Can an employer apply for ETIAS for an employee?

For travel, HR and operations teams deciding whether to handle ETIAS applications centrally or leave them with each traveller.

The short answer

Yes. The official ETIAS guidance allows another person, including a commercial intermediary, to submit an application on a traveller's behalf. The representative and the traveller must sign a declaration of representation, and the application must still go through the official ETIAS service.

Being allowed to apply is not the same as being the right owner. The traveller remains responsible for the accuracy of the application, and the application contains passport and personal details your company would then handle.

Applications are not open yet. When we last checked the official ETIAS site (opens in a new tab) on 15 October 2026, it said ETIAS was not operating and no applications were being accepted, with the start date to be announced ahead of launch. Anything offering to process an application today is not the official service.

Three ways to organise it

Start with the first row. Move down only when there is a real reason, because each step increases what the company must protect.

If the company submits the application

The official guidance points to a few safeguards worth building into your process:

1. Get the signed declaration of representation before submitting. Keep it with the trip record.
2. Let the employee check the answers first. They carry responsibility for accuracy, so they should see the full draft, not a summary.
3. Use an email address the employee can reach. The official guidance says ETIAS authorities may contact the applicant throughout the authorisation's validity, so a shared company inbox shouldn't be the only contact.
4. Use the official service only. Check the web address in the booking checklist, not just in the traveller's memory.
5. Pay the official fee through the official service. The fee is expected to be €20 for most applicants. Reimburse it under your travel policy; don't add an unexplained handling charge.

Keep as little personal data as you can

A passport number, date of birth and travel history are exactly the data an ordinary travel approval does not need to keep. For the approval itself, your records only need to show:

• which passport the authorisation is linked to, by nationality and expiry date rather than a stored scan;
• that the authorisation was valid, and its expiry date;
• who verified it, and when.

If your people team already has a policy for storing identity documents, apply it here. The ICO's guidance on monitoring workers (opens in a new tab) is a reasonable starting point for how much to collect and why. Check your own retention rules, or take advice, before holding application drafts or passport images.

A worked example

A UK company has a director who travels to Germany and Spain several times a year. Her assistant books everything and offers to submit the ETIAS application once the system opens.

That's workable if the director signs the declaration, reviews the full application before it goes in, and receives the confirmation at her own email address. The assistant records "valid to [date], linked to passport ending [last four characters]" in the trip file and deletes the draft.

If the director renews her passport next spring, the authorisation doesn't carry over. The assistant needs to repeat the check, because ETIAS is linked to the passport used in the application.

What ETIAS does not settle

A valid authorisation doesn't guarantee entry at the border, give permission to work, or add days to the Schengen allowance. Keep those checks separate:

• the 90/180-day position for every day of the planned stay;
• whether the employee may carry out the planned activity in that country; and
• the border record, covered in our EES versus ETIAS comparison.

The employer ETIAS checklist shows where each check fits in an approval flow, and the pre-trip checklist puts them in order for a single trip.

Sources and review date

• Official ETIAS guidance on applying on behalf of others (opens in a new tab)
• Official ETIAS FAQs on applications, fees and passports (opens in a new tab)
• ICO: data protection and monitoring workers (opens in a new tab)

Sources last checked: 2026-10-15.

ETIAS rules and dates are time-sensitive. Recheck the official EU site before changing your process. ComplyEur tracks Schengen day usage from the trips you record; it does not submit or verify ETIAS applications, and this article is not legal or immigration advice.

See team Schengen day forecasting or check the day count separately.