committee, a governing body composed of one representative from each member, that it was able to meet all political and technical conditions to be considered as a fully-fledged Schengen member. Unlike then, the procedure to enter the Schengen Area is now supervised by the European Commission, the Council of the European Union and the European Parliament.
You can see the development of the Schengen area below:
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Italy was eventually allowed to sign the Schengen Agreements on 27 November 1990. This was after it removed geographical and temporal limitations on the refugee definition, adopted more restrictive measures against illegal immigration, imposed visa restrictions on sending countries in the Southern Mediterranean and acceded to a readmission agreement with France. Portugal and Spain followed suit on 25 June 1991, after having aligned with the more restrictive immigration legislation of the Schengen countries and imposed visas on emigration countries in the Southern Mediterranean and Central and Southern America. Greece, finally, signed the Schengen Agreements on 6 November 1992.
The road to entry into the Schengen Area, however, was difficult for all of them. The Schengen Executive Committee asked them to: adopt more restrictive approaches to immigration; adapt their international airports; create national bodies on asylum and refugee policies; and implement modern policies on the treatment of personal data. In addition, the Executive Committee put pressure on Spain to abandon its relatively tolerant policy on drugs.
Madrid was effective and quick to comply with these requests. Accordingly, Spain, together with Portugal, joined the Schengen Area at its inception on 26 March 1995. Unlike them, Italy was put on hold. It joined the Schengen Area only between 26 October 1997 and 31 March 1998, after having reassured all its partners, especially France, Germany and the Netherlands, that it was able to comply with all the main requests. Greece was considered ready to effectively patrol its external borders and comply with the political and technical conditions required to be a member of the Schengen Area two years later, between 1 January and 26 March 2000. The Mediterranean expansion was the first; in this sense, it provided a model for all subsequent enlargement waves.
The road to entry into the Schengen Area was easier but not shorter for Austria and the Scandinavian countries. A Germano-Austrian agreement signed in 1984 to ease controls at common borders did not produce great results. Not only was Austria not a member of the European Community, it was also close to the Balkans, an area which, according to West German police officials, could represent a threat in terms of international criminality and illegal immigration.
The process resumed in the context of the collapse of Communist regimes in Central and Eastern Europe, when Bonn asked its Schengen partners to accept its bilateral agreement with Vienna. The Convention implementing the Schengen Agreement mentioned this agreement but restricted the simplification of border checks to Austrian nationals. Austria signed the Schengen Agreements shortly after its entry into the European Union, on 28 April 1995. After some hesitancy from France, it joined the Schengen Area between 1 December 1997 and 31 March 1998.
The possibility of an agreement between the Community and the Scandinavian countries on the abolition of controls at common borders, strongly supported by West Germany, emerged as early as 1986. In the short term, however, this idea did not come to anything. As a consequence, Denmark, which was a member of the Nordic Passport Union with Finland, Iceland, Norway and Sweden, continued to stay outside the Schengen system, though it was a member of the European Community.
The entry of Finland and Sweden into the European Union in 1995 and the positive results of the Schengen system brought the Scandinavian question to the centre of the Schengen debate. While all the members of the Nordic Passport Union were willing to join the Schengen Area, a problem rested with Iceland and Norway, which were not members of the European Union. Despite scepticism about the entry of non-EU countries from the European Commission and some members , especially Belgium, all five states of the Nordic Passport Union were allowed to sign the Schengen Agreements on 19 December 1996. All of them joined the Schengen Area on 25 March 2001. The incorporation of the Schengen acquis into the legal system of the European Union in 1999 (see the chapter on Origins) constrained the EU to negotiate a special new agreement with Iceland and Norway and led Denmark to opt out of the Justice and Home Affairs pillar of the EU, while adopting the Schengen acquis on an intergovernmental basis.
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Switzerland had aimed to join the Schengen system since the early 1990s. After some hesitation, in 2001 the European Union consented to opening negotiations on Schengen association in return for Switzerland’s consent to negotiate an agreement on the taxation of savings and the fight against financial crimes. The Schengen association agreements with Iceland and Norway provided an incentive and a model. Switzerland, which remains outside the European Union, signed the Schengen agreements on 26 October 2004 and was formally associated with the Schengen Area between 12 December 2008 and 29 March 2009. Similarly, another non-EU country, Liechtenstein, signed the Schengen Agreements on 28 February 2008 and associated with the Schengen Area on 19 December 2011.
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Before their entry into the European Union on 1 May 2004, the Czech Republic, Estonia, Latvia, Lithuania, Hungary, Poland, Slovakia, Slovenia and Malta signed the Schengen Agreements on 16 April 2003. Although they initially lacked effective border control and immigration policies, they were able to rapidly comply with the accession conditions and, in particular, to align with the more restrictive approach to immigration which prevailed in Western Europe. Accordingly, they were allowed to join the Schengen Area relatively soon, between 21 December 2007 and 30 March 2008.
Bulgaria and Romania signed the Schengen Agreements two years later than other former Communist countries in Central and Eastern Europe, on 25 April 2005, and were constrained to wait much longer before joining the Schengen Area. Although the European Commission and the European Parliament supported their entry as early as 2011, a significant minority of countries in the Council of Ministers opposed the inclusion of Bulgaria and Romania into the Schengen Area, arguing that they were unable to effectively fight against corruption, organised crime and illegal migration flows transiting through their territories. Bulgaria and Romania joined the Schengen system only between 31 March 2024 and 1 January 2025, after that the most critical country, Austria, gave up its staunch opposition and reluctantly consented to their accession.
In the meantime, on 9 December 2011, Croatia signed the Schengen Agreements; it was the same day that it signed the treaty of accession to the European Union. After 11 years, Zagreb was able to reassure its partners about the effectiveness of its external border controls and to enter the Schengen Area, between 1 January and 26 March 2023.
The Schengen Area is now composed of 29 countries, all 27 members of the European Union apart from Cyprus and Ireland, plus all four members of the European Free Trade Association, i.e. Liechtenstein, Iceland, Norway and Switzerland. Though they are not full members, Andorra, Monaco, San Marino and Vatican City are de facto part of the Schengen Area. Ireland, which is a member of the Common Travel Area together with the United Kingdom, maintains its opt-out, while Cyprus is obliged to join the Schengen system once it fulfils all requirements. Its participation in the Schengen Area has been complicated by the Turkish occupation of the Northern part of the island, but the government in Nicosia is now hoping to enter the Schengen Area by the end of 2025. Meanwhile, on 11 June 2025, the European Union and Great Britain agreed that the British Overseas Territory of Gibraltar will be allowed to become part of the Schengen Area, while remaining under full British sovereignty.